Audit of National Security Loan Program Recipient — MapLarge, Inc. (SIGPR-A-23-003)

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Summary

A final audit report issued May 14, 2024 by the Special Inspector General for Pandemic Recovery, Report Number SIGPR-A-23-003, on National Security Loan Program recipient MapLarge. The audit asked whether MapLarge followed the terms of its loan agreement with the U.S. Department of the Treasury under section 4003(b)(3) of the CARES Act, a $10 million loan made November 2, 2020 and maturing October 31, 2025. The report identifies no instances of noncompliance by MapLarge and finds that Treasury did not give sufficient guidance on accounting for loan proceeds, which were commingled with other company funds. It makes one recommendation, that Treasury guide participants in future loan programs; Treasury officials disagreed with the finding but generally agreed. It reports that as of November 1, 2023 Treasury had made loans to 35 borrowers, 14 of which had fully repaid.

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FINAL REPORT 
 
 
 
SIGPR-A-23-003 
 
FOR OFFICIAL USE ONLY  
 
Audit of National Security Loan Program 
Recipient – MapLarge, Inc.  
Report Number SIGPR-A-23-003 
May 14, 2024 
 
 
 
 

FINAL REPORT 
 
 
 
SIGPR-A-23-003 
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Executive Summary 
 
Audit of National Security Loan Program Recipient – MapLarge, Inc.  
Report Number SIGPR-A-23-003 
May 14, 2024 
 
Why We Performed This Audit 
We performed this audit as part of our ongoing audit work relating to section 4003 of the 
Coronavirus Aid, Relief, and Economic Security Act (CARES Act). MapLarge, Inc. 
(MapLarge) received a loan under the CARES Act section 4003(b)(3) and entered into a 
loan agreement with the U.S. Department of the Treasury (Treasury). The audit intends 
to determine if MapLarge is following the terms and conditions in its loan agreement 
with Treasury. 
  
 
What We Found 
We did not identify any instances of noncompliance by MapLarge with the terms and 
conditions of its loan agreement with Treasury. We found that MapLarge, Inc. was not 
provided sufficient guidance on how to account for loan proceeds.  
 
What We Recommended 
We recommend that Treasury officials: 
a. Provide sufficient guidance to participants in future loan programs to ensure that 
compliance with associated program restrictions can be monitored and 
independently verified.  
 
 

FINAL REPORT 
 
 
 
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Table of Contents 
Introduction .............................................................................................................. 1 
Results 
Finding 1 – Treasury did not provide sufficient guidance to MapLarge, Inc. related to 
accounting for loan proceeds. ................................................................. 3 
 
Conclusion ................................................................................................................ 5 
Recommendation ....................................................................................................... 5 
 
Appendixes 
Appendix A – Scope and Methodology .............................................................. A-1 
Appendix B – Agency Comments ....................................................................... B-1 
Appendix C – MapLarge, Inc. Comments ........................................................... C-1 
Appendix D – Report Distribution ....................................................................... D-1 

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Introduction 
The Special Inspector General for Pandemic Recovery (SIGPR) was established by 
section 4018 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Under 
the CARES Act, SIGPR has the duty to conduct, supervise, and coordinate audits and 
investigations of the making, purchase, management, and sale of loans, loan guarantees, 
and other investments made by the Secretary of the Treasury under any program 
established by the Secretary, as well as the management by the Secretary of any program 
established under subtitle A of title IV of division A of the CARES Act. SIGPR also has 
the duties, responsibilities, powers, and authorities granted inspectors general under the 
Inspector General Act of 1978. We performed an audit of MapLarge, Inc. (MapLarge) to 
determine if MapLarge complied with the provisions in the CARES Act, and if it followed 
the terms and conditions of its loan and guarantee agreement. 
 
Purpose 
The SIGPR Office of Audits has the mission to conduct audits of loans, loan guarantees, 
and other investments made by the U.S. Department of the Treasury (Treasury) under 
programs within SIGPR’s jurisdiction. Section 4003(b)(3) of the CARES Act authorized 
loans of up to $17 billion to help stabilize businesses critical to maintaining national 
security. In November 2020, Treasury agreed to make a loan totaling $10 million to 
MapLarge. The purpose of this audit is to determine if MapLarge is following the terms 
and conditions in its loan agreement with Treasury. 
 
Objective 
The objective of SIGPR’s Audit of National Security Loan Program Recipient – 
MapLarge, Inc. is to determine if MapLarge is following the terms and conditions of its 
loan agreement with Treasury. 
See Appendix A – Scope and Methodology for additional details. 
 
