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Audit Report - Oig 24 037 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of The Communi

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Department of the Treasury Office of Inspector General Audit Report OIG-24-037, Audit of the Community Development Financial Institutions Fund's Award and Post-Award Administration of the CDFI Equitable Recovery Program, dated September 25, 2024, addressed to Pravina Raghavan, Director of the CDFI Fund. It states that the audit assessed the award process for ensuring the accuracy of CDFI ERP payments and the design of post-award administration, covering activities from June 24, 2022 through November 30, 2023, including a statistical sample of 27 payments totaling $58 million from 596 payments totaling approximately $1.4 billion. The Results in Brief states that the CDFI Fund accurately issued the sampled payments and designed the post-award process in compliance with applicable guidance, and that the OIG did not make any recommendations.

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Inspector general and oversight reports
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Audit Report
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Oig 24 037 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of The Communi

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Audit Report




OIG-24-037

CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS


Audit of the Community Development
Financial Institutions Fund's Award and Post-
Award Administration of the CDFI Equitable
Recovery Program

September 25, 2024

Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
Contents

Audit Report
Results in Brief .............................................................................................. 3

Background ................................................................................................... 4

Audit Results ............................................................................................... 12

Next Steps .................................................................................................. 23


Appendices
Appendix 1: Objective, Scope, and Methodology ............................................. 24
Appendix 2: Management Response ............................................................... 32
Appendix 3: Major Contributors to This Report ................................................ 33
Appendix 4: Report Distribution ..................................................................... 34



Abbreviations
ACR                             Annual Certification and Data Collection Report
AMIS                            Awards Management Information System
Assistance Agreement            CDFI ERP Assistance Agreement
CAA, 2021                       Consolidated Appropriations Act, 2021
CDFI                            Community Development Financial Institutions
CDFI ERP                        CDFI Equitable Recovery Program
CFR                             Code of Federal Regulations
COVID-19                        Coronavirus Disease 2019
FSA                             Financial Statement Audit
FY                              Fiscal Year
GAO                             Government Accountability Office
Green Book                      Standards for Internal Control in the Federal Government
NOFA                            Notice of Funds Availability
OCME                            Office of Compliance Monitoring and Evaluation
OIG                             Office of Inspector General
OMB                             Office of Management and Budget
PG&Ms                           Performance Goals and Measures
SF                              Standard Form
SOPs                            standard operating procedures
TLR                             Transaction Level Report


                                                                                                                i
Treasury           Department of the Treasury
Uniform Guidance   Uniform Administrative Requirements, Cost Principles, and
                   Audit Requirements for Federal Awards, 2 CFR Part 200




                                                                           ii
This Page Intentionally Left Blank
                        September 25, 2024

                        Pravina Raghavan
                        Director of the Community Development Financial Institutions
                        Fund

                        This report presents the results of our audit of the Community
                        Development Financial Institutions (CDFI) Fund's award and
                        post-award administration of the CDFI Equitable Recovery
                        Program (CDFI ERP). Title V, Subtitle B in Division N of the
                        Consolidated Appropriations Act, 2021 (CAA, 2021) 1
                        authorized the CDFI Fund to provide emergency support to
                        CDFIs 2 and communities responding to the economic impact of
                        the Coronavirus Disease 2019 (COVID-19) pandemic.
                        Furthermore, the Department of the Treasury's (Treasury) Office
                        of Inspector General (OIG) is required to submit a report no less
                        than twice a year to Congress 3 and Treasury on the oversight
                        provided for the programs established under Subtitle B,
                        including any recommendations for improvement. In accordance
                        with this mandate, we conducted this audit.

                        The objective of this audit was to assess the CDFI Fund’s
                        award process for ensuring the accuracy of the CDFI ERP
                        payments and the design of the post-award administration over
                        recipient monitoring, in compliance with applicable laws,
                        regulations, and policies and procedures. The scope of our audit
                        included, but was not limited to, the: (1) assessment of the
                        CDFI Fund’s allocation methodologies; (2) determination of ERP-

1
    Public Law 116-260, Consolidated Appropriations Act, 2021 (December 27, 2020).
2
    A CDFI must have a primary mission of promoting community development. The CDFI Fund will
    consider whether the activities of the entity are purposefully directed toward improving the social
    and/or economic conditions of underserved people (which may include low-income persons or
    persons who lack adequate access to capital and/or financial services) and/or residents of
    economically distressed communities.
3
    The committees of Congress named under Subtitle B include the Committee on Financial Services
    of the House of Representatives and the Committee on Banking, Housing, and Urban Affairs of
    the Senate.

