Finding Text
CDFI Program – CFDA No. 21.024; Grant Nos. 21RRP057045: Grant period – December 31, 2022.
Condition: The Credit Union has contracted with a third-party vendor, Inclusiv, for CDFI reporting
purposes. According to Inclusiv’s reporting, the Credit Union met the closing financial products goal (loans deployed) in the designated target market (TM) requirement as reported on the Annual
Performance Report. Based on our testing, we were also able to support that the Credit Union
satisfied the requirements. However, we were unable to obtain a list of identifiable loans that met the eligibility requirements or documentation that validated the loan data reported by Inclusiv was reasonably accurate. In addition, the amount reported by the Credit Union was the total loans issued in 2022 versus the loans specific to the CDFI Rapid Response Program (RRP) grant.
Criteria: Eligible loans meeting an established threshold (performance goal) as outlined in the Grant Assistance Agreement are to be deployed within the TM.
Questioned Costs: None
Context: Eligible loan deployment as reported in the Performance Progress Report was overstated and were unable to be supported on an individual basis.
Effect: Performance goals as stipulated in the Grant Assistance Agreement may not be met or reported inaccurately.
Cause: There was not a control in place to validate Inclusiv’s analysis or specifically identify eligible loans reported on the Performance Progress Report.