Management acknowledges that controls were not in place to properly monitor when Federal awards were expended in compliance with CDFI programs to accurately report to CDFI FUND, which will be addressed through comprehensive training with GAC’s CDFI award compliance consultants. The Vice President of Finance, GAC’s Executive Director, and the accounting/loan servicing team will participate in multiple rounds of Federal award compliance training. Further, a compliance specialist with an accounting background will be engaged to meet regularly with the Executive Director and Vice President of Finance to ensure proper monitoring of Federal awards and accurate CDFI FUND reporting. In addition, the GAC team will meet regularly to discuss new loan closings and whether the funds deployed should be sourced to Federal awards or other non-Federal tranches of funds.