    Audit of the Community Development Financial Institutions Fund’s Award and
    Post-Award Administration of the CDFI Equitable Recovery Program (OIG-24-
    037)                                                                                             1
                        Eligible Geographies; (3) accuracy of award amounts and
                        payments; and (4) adequacy of the CDFI ERP post-award
                        reporting process. Our audit scope included the CDFI Fund’s
                        activities related to CDFI ERP applications, awards, and
                        payments from June 24, 2022, through November 30, 2023.

                        To accomplish our audit objective, we:

                            •   reviewed applicable laws and regulations, including the
                                CDFI ERP Notice of Funds Availability (NOFA); 4

                            •   reviewed CDFI ERP policies and procedures, major
                                decisions, award terms and conditions, and other
                                supporting documentation related to the CDFI Fund’s
                                administration of the program;

                            •   assessed the accuracy of award payments by selecting a
                                statistical sample of 27 CDFI ERP payments, totaling
                                $58 million, from the population of 596 payments 5 issued
                                as of November 30, 2023, totaling approximately $1.4
                                billion;

                            •   assessed whether the CDFI Fund correctly determined
                                applicant ineligibility for all 92 CDFI ERP applicants who
                                did not receive an award;

                            •   performed walkthroughs of the CDFI Fund’s Awards
                                Management Information System (AMIS); 6

                            •   interviewed CDFI Fund officials and personnel responsible
                                for implementing, performing, and monitoring the CDFI
                                ERP; and




4
    The NOFA is a federal agency’s formal announcement of the availability of federal funding for a
    financial assistance program.
5
    On April 10, 2023, Treasury announced that the CDFI Fund awarded CDFI ERP grants to
    604 CDFIs. As of November 30, 2023, there were 596 initial award payments issued. The
    remaining award payments had yet to be issued and were not part of our testing.
6
    AMIS is an enterprise-wide business system that supports all CDFI Fund programs through each
    phase of the programs’ life cycles, including processes related to certification, program awards
    and allocations, pre-award requirements, compliance reporting, and data analysis. Additionally,
    applicants use AMIS to create, complete, and submit applications.



      Audit of the Community Development Financial Institutions Fund’s Award and Post-
      Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         2
                            •   assessed the design and implementation of processes and
                                internal controls over CDFI ERP post-award activities.

                        We conducted our fieldwork remotely from March 2024 to
                        July 2024. Appendix 1 contains a detailed description of our
                        audit objective, scope, and methodology.


Results in Brief

                        In brief, CDFI Fund management documented the CDFI ERP
                        award determination process across multiple standard operating
                        procedures (SOPs), consistent with the Government
                        Accountability Office’s (GAO) Standards for Internal Control in
                        the Federal Government (Green Book). 7 CDFI Fund management
                        also accurately calculated CDFI ERP awards and administered
                        them in accordance with the CAA, 2021 and the Office of
                        Management and Budget’s (OMB) Uniform Administrative
                        Requirements, Cost Principles, and Audit Requirements for
                        Federal Awards, 2 Code of Federal Regulations (CFR) Part 200
                        (Uniform Guidance). 8 Based on the 27 sampled CDFI ERP
                        recipients, we found that the CDFI Fund accurately issued CDFI
                        ERP payments in compliance with federal guidance and
                        regulations.

                        Additionally, the CDFI Fund designed and implemented the CDFI
                        ERP post-award administration process, to include recipient
                        monitoring, in compliance with the CAA, 2021, Uniform
                        Guidance, and GAO Green Book. CDFI Fund management
                        developed post-award and monitoring SOPs as well as the CDFI
                        ERP Assistance Agreement (Assistance Agreement), which
                        incorporated Uniform Guidance requirements to recipients.
                        Furthermore, CDFI Fund management established:
                        (1) procedures for evaluating CDFI ERP annual compliance
                        reports; (2) a noncompliance process; and (3) a process for
                        closing CDFI ERP awards. Accordingly, we did not make any
                        recommendations in this report.

7
    The Green Book sets the standards for an effective internal control system for federal agencies
    and provides the overall framework for designing, implementing, and operating an effective
    internal control system.
8
    The Uniform Guidance is an authoritative set of rules and requirements for federal awards.



      Audit of the Community Development Financial Institutions Fund’s Award and Post-
      Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         3
                     As part of our reporting process, we provided the CDFI Fund
                     management an opportunity to comment on a draft of this
                     report. In a written response, the CDFI Fund management
                     acknowledged there was no recommendation and stated that
                     they appreciated the work of Treasury OIG staff, and the
                     opportunity to review and provide a response to the report. The
                     CDFI Fund’s management response, in its entirety, is included in
                     appendix 2 of this report.