Background 
Section 4003 of the CARES Act authorized Treasury to make loans, loan guarantees, 
and other investments to provide liquidity to eligible businesses related to losses 
incurred because of the coronavirus pandemic. Under this program, Treasury provided 
approximately $2.7 billion in loans to 35 eligible businesses, including passenger air 
carriers, repair station operators, ticket agents, cargo air carriers, and businesses 
critical to maintaining national security.  

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As of November 1, 2023,  
• Treasury made loans to 35 borrowers; 
• 14 borrowers have fully repaid their loans; 
• 21 borrowers have a combined outstanding loan amount of nearly $954 million; 
• Nearly $1.8 billion in principal has been repaid; and 
• More than $160 million cash interest has been collected.1 
 
MapLarge is a software product company in the geospatial mapping industry that 
delivers location intelligence solutions to Fortune 1000 enterprise and government 
customers. It is a privately held S corporation with two primary shareholders 
headquartered in Atlanta, Georgia. MapLarge’s designation as a business critical to 
maintaining national security was partly based on National Industrial Security Program 
regulations (32 C.F.R. Part 2004).  
On November 2, 2020, Treasury made a $10 million loan to MapLarge pursuant to 
section 4003(b)(3) of the CARES Act. The loan proceeds were to be used to provide 
liquidity to continue the company’s operations. The loan is unsecured, has an interest 
rate equal to LIBOR (London Interbank Offered Rate) plus 5.5 percent, and matures on 
October 31, 2025. The loan agreement includes covenants by MapLarge to comply with 
certain restrictions including its use of loan proceeds, employee compensation, stock 
repurchases, dividends, and reductions in employment levels, as required by the 
CARES Act. The loan is a senior debt instrument with 3 percent annual payment-in-kind 
interest due to Treasury according to section 4003(d) of the CARES Act. 
 
Status of Treasury Loan to MapLarge as of 11/1/2023 
Source: U.S. Department of the Treasury. Report Under Section 4026(b)(1)(C) of the CARES Act on Loans to Air 
Carriers, Eligible Businesses, and National Security Businesses (November 1, 2023). https://home.treasury.gov/ 
system/files/136/4026b1CLoanReport11012023.pdf 
 
 
 
1 U.S. Department of the Treasury. Report Under Section 4026(b)(1)(C) of the CARES Act on Loans to 
Air Carriers, Eligible Businesses, and National Security Businesses (November 1, 2023). 
https://home.treasury.gov/system/files/136/4026b1CLoanReport11012023.pdf 
Loan Amount 
Date of 
Loan 
Agreement 
Maturity 
Date 
Total 
Outstanding 
Loan Amount 
Total 
Repaid 
Principal 
Cash 
Interest 
Receipts 
$10,000,000 
11/2/2020 
10/31/2025 
$12,466,393 
$0 
$987,600 

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Results 
We did not identify any instances of noncompliance by MapLarge with the terms and 
conditions of its loan agreement with Treasury. We found that Treasury did not provide 
sufficient guidance to MapLarge, Inc. to account for expenditures of loan proceeds. This 
may have led to co-mingled loan proceeds with normal operating funds. It therefore 
cannot be determined if MapLarge used loan proceeds for non-operating expenses. 
 
