Finding 598082 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-09-27
Audit: 27146
Auditor: Doeren Mayhew

AI Summary

  • Core Issue: The Credit Union reported meeting loan deployment goals but lacked documentation to verify the accuracy of the loan data.
  • Impacted Requirements: Loans reported did not specifically align with the CDFI Rapid Response Program, leading to potential inaccuracies in performance reporting.
  • Recommended Follow-up: Implement controls to validate third-party reporting and ensure identifiable loans meet eligibility criteria as per the Grant Assistance Agreement.

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.

Categories

Eligibility Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 21639 2022-000
    Significant Deficiency
  • 21640 2022-001
    Significant Deficiency
  • 21641 2022-002
    Significant Deficiency
  • 598081 2022-000
    Significant Deficiency
  • 598083 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.024 Community Development Financial Institutions Rapid Response Program (cdfi Rrp) $730,506
21.020 Community Development Financial Institutions Program $125,000