Background

                     The CDFI Fund
                     The CDFI Fund was established by the Riegle Community
                     Development Regulatory Improvement Act of 1994, 9 as a
                     bipartisan initiative created for the purpose of promoting
                     economic revitalization and community development through
                     investment in and assistance to CDFIs. Since its creation, the
                     CDFI Fund has awarded more than $7.4 billion to CDFIs,
                     community development organizations, and financial institutions
                     through the: Bank Enterprise Award Program; Capital Magnet
                     Fund; CDFI Rapid Response Program; CDFI Program, including
                     the Healthy Food Financing Initiative; Native American CDFI
                     Assistance Program; and Small Dollar Loan Program.

                     The CDFI Fund is led by the Director 10 who is supported by the
                     Chief of Staff, the Chief Financial Officer, the Office of Legal
                     Counsel, and the Office of Legislative and External Affairs.
                     There are two Deputy Directors who oversee programs and
                     operations: (1) the Deputy Director of Policy and Programs who
                     oversees the efforts of all the CDFI Fund’s award programs in
                     support of the CDFI Fund’s strategic visions; and (2) the Deputy
                     Director of Finance and Operations 11 who is responsible for



9
   Public Law 103-325, The Riegle Community Development and Regulatory Improvement Act of
   1994 (September 23, 1994).
10
   On March 11, 2024, the CDFI Fund announced Pravina Raghavan as the new Director of the
   CDFI Fund.
11
   As of July 2024, the Operations Manager of the CDFI Fund currently serves as the Acting
   Deputy Director of Finance and Operations.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         4
                       developing policies, operating procedures, internal controls, and
                       short- and long-term strategic plans for the CDFI Fund.

                       CDFI ERP
                       Title V, Subtitle B, Community Development Investment, within
                       Division N of the CAA, 2021, appropriated $3 billion to the
                       CDFI Fund, of which, up to $1.75 billion shall be made available
                       until expended to provide grants to CDFIs to respond to the
                       economic impact of the COVID-19 pandemic. 12 To award these
                       funds, the CDFI Fund established the CDFI ERP.

                       The CDFI ERP awards are provided to CDFIs to expand lending,
                       grant making, and investment activity in low- or moderate-
                       income communities and to borrowers, including minorities, that
                       have significant unmet capital or financial service needs and
                       were disproportionately impacted by the COVID-19 pandemic.
                       CDFI ERP awards also enable CDFIs to build organizational
                       capacity and acquire technology, staff, and other tools
                       necessary to accomplish the activities.

                       CDFI ERP Eligibility Requirements
                       To be eligible to apply for a CDFI ERP grant, organizations must
                       have complied with all outstanding CDFI awards, allocations, or
                       bond guarantee requirements, as well as meeting benchmarks
                       for programmatic/financial safety and soundness. Furthermore,
                       to be eligible for the CDFI ERP, the CDFI must have been
                       certified as of the date the NOFA was published in the Federal
                       Register. 13




12
   Of the $3 billion, $1.75 billion was allocated for the CDFI ERP. The remaining $1.25 billion was
   allocated for the CDFI Rapid Response Program, which was not within the scope of this audit.
13
   The NOFA was published in the Federal Register on June 24, 2022.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         5
                       CDFI Certification
                       CDFI certification is the CDFI Fund’s recognition of specialized
                       financial institutions serving low-income communities. Through
                       certification, CDFIs are qualified to apply for CDFI Financial
                       Assistance Program awards, as well as training provided by the
                       CDFI Fund through the Capacity Building Initiative. 14

                       To become a certified CDFI, an organization must:

                           (1) be a legal entity;

                           (2) have a primary mission of promoting community
                               development;

                           (3) be a financing entity;

                           (4) provide development services along with financing
                               activities;

                           (5) serve one or more target market(s); 15

                           (6) maintain accountability to its defined target market(s);
                               and

                           (7) be a non-government entity and not under the control of
                               any government entity.

                       To qualify as a CDFI that served Native Communities,
                       50 percent or more of the applicant’s past activities must have
                       been directed to Native Communities and the applicant’s
                       certification target market must have met selected
                       characteristics.