Finding 1 – Treasury did not provide sufficient guidance to MapLarge, Inc. related 
to accounting for loan proceeds. 
Treasury did not provide sufficient guidance to MapLarge relating to accounting for loan 
proceeds, which made it difficult to independently verify whether MapLarge’s use of loan 
proceeds was restricted to expenses stipulated in its loan agreement. When MapLarge 
received its loan proceeds, the entire amount was deposited into an existing bank 
account, which contained other cash balances of the company. Once the funds were 
comingled, the fungibility of cash made it difficult – if not impossible – for Treasury, or 
an independent third-party such as SIGPR, to determine whether loan proceeds were 
used for purposes allowed under the terms of the loan agreement.  
According to internal documents obtained from MapLarge executives, MapLarge began 
using the proceeds of its loan during the second quarter of 2021. At the end of the 
fourth quarter of 2022, roughly $1.5 million of proceeds remained and were being held 
in reserve. MapLarge executives stated that they did not receive any formal guidance 
from Treasury on how to account for National Security Loan expenditures. MapLarge 
developed its own system to track loan expenditures and ensure compliance with the 
terms of its loan and guarantee agreement.  
The loan agreement between MapLarge and Treasury places restrictions on the use of 
loan proceeds. For example, borrowers may not use loan proceeds “for any purpose 
other than for general corporate purposes and operating expenses…provided, however, 
that the proceeds…shall not be used for any non-operating expenses….” However, 
Treasury did not provide sufficient guidance regarding the accounting for loan proceeds 
to recipients. Therefore, Treasury must rely on borrower self-reporting and cannot 
independently verify that loan proceeds are being used according to the terms of its 
loan agreement.  
Standards for Internal Control in the Federal Government (the Green Book) sets internal 
control standards for Federal entities. The internal control standards consist of five 
components and each component has a number of principles which outline the 
requirements of each component. Among the principles related to the Information and 
Communication component, the Green Book states “management should externally 
communicate the necessary quality information to achieve the entity’s objectives.”2 By 
not providing guidance to MapLarge on how to account for its use of the loan proceeds, 
Treasury did not adhere to this principle. Treasury should have communicated 
necessary information to MapLarge to ensure that one of the loan program’s objectives 
 
2 Principle 15, Standards for Internal Control in the Federal Government (GAO-14-704G), 62. 

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– a restriction on the use of loan proceeds – would be met and could be monitored for 
compliance. 
When asked why Treasury restricted the use of proceeds but did not provide guidance 
on how to account for loan proceeds separately from other funds, Treasury officials 
replied, 
Treasury believed that the loan agreements adequately explained the restrictions 
on use of proceeds to the borrowers. Under the Loan Agreement, the permissible 
uses of 4003 loan proceeds were broad: “general corporate purposes and 
operating expenses (including payroll, rent, utilities, materials and supplies, 
repair and maintenance, and scheduled interest payments on other Indebtedness 
incurred before February 15, 2020.” 4003 Loans were generally made to more 
sophisticated recipients then [sic] some of our other programs, and Treasury 
considered that these entities would likely be able to comply with restrictions 
without further guidance. Treasury did not believe it necessary to prescribe to 
borrowers how such funds should be maintained. 
Our review of MapLarge records showed that MapLarge employees tracked the 
amounts of loan proceeds used to pay for (1) payroll, (2) salaries and wages, and (3) 
rent, which are all allowable expenses under the terms of its agreement, by quarter. 
MapLarge executives contend that loan proceeds were not used for any other 
expenses. However, because MapLarge comingled loan proceeds with funds from other 
sources, it is impossible to independently validate this claim. 
To help ensure borrower compliance with the terms of its loan agreements, Treasury 
has a quarterly “Review Card” process. As part of this process, borrowers must enter 
responses to Treasury’s monitoring questions through a Salesforce portal. Treasury 
developed the Review Card questions to monitor compliance in a variety of areas, 
including the use of the loan proceeds. However, the Review Card process relies 
primarily on borrower certifications. If a borrower’s self-reporting is incomplete or 
indicates non-compliance, Treasury may initiate a more detailed review. 
As part of the quarterly Review Card process, Treasury requests information from the 
borrower on its use of the loan proceeds. However, unless the borrower self-reports that 
it used direct loan proceeds for expenses other than operating expenses or general 
corporate purposes, the borrower will get a pass for the Direct Loan Spending portion of 
the Review Card. MapLarge has received a pass on all Review Cards relating to proper 
use of loan proceeds. 
When asked why Treasury relied on self-certification from loan recipients when 
completing the Review Card process, Treasury officials replied, 
Treasury monitors its borrowers’ compliance through a multipronged approach. 
Each quarter, Treasury requires borrowers to respond to a compliance 
questionnaire that is administered through Treasury’s award management 
system. Borrowers are also required to submit certain documents, including 
collateral coverage ratio certificates, to Treasury’s financial agent serving as the 
administrative and collateral agent under the loan agreements. Treasury’s 
financial agent collects principal and interest payments on loans that are 

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reconciled by Treasury. In addition, Treasury communicates regularly with 
borrowers and reviews financial statements and borrowers’ reports filed with the 
Securities and Exchange Commission for publicly traded companies. 
Only one of those prongs relies on self-certification from loan recipients. Treasury 
allocated its scarce resources using a risk-based approach, and determined that 
requiring borrowers to self-certify, under penalty of perjury, for certain 
requirements would adequately protect taxpayer interests. 
 
