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SIGPR-A-22-003-1 — Independent Review: Frontier Airlines Validation Memo (March 2022)

Record facts

CourtSpecial Inspector General for Pandemic Recovery (SIGPR)
Filed2022-03-22

Summary

Report Number SIGPR-A-22-003-1, dated March 22, 2022, from the Assistant Inspector General for Auditing of the Special Inspector General for Pandemic Recovery (SIGPR) to the Chief Recovery Officer of the U.S. Department of the Treasury. It reviews the Validation Memo Treasury completed for Frontier Airlines, Inc.'s application, filed April 16, 2020, for a $498,000,000 loan under Section 4003 of the CARES Act. The report states that Treasury later increased Frontier's allocation by $76 million to $574 million, and classifies Frontier as a Tier 1 borrower. It concludes that SIGPR is not aware of any material modifications that should be made to the Validation Memo to comply with Treasury's Underwriting Guide. Appendices set out the objective, scope and methodology of the review and the report distribution.

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Full text

SIGPR-A-22-003-1 
   
 
 
 
 
Independent Review of 4003(b) Loan Recipient’s  
Validation Memo – Frontier Airlines, Inc.   
 
Report Number: SIGPR-A-22-003-1 
March 22, 2022 
 
 
 
 

 
SIGPR-A-22-003-1  
i 
  
March 22, 2022 
 
TO: 
Jacob D. Leibenluft   
Chief Recovery Officer 
U.S. Department of the Treasury 
FROM: 
Theodore R. Stehney 
Assistant Inspector General for Auditing 
Special Inspector General for Pandemic Recovery (SIGPR) 
SUBJECT: 
Independent Review of 4003(b) Loan Recipient’s  
Validation Memo – Frontier Airlines, Inc.   
 
This report presents the results of our review of the Validation Memo associated with 
Frontier Airlines, Inc.’s (Frontier) application submission to the Department of Treasury 
(Treasury). Frontier applied for a $498,000,000 loan under Section 4003, Division A 
Title IV, Subtitle A of the Coronavirus Aid, Relief, and Economic Security Act of 2020 
(the “CARES Act”).  
On April 16, 2020, Frontier applied for a loan under Application Number LA-
2004160247. All applicants had to provide specific documentation along with their 
applications to be further considered to receive a loan, as outlined in Treasury’s 
Underwriting Guide. Treasury completed a Validation Memo once it received and 
reviewed an applicant’s document submissions. Once the Validation Memo was 
completed, Treasury forwarded the application to the next level of the underwriting 
process.   
Based on our review, we are not aware of any material modifications that should be 
made to the Validation Memo that Treasury completed for Frontier to comply with 
Treasury’s Underwriting Guide.   
Please address questions regarding this report to Michael Sinclair at (202) 923-8021 or 
Michael.Sinclair@sigpr.gov. 
 
 

 
SIGPR-A-22-003-1  
1 
  
Introduction  
Section 4003, Division A Title IV, Subtitle A of the CARES Act authorizes the Treasury 
to make loans, loan guarantees, and other investments to provide liquidity to eligible 
businesses related to losses incurred as a result of the coronavirus pandemic. Sections 
4003(b)(1)-(3) appropriated $46 billion to help stabilize the airline industry and 
businesses critical to maintaining national security.   
The breakdown of available funding was as follows: 
1. Up to $25 billion for passenger air carriers; businesses certified to perform 
inspection, repair, replace or overhaul services; and ticket agents; 
2. Up to $4 billion for cargo air carriers; and 
3. Up to $17 billion for businesses critical to maintaining national security.    
Section 4003 loans were further categorized by the loan amount requested. The Air 
Carrier Loan Program is categorized into tiers as follows: Tier 1 loans were above 
$300 million, Tier 2 loans were between $20 million and $300 million, and Tier 3 
loans were under $20 million.   
 
Background 
On April 16, 2020, Frontier applied for a for $498 million loan under Section 4003 of 
the CARES Act. As a result of additional CARES Act funding availability, Treasury 
increased Frontier’s allocation by $76 million to $574 million. Based on its loan 
amount, Frontier is classified as a Tier 1 borrower.  
During the application period, applicants were required to provide multiple 
documents, as identified in the Underwriting Guide. For each applicant to move 
forward in the loan process, they had to provide financial statements, a financial 
plan, and certain IRS forms, among other documentation. Depending on the 
applicant’s type of business additional documentation was also required. For 
instance, air carriers had to provide their Department of Transportation certification 
as such under Section 40102(a) of Title 49, United States Code. All documentation 
provided was to be maintained by Treasury.   
Once the required documentation was compiled, Treasury verified and recorded it 
using a Validation Memo.  A completed and signed Validation Memo allowed the 
applicant to move forward to the loan underwriting process.   
  
Results in Brief 
Based on our review, we are not aware of any material modifications that should be 
made to the Validation Memo Treasury completed for Frontier to comply with Treasury’s 
Underwriting Guide.   

 
SIGPR-A-22-003-1  
2 
  
Compliance Statement 
We conducted our review in accordance with generally accepted government auditing 
standards for attestation engagements. Those standards require that we plan and perform 
the review to obtain limited assurance that the Validation Memo is fairly presented in all 
material respects and completed according to Treasury’s Underwriting Guide. A review is 
substantially less in scope than an examination, the objective of which is to obtain 
reasonable assurance and express an opinion on the subject matter. Accordingly, we do 
not express such an opinion. We believe that our review provides a reasonable basis for 
our conclusion.   
 
Audit Team 
This review was conducted the individuals listed below: 
Kevin Gallagher 
Audit Manager   
Michael Sinclair 
Audit Manager   
 
 

 
SIGPR-A-22-003-1 
A-1 
 
Appendix A – Objective, Scope and Methodology 
 
We have reviewed Frontier Airlines Inc. submission of loan documents under 
Application Number LA-2004160247. Treasury was responsible for obtaining Frontier’s 
loan documentation and completing the Validation Memo in accordance with its 
Underwriting Guide prior to moving the application further in the loan process. Our 
responsibility is to express a conclusion about whether any material modification should 
be made to the Validation Memo for it to be in accordance with Treasury’s Underwriting 
Guide and be fairly stated.  
The objective of this review is to evaluate whether Treasury’s Validation Memo for 
Frontier was completed according to Treasury’s Underwriting Guide and other 
applicable criteria, and fairly presents the supporting documentation provided by 
Frontier in all material respects. Treasury’s efforts culminated in the completion of the 
Validation Memo. Additionally, this review is an offshoot of the overall examination of 
the 4003(b) loan program.  
We primarily performed this review remotely due to the ongoing telework situation 
dictated by the pandemic. We therefore relied on mostly electronic records for our 
review.  
To accomplish the review objective, our fieldwork included, but was not limited to, the 
following procedures: 
• Reviewed Treasury’s Underwriting Guide and determined the documents 
required by all applicants;  
• Reviewed Frontier’s Validation Memo for completeness and accuracy; 
• Determined if the document submissions were complete and accurate;  
• Requested additional documentation from Treasury officials when needed; and 
• Held discussions with Treasury officials when applicable.  
The review was conducted in accordance with generally accepted government auditing 
standards for attestation engagements.  
 
 

 
SIGPR-A-22-003-1 
B-1 
 
Appendix B – Report Distribution 
 
Chief Recovery Officer – U.S. Department of the Treasury  
Office of General Counsel – U.S. Department of the Treasury  
Inspector General – Special Inspector General for Pandemic Recovery 
Asst. Inspector General for Auditing – Special Inspector General for Pandemic 
Recovery 
Office of General Counsel – Special Inspector General for Pandemic Recovery

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