14
   The CDFI Fund created the Capacity Building Initiative to help CDFIs improve their ability to
   deliver financial products and services to economically underserved communities. CDFIs can
   access free training workshops, webinars, market research, customized technical assistance, and
   informational resources to help them develop, diversify, and grow.
15
   A target market refers to one or more investment area(s) and/or targeted population(s). Targeted
   population(s) may include low-income targeted population(s) or other targeted population(s) in the
   organization’s service area for which there exists a strong basis in evidence that the group lacks
   access to loans, equity investments, and/or financial services. A target market is established
   when a certified CDFI selects an investment area as its target market.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         6
                         Once a CDFI has been certified, it must submit an Annual
                         Certification and Data Collection Report (ACR) to allow the CDFI
                         Fund to assess whether the organization remains in compliance
                         with their certification requirements and to monitor any changes
                         in the organization’s financial and/or other data. 16

                         CDFI ERP Eligible Activities
                         The CDFI Fund will provide CDFI ERP awards in the form of
                         grants to support eligible activities which may be expended as:
                         (1) financial products and services; and (2) operational support.

                         Financial products and services may serve commercial real
                         estate, small businesses, microenterprise, community facilities,
                         and affordable housing, and also includes consumer financial
                         products, consumer financial services, commercial financial
                         products, commercial financial services, intermediary lending to
                         non-profits and CDFIs, and other lines of business as deemed
                         appropriate by the CDFI Fund in the following six eligible
                         financial products and services categories: (i) financial products
                         (e.g. loans and equity investments); (ii) financial services (e.g.
                         providing checking and savings accounts); (iii) development
                         services (e.g. activities that promote community development);
                         (iv) grants (e.g. funds transferred without a repayment
                         requirement to a person, business, or other organization);
                         (v) loan loss reserves (e.g. award funds set aside in the form of
                         cash reserves to cover losses on loans); and (vi) capital reserves
                         (e.g. award funds set aside as reserves to support a CDFI’s
                         ability to leverage other capital for a specific purpose, such as
                         providing financing).

                         A portion of a CDFI ERP award may also be used for the
                         following seven eligible operational support categories:
                         (i) compensation – personal services; (ii) compensation – fringe
                         benefits; (iii) professional service costs; (iv) travel costs;
                         (v) training and education costs; (vi) equipment; and
                         (vii) supplies.


16
     On December 7, 2023, the CDFI Fund announced the release of a revised CDFI certification
     application and related tools. As a result, all certified CDFIs are required to reapply for
     certification using the revised version of the certification application by December 20, 2024.




       Audit of the Community Development Financial Institutions Fund’s Award and Post-
       Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         7
                      For any award size, no more than 25 percent of the award
                      amount may be used for financial services and development
                      services combined. Also, recipients may use up to the greater of
                      $166,667 or 15 percent of their award amount, up to a
                      maximum of $400,000, for eligible operational support activities
                      combined. Recipients are required to expend all funds by the
                      end of the period of performance 17 on eligible activities.

                      ERP-Eligible Geographies
                      To achieve the statutory objective of directing CDFI ERP
                      activities to low- or moderate-income communities and to
                      borrowers, including minorities, that have significant unmet
                      capital or financial services needs, and were disproportionately
                      impacted by the COVID-19 pandemic, the CDFI Fund has
                      identified ERP-Eligible Geographies. These are defined as
                      geographies that meet one of the following two criteria: (a) are
                      census tracts 18 that (i) demonstrate ‘‘severe impact’’ of the
                      COVID-19 pandemic; and (ii) have a median income at or below
                      120 percent of the area median income, and (iii) are CDFI
                      Investment Areas; or (b) are Native Areas.

                      The list of ERP-Eligible Geographies is available on the CDFI
                      Fund’s website. Data on ERP-Eligible Geographies is available
                      through the CDFI Fund’s Community Impact Mapping System. 19
                      All CDFI ERP eligible activities must serve ERP-Eligible
                      Geographies, except 10 percent of an award amount, which
                      may be deployed outside of ERP-Eligible Geographies to serve
                      low- or moderate- income persons and businesses (including
                      non-profit organizations) disproportionately impacted by the
                      COVID-19 pandemic.


