Finding FA 2023-004: Special Tests and Provisions – Using a Servicer or Financial Institution to Deliver
Title IV Credit Balances to a Card or Other Access Device – Failure to Submit URL to the Secretary of
Education for Publication in a Centralized Database Accessible to the Public
Federal Catalog Number: ALN 84.007, 84.033, 84.038, 84.063, and 93.364
Federal Program Name: Student Financial Assistance Cluster:
Federal Supplement Educational Opportunity Grants
(FSEOG)
Federal Work-Study Program (FWS)
Federal Perkins Loan Program
Federal Pell Grant Program
Federal Direct Student Loans
Nursing Student Loans (NSL)
Federal Agency: U.S. Department of Education (ED)
Passed Through Entity: N/A
Federal Award Number: FSEOG
P007A210450, P007A210365, P007A210451,
P007A210452, P007A210453, P007A210455,
P007A210456, P007A210457, P007A210676
FWS
P033A210450, P033A210365, P033A210451,
P033A210452, P033A210453, P033A210455,
P033A210456, P033A210457, P033A210676
Pell
P063P210033, P063P215263, P063P210034,
P063P210658, P063P210035, P063P215261,
P063P215260, P063P210036, P063P215262
NSL
P268K220033, P268K225263, P268K220034,
P268K220658, P268K220035, P268K225261,
P268K225260, P268K220036, P268K225262
Federal Award Year: July 1, 2022, to June 30, 2023
Campuses: Los Angeles Community College District
Compliance Requirement: Special Tests and Provisions: Using a Servicer or
Financial Institution to Deliver Title IV Credit Balances to
a Card or Other Access Device
Criteria or Specific Requirements:
Per 34 Code of Federal Regulations 668.164 Disbursing Funds:
In Tier One (T1) arrangement, an institution located in a State has a contract with a third-party servicer under
which the servicer performs one or more of the functions associated with processing direct payments of Title IV,
HEA program funds on behalf of the institution. The institution or third-party servicer makes payments to one or
more financial accounts that are offered to students under the contract; a financial account where information
about the account is communicated directly to students by the third-party servicer, or the institution on behalf of
or in conjunction with the third-party servicer; or a financial account where information about the account is
communicated directly to students by an entity contracting with or affiliated with the third-party servicer.
Institutions with a T1 arrangement should ensure that no later than September 1, 2017, and then no later than
60 days following the most recently completed award year thereafter, disclose conspicuously on the institution’s
Website and in a format established by the Secretary of Education the total consideration for the most recently
completed award year, monetary and non-monetary, paid or received by the parties under the terms of the
contract; and for any year in which the institution’s enrolled students open 30 or more financial accounts under
the T1 arrangement, the number of students who had financial accounts under the contract at any time during
the most recently completed award year, and the mean and median of the actual costs incurred by those
account holders.
The institution should also provide the Secretary with an up-to-date Uniform Resource Locator (URL) for the
contract and contract data as described above for publication in a centralized database accessible to the public.
Identified Condition:
We noted that the District’s URL link to the contract with BMTX, Inc. (BankMobile) and other required
information was not included in the latest Cash Management Contracts Database published by ED on
March 2022 as the District was unable to provide the URL link to ED for the award year ended June 30, 2023.
Cause and Effect:
Due to a miscommunication between the District staff and Bankmobile staff, the website link was not submitted
to the Department of Education, although the report was published and available to the public.
Questioned Costs:
None.
Recommendation:
We recommend that the District review its roles and responsibilities with Bankmobile and implement control
procedures to ensure that the District remains compliant with the requirements of Uniform Guidance and the
Code of Federal Regulation.
Views of Responsible Officials and Planned Corrective Actions:
The District has taken responsibility for providing the Department of Education with the website link and will
provide that going forward.
Personnel Responsible for Implementation: Nyame-Tease Prempeh
Position of Responsible Personnel: Assistant Director of Accounting
Expected Date of Implementation: November 1, 2023