Court filing
SIGPR-A-22-003-12 — Independent Review: SpinLaunch Validation Memo (September 2022)
Record facts
| Court | Special Inspector General for Pandemic Recovery (SIGPR) |
|---|---|
| Filed | 2022-09-27 |
Summary
Report Number SIGPR-A-22-003-12, dated September 27, 2022, is an independent review by the Special Inspector General for Pandemic Recovery (SIGPR) of the Treasury Validation Memo for SpinLaunch Inc., addressed to Treasury's Chief Recovery Officer. The report states that SpinLaunch applied on May 1, 2020 for a $15 million loan under Section 4003 of the CARES Act and that on November 13, 2020 it and Treasury agreed to a $2.5 million loan, making it a Tier 3 borrower. SIGPR reports that it is not aware of any material modifications that should be made to the Validation Memo. It lists two discrepancies it considers inconsequential: the memo noted a $20,000,000 allocation, and it stated a $1.05 million Payroll Protection Program award that the audit team found was fully cancelled before disbursement. Appendices set out the objective, scope and methodology and the report distribution.
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Full text
SIGPR-A-22-003-12 Independent Review of 4003(b) Loan Recipient’s Validation Memo – SpinLaunch Inc. Report Number: SIGPR-A-22-003-12 September 27, 2022 SIGPR-A-22-003-12 i September 27, 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 – SpinLaunch Inc. This report presents the results of our review of the Validation Memo associated with SpinLaunch Inc.’s (SpinLaunch) application submission to the Department of the Treasury (Treasury). SpinLaunch received a $2.5 million 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 May 1, 2020, SpinLaunch applied for a loan under Application Number NSL- 200430000043. 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 SpinLaunch 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-22-003-12 1 Introduction Section 4003 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 National Security Loan Program (NSLP) 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 up to $20 million and no less than $250,000. Background On May 1, 2020, SpinLaunch applied for a $15 million loan under Section 4003 of the CARES Act. On November 13, 2020, SpinLaunch and the Department of the Treasury agreed to a $2.5 million loan. Based on its loan amount, SpinLaunch is classified as a Tier 3 borrower. During the application period, applicants were required to submit documents through a Treasury web portal. For each applicant to move forward in the loan process, they had to provide a financial plan, IRS Form 941s, and financial statements, among other documentation. Depending on the applicant’s type of business additional documentation was also required. For instance, businesses critical to maintaining national security had to provide proof of a DX contract, a Top- Secret Facility Clearance, or a Secretary of Defense or Secretary of National Intelligence certification. 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. SIGPR-A-22-003-12 2 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 SpinLaunch to comply with Treasury’s Underwriting Guide. However, we identified the following discrepancies in the completion of the Validation Memo that we consider inconsequential: 1) The Treasury Reviewer noted that SpinLaunch was allocated a $20,000,000 loan. However, they were awarded only a $2.5 million loan. 2) The Reviewer also stated that SpinLaunch was awarded $1.05 million through the Payroll Protection Program. The audit team utilized SIGPR’s Data Analytics Library and confirmed that a Payroll Protection Program loan had been originated, however was fully cancelled prior to being disbursed to SpinLaunch. 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 by the individuals listed below: Michael Sinclair Audit Manager Renata Malionek Management Analyst SIGPR-A-22-003-12 A-1 Appendix A – Objective, Scope and Methodology We have reviewed SpinLaunch’s submission of loan documents under Application Number NSL-200430000043. Treasury was responsible for obtaining SpinLaunch’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 SpinLaunch was completed according to Treasury’s Underwriting Guide and other applicable criteria, and fairly presents the supporting documentation provided by SpinLaunch in all material respects. Treasury’s efforts culminated in the completion of the Validation Memo. Additionally, this review is an offshoot of the overall audit 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 SpinLaunch’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-22-003-12 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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