17
   The period of performance for each CDFI ERP award begins with the date that the CDFI Fund
   announces the recipients of the CDFI ERP awards and includes a recipient’s five full consecutive
   fiscal years after the date of the CDFI ERP award announcement.
18
   A census tract is considered to have experienced ‘‘severe impact’’ of the COVID–19 pandemic if
   it meets one or more of the following criteria: (a) demonstrates severe mortality; or
   (b) demonstrates severe change in unemployment; or (c) demonstrates low community resilience.
19
   The CDFI Fund‘s Community Impact Mapping System is a mapping tool created to provide
   prospective applicants with the ability to search by address, census tract, and other geographic
   areas of interest to determine program eligibility for the Bank Enterprise Awards, CDFI Program,
   Capital Magnet Fund, CDFI ERP, Native American CDFI Assistance Program, and New Market
   Tax Credit Program.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         8
                       CDFI ERP Reporting Requirements
                       Per the Assistance Agreement, throughout the period of
                       performance, the recipient must provide to the CDFI Fund
                       annual reports, which are comprised of two parts: (1) financial
                       condition reports; and (2) performance reports. The CDFI Fund
                       reviews these reports to monitor each recipient’s compliance
                       with the performance goals and measures (PG&Ms) set forth in
                       the Assistance Agreement and assess the impact of the
                       program.

                       The financial condition reports include:

                           1. A-133/Single Audit Report 20 (if applicable);

                           2. Financial Statement Audit (FSA) Report; 21 and

                           3. Transaction Level Report (TLR). 22

                       The performance reports include:

                           1. Performance Progress Report; 23



20
   According to the Uniform Guidance, dated November 13, 2023, a non-Federal entity must
   complete an annual A-133/Single Audit Report pursuant to 2 CFR Part 200.500 if it expends
   $750,000 or more in federal awards in its FY, or such other dollar threshold established by OMB
   pursuant to 2 CFR Part 200.501. If an A-133/Single Audit is required, the recipient must submit
   the audit report to the Federal Audit Clearinghouse 270 days after the organization’s FY end
   date. Per the OMB Final Rule dated April 22, 2024, Guidance for Federal Financial Assistance, as
   of October 1, 2024, a non-Federal entity will be required to complete an annual A-133/Single
   Audit Report if it expends $1 million or more in federal awards in its FY.
21
   Non-profit recipients (including insured credit unions and state-insured credit unions), for-profit
   recipients, depository institution holding companies, and insured depository institutions must
   submit an FSA report in AMIS, along with the recipient’s statement of financial condition audited
   or reviewed by an independent certified public accountant. The FSA Report is due 180 days after
   the organization’s FY end date.
22
   The TLR is comprised of different sections depending on the type and purpose of transactions
   being reported on as well as financial entity type and CDFI Fund award type. A recipient is
   expected to report on all their transactions in the TLR including grant activity regardless of
   whether the transaction is directly tied to their CDFI Fund award. Recipients submit one TLR to
   the CDFI Fund regardless of the number of awards they have. The TLR is due 180 days after the
   organization’s FY end date.
23
   The Performance Progress Report details the recipient’s progress towards meeting the specific
   required PG&M benchmarks in their Assistance Agreement. The Performance Progress Report is
   due 90 days after the organization’s FY end date.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)         9
                           2. Uses of Award Report; 24 and

                           3. ACR. 25

                       On August 21, 2023, the CDFI Fund announced the addition of
                       the Standard Form (SF) 425 Federal Financial Report as a
                       reporting requirement for CDFI ERP recipients starting in fiscal
                       year (FY) 2024. Specifically, the recipient must submit the
                       SF-425 Federal Financial Report in AMIS to disclose how much
                       of their CDFI ERP award funds were expended during the
                       Federal Government's FY of October 1 through September 30.
                       This report is due annually, beginning on October 15, 2024, and
                       continuing through October 2028. 26




24
   The Uses of Award Report is used to determine recipient compliance with their PG&Ms and to
   demonstrate how CDFI ERP award funds are expended. The Uses of Award Report is due 90
   days after the organization’s FY end date.
25
   The ACR, which must be completed in the CDFI Fund’s AMIS, allows the CDFI Fund to annually
   assess a CDFI’s compliance with certification guidelines and collect data that provides insights
   into the CDFI industry. The ACR must be submitted by the due date indicated in AMIS.
26
   In the first SF-425 Federal Financial Report, the CDFI ERP recipient must disclose how much of
   the CDFI ERP award funds were expended from April 10, 2023, through September 30, 2024.
   The four following reports cover the funds expended from October 1 through September 30 of
   their respective years.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        10
                         CDFI ERP Award Allocations
                         On April 10, 2023, the CDFI Fund awarded over $1.73 billion in
                         CDFI ERP grants to 604 CDFIs across the country. 27 CDFI ERP
                         award amounts ranged from $500,000 to $6,197,097. See
                         information in figure 1 related to the award recipients’
                         commitments and allocation totals.