Conclusion 
We did not identify any instances of noncompliance by MapLarge with the terms and 
conditions of its loan agreement with Treasury. However, Treasury did not provide 
MapLarge sufficient guidance on how to account for loan proceeds which made 
Treasury noncompliant with internal control standards. This lack of guidance led 
MapLarge to co-mingle its loan proceeds with existing funds which made it difficult to 
independently verify whether MapLarge used loan proceeds according to the terms of 
its loan and guarantee agreement. 
 
Recommendation 
We recommend that Treasury officials: 
1. Provide sufficient guidance to participants in future loan programs to ensure that 
compliance with associated program restrictions can be monitored and 
independently verified. 
 
Agency Comments 
Treasury officials did not agree with our finding that Treasury did not provide sufficient 
guidance to MapLarge related to accounting for loan proceeds. Treasury officials cite 
the following as reasons for disagreeing with our finding: 
• The absence of – 
• a Treasury prohibition on the co-mingling of funds by borrowers or  
• a Treasury requirement for the segregation of loan proceeds; 
• Treasury’s use of “typical approaches” for federal loan programs and “standard 
commercial practice;” and  
• The terms of Treasury’s National Security Loan Program loan agreement with 
MapLarge. 
Treasury officials did however agree, in general, with our recommendation to provide 
sufficient guidance to participants in future loan programs to ensure that compliance 
with associated program restrictions can be monitored and independently verified. 
Additionally, Treasury officials stated that “Treasury will give serious consideration to 
providing additional guidance, which in appropriate circumstances could include 
requiring borrowers to establish segregated accounts for loan proceeds. However, 
depending on the circumstances, certain factors may weigh against imposing such a 

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requirement.” Treasury’s management response is included, in its entirety, in Appendix 
B. 
 
SIGPR Response 
Although we do not agree with Treasury that the guidance to MapLarge was sufficient, 
we commend Treasury for its consideration to provide additional guidance to borrowers 
participating in future loan programs. This could include requiring borrowers to establish 
a separate account for loan proceeds, among other things. It is important that loan 
programs such as the National Security Loan Program operate with transparency into 
the use of taxpayer funds and that federal agencies maintain internal control to meet 
that objective.  
 
Audit Team 
This audit was managed and conducted by the individuals listed below: 
 
 
Michael Sinclair 
Audit Manager 
Reynaldo Gonzales 
Auditor-In-Charge 
 
 
 

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Appendix A – Scope and Methodology 
Scope and Methodology 
Our objective was to determine if MapLarge is in compliance with the terms of its loan 
agreement with Treasury. 
To accomplish our objective, we: 
• Interviewed Treasury’s program officials charged to handle MapLarge’s loan; 
• Reviewed CARES Act section 4003 requirements; 
• Reviewed the Loan and Guarantee Agreement and Pledge and Security 
Agreement between MapLarge, Treasury, and the Bank of New York Mellon; 
• Reviewed Treasury’s process for monitoring the loan through Salesforce Review 
Cards; and 
• Conducted a site visit to MapLarge to interview MapLarge officials and review 
financial information related to the loan. Specifically, we reviewed payroll records, 
general ledger detail for certain accounts, and MapLarge’s loan tracker 
worksheet.  
We conducted this performance audit between March 2023 and January 2024 in 
accordance with generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, appropriate evidence to 
provide a reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 
Internal Control  
We assessed internal control and compliance relating to the context of our audit against 
Standards for Internal Control in the Federal Government (GAO-14-704G) and with laws 
and regulations necessary to satisfy the audit objective. The methodology above 
describes the scope of our assessment, and the report findings include any internal 
control deficiencies we identified. Our assessment is not intended to provide assurance 
on Treasury’s internal control structure as a whole. Treasury management is 
responsible for establishing and maintaining an effective system of internal control. 
 

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Appendix B – Agency Comments 
 

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Appendix C – MapLarge, Inc. Comments 

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Appendix D – Report Distribution 
Chief Program Officer – U.S. Department of the Treasury, Office of Capital Access 
General Counsel – U.S. Department of the Treasury, Office of General Counsel 
Chief Executive Officer – MapLarge, Inc. 
Chief Technology Officer – MapLarge, Inc. 
Special Inspector General – Special Inspector General for Pandemic Recovery 
Deputy Inspector General – Special Inspector General for Pandemic Recovery 
Assistant Inspector General for Auditing – Special Inspector General for Pandemic 
Recovery 
General Counsel – Special Inspector General for Pandemic Recovery

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