                         Figure 1. CDFI ERP Cumulative Award Allocations and Award
                         Recipients




                         Source: Generated by Treasury OIG based on the CDFI Fund’s CDFI
                         ERP Award Announcement on April 10, 2023.

                         The 604 CDFI ERP award recipients are headquartered in 44
                         states, the District of Columbia, Guam, and Puerto Rico.
                         Certified CDFIs can be one of a variety of financial institution
                         types, including banks, credit unions, loan funds, or venture
                         capital providers. Details described in figure 2.




27
     The CDFI Fund awarded $1.73 billion across all eligible applicants in a single program round. The
     CDFI Fund determined that the remainder of the $1.75 billion would cover administrative
     expenses related to the program.



       Audit of the Community Development Financial Institutions Fund’s Award and Post-
       Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        11
                  Figure 2. CDFI ERP Cumulative Award Allocations by Type of
                  Institution




                  Source: Generated by Treasury OIG based on the CDFI Fund’s CDFI ERP
                  Award Announcement on April 10, 2023.



Audit Results

                  The CDFI Fund Administered CDFI ERP Award
                  Payments and Designed and Implemented Post-Award
                  Procedures in Compliance With Federal Requirements
                  The CDFI Fund documented the CDFI ERP application review
                  and award payment processes across multiple SOPs in
                  compliance with requirements in the GAO Green Book. We
                  tested 27 CDFI ERP award payments out of a population of 596
                  initial payments as of November 30, 2023. Based on our testing
                  results, we determined that the CDFI Fund followed the award
                  application review process and documented the four-step
                  evaluation of each application for the sample we evaluated.
                  Furthermore, the CDFI Fund adhered to the applicable Uniform
                  Guidance and policies and procedures when processing
                  payments. The CDFI Fund accurately made initial CDFI ERP
                  award payments for the program, and we noted no issues or
                  exceptions with the payments we tested.

                  The CDFI Fund also designed and implemented the CDFI ERP
                  post-award administration and monitoring policies, procedures,
                  and processes in compliance with the Uniform Guidance and the



   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        12
               GAO Green Book. Accordingly, we did not make any
               recommendations.

               Summary described in figure 3.

               Figure 3. CDFI ERP Award and Post-Award Audit Results




               Source: Generated by Treasury OIG.

               The CDFI Fund Documented Policies and Procedures
               for Determining and Processing CDFI ERP Awards in
               Accordance With the GAO Green Book
                           Consistent with GAO Green Book Principle 10, which
                           states that “management should design control
                           activities to achieve objectives and respond to risks,”
                           and GAO Green Book Principle 12, which states that
               “management should implement control activities through
               policies,” the CDFI Fund created an application review process
               and documented it across multiple SOPs. For example, the CDFI
               Fund implemented the NOFA’s four-step evaluation process for
               each CDFI ERP application in the “CDFI ERP SOPs FY
               2022 Steps A Thru E” and created separate, detailed job aids




Audit of the Community Development Financial Institutions Fund’s Award and Post-
Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        13
               for each step of the application review process. Summary
               described in figure 4.

               Figure 4. CDFI ERP Award Determination’s Four-Step Evaluation
               Process




               Source: Generated by Treasury OIG based on the FY 2022 CDFI ERP
               Application Evaluation Process.

               As part of the first step of the application review process, the
               CDFI Fund evaluated each application to determine whether the
               applicant was eligible to qualify for an award. Consistent with
               GAO Green Book Principle 11, which states that “management
               should design the entity’s information system and related
               control activities to achieve objectives and respond to risks,”
               the CDFI Fund built validations into AMIS to automate the initial
               eligibility review checks. These review checks included checking
               whether the applicant attached the required documentation to
               their application; verifying whether the applicant attested and
               provided data to substantiate that 30 percent of the average
               annual financial products closed and grants made over the
               applicant’s five most recent historic FYs were in ERP-Eligible
               Geographies; and confirming that the applicant had attested
               that no affiliates were separately applying for a CDFI ERP
               award.




Audit of the Community Development Financial Institutions Fund’s Award and Post-
Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        14
                       Additionally, for each application, the CDFI Fund verified CDFI
                       certification as of the date of the NOFA publication; ensured the
                       applicant submitted the correct Unique Entity Identifier 28 and
                       Employer Identification Number in their SF-424 29 and AMIS
                       account; and conducted Do Not Pay 30 checks. Furthermore, the
                       CDFI Fund sampled 350 CDFI ERP applicants to ensure that the
                       attestations regarding their track records in ERP-Eligible
                       Geographies were calculated accurately and found no issues.
                       Additionally, the CDFI Fund conducted quality assurance
                       reviews to ensure accuracy of all eligibility findings and
                       documented the reason(s) for any ineligibility determinations.

                       Applicants deemed eligible to qualify for a CDFI ERP award
                       based on the initial eligibility checks proceeded to the second
                       step of the application review process. The second step
                       involved the CDFI Fund conducting a basic financial soundness
                       and compliance risk analysis of each applicant. For applicants
                       deemed to have a high financial risk or a high compliance risk,
                       the CDFI Fund conducted quality assurance desk reviews.
                       Applicants that met the applicable scores on the financial and
                       compliance metrics established in the NOFA proceeded to the
                       third step of the application review process.

                       For the third step of the application review process, the CDFI
                       Fund conducted application evaluations and initial funding
                       recommendations. The CDFI Fund utilized External Reviewers 31
                       to evaluate and score applications based on the applicant’s
                       business strategy; community impact track record; policy
                       priorities, projected performance and outcomes; and
                       organizational capacity as part of the application review
                       process. Each application received a score up to 100 points

28
   The Unique Entity Identifier is a unique number assigned to all entities who register to do
   business with the federal government to streamline the entity identification and validation
   process.
29
   The OMB SF-424 is an application for federal assistance and must be submitted via Grants.gov.
30
   The Do Not Pay Portal, run by Treasury’s Bureau of the Fiscal Service, allows federal agencies to
   check multiple data sources to verify initial and ongoing eligibility of a vendor, grantee, loan
   recipient, or other beneficiary to receive federal payments. Recipients may be ineligible because
   of previous default on federal debt, fraud, or other disqualifying factors.
31
   The External Reviewers were contracted, non-federal personnel selected based on criteria that
   included a professional background in affordable housing finance or in community and economic
   development finance. The External Reviewers were required to complete the CDFI Fund’s conflict
   of interest process and be approved by the CDFI Fund.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        15
                       based on the evaluation. At the end of the evaluation, the
                       External Reviewer was required to provide an award
                       recommendation. As part of the award evaluation, the CDFI
                       Fund also used Federal Reviewers 32 who: (1) conducted quality
                       control reviews for the External Reviewer’s evaluation and
                       scoring of each application; (2) provided recommendations as to
                       whether the application should be forwarded to next step for an
                       award determination; and (3) recommended an initial award
                       amount. The Federal Reviewer determined the initial award
                       amount based on the numeric score calculated by the External
                       Reviewer. However, if an applicant had an overall due diligence
                       score 33 of “somewhat concerned,” the Federal Reviewer
                       reduced the award amount by 30 percent. Applicants that
                       received a funding recommendation from both the External
                       Reviewer and the Federal Reviewer advanced to the fourth step
                       for award determination.

                       For the fourth step in the application review process, the CDFI
                       Fund made award amount determinations for CDFI ERP
                       recipients. The award determination step was consistent with
                       GAO Green Book Principle 13, which states that “management
                       should use quality information to achieve the entity’s
                       objectives.” The Reviewing Official 34 ensured that applications
                       that received a recommendation for award met all five of the
                       minimal criteria. This criteria included: (1) the applicant’s
                       business strategy was minimally understandable and consistent
                       throughout the application; (2) the applicant’s business strategy


32
   Federal Reviewers are internal reviewers, made up of CDFI Fund staff and other federal agency
   staff, as needed, who serve as team leaders for External Reviewers.
33
   The purpose of the due diligence review is to assess any potential compliance concerns for each
   CDFI ERP applicant. All CDFI ERP applicants that advanced to the third step of the evaluation
   process received a due diligence review by a Federal Reviewer. The level of concern will be either
   “not concerned,” “somewhat concerned,” or “very concerned.” Applicants that receive a level of
   concern score of “not concerned” will not see a reduction in their initial award amount
   recommendation. Applicants that receive a level of concern score of “somewhat concerned” may
   be recommended for an award, but their recommended initial award size will be reduced by 30
   percent. Applicants that receive a level of concern score of “very concerned” will not be
   recommended for an award.
34
   The Reviewing Official is responsible for: (1) reviewing applications in cases where either the
   External Reviewer or the Federal Reviewer does not recommend that the application be funded;
   (2) providing a recommendation to fund or not to fund an application; and (3) providing an initial
   award amount recommendation if the Federal Reviewer does not recommend funding the
   application and the Reviewing Official overturns this decision.



     Audit of the Community Development Financial Institutions Fund’s Award and Post-
     Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        16
                         was related to addressing the economic impact(s) of the
                         COVID-19 pandemic on the communities, businesses and
                         people the applicant proposed to serve; (3) the applicant
                         proposed to use the award for eligible activities; (4) the
                         applicant had the organizational capacity or a plan to grow
                         organizational capacity to deploy at least a minimum award
                         amount of $500,000 during the five year period of
                         performance; and (5) the applicant had an overall due diligence
                         score of “not concerned” or “somewhat concerned.” If the
                         applicant met the minimum criteria, they were recommended for
                         a CDFI ERP award. Lastly, the Selecting Official 35 ensured that
                         evaluations were conducted in accordance with the review
                         guidance and made the preliminary award determination.

                         After all preliminary award determinations were made, the CDFI
                         Fund imported the award data into the CDFI ERP Award Model
                         and proportionally reduced the award amounts based on the
                         award recommendation and the funding availability. To meet
                         GAO Green Book Principle 10, which states that “management
                         should design control activities to achieve objectives and
                         respond to risks,” the CDFI Fund developed multiple validation
                         checks to ensure award amounts were allocated properly. For
                         example, the CDFI Fund designed the CDFI ERP Award Model to
                         not allow any award amount to be: (1) less than the minimum
                         award amount; and (2) less than the minimum award amount
                         that the applicant requested.

                         Once award determinations were made, the initial award
                         payment process began. The first step of the process required
                         the recipient’s signature of the Assistance Agreement in AMIS.
                         The CDFI Fund followed a process that included a series of
                         reviews by the Program Staff, the Office of Compliance
                         Monitoring and Evaluation (OCME) Portfolio Manager, the CDFI
                         ERP Closing Manager, and the Financial Manager before sending
                         the payment batches to the Bureau of the Fiscal Service for
                         processing. As part of the payment review process, CDFI Fund
                         staff conducted a series of quality assurance reviews to ensure
                         that payments were processed accurately. If there were



35
     The Selecting Official is responsible for conducting reviews based on the guidance to determine
     preliminary award amounts in accordance with the CDFI ERP Internal Review Guidance.



       Audit of the Community Development Financial Institutions Fund’s Award and Post-
       Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        17
                        discrepancies, the CDFI Fund staff worked with the recipient to
                        remediate any payment issues.

                        Lastly, the audit team tested the design, implementation, and
                        operational effectiveness of the internal controls deemed
                        significant to the audit objective for the CDFI ERP award
                        administration and noted no deficiencies. The CDFI Fund
                        complied with the requirements in the GAO Green Book and
                        OMB A-123 36 when administering the CDFI ERP.

                        The CDFI Fund Evaluated CDFI ERP Applicants and
                        Processed Award Payments Accurately
                                    We tested 27 award payments out of a population
                                    of 596 initial CDFI ERP award payments as of
                                    November 30, 2023. We determined that the CDFI
                                    Fund ensured that: (1) the award determinations and
                        evaluations were made in accordance with the CDFI Fund’s
                        policies and procedures; and (2) the CDFI ERP initial award
                        payments were made accurately and in compliance with internal
                        and external requirements. As part of our testing of the
                        27 sampled payments, we reviewed each CDFI ERP recipient’s
                        application and compared the review actions by the CDFI Fund
                        with the four-step application review process documented in the
                        policies and procedures. We noted no issues or exceptions with
                        the accuracy or completeness of records for the initial award
                        payments of the sample we tested.

                        Additionally, we reviewed the entire universe of 92 CDFI ERP
                        applicants who did not receive a CDFI ERP award, to assess
                        whether the CDFI Fund correctly determined the applicants’
                        ineligibility in accordance with the applicable requirements in the
                        CDFI ERP NOFA. We reviewed the CDFI Fund’s written
                        explanations, as well as the applicants’ CDFI ERP applications
                        and Internal Review Records from AMIS, to determine whether

36
     On July 15, 2016, OMB published an update to Circular No. A-123, Management’s Responsibility
     for Enterprise Risk Management and Internal Control. The Circular defined management’s
     responsibilities for enterprise risk management and internal control. Additionally, the Circular
     provided updated implementation guidance to federal managers to improve accountability and
     effectiveness of federal programs as well as mission support operations through implementation
     of enterprise risk management practices and by establishing, maintaining, and assessing internal
     control effectiveness.



       Audit of the Community Development Financial Institutions Fund’s Award and Post-
       Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        18
               the applicants were properly excluded from receiving CDFI ERP
               awards. We noted that all 92 applicants that did not receive an
               award were properly excluded, and that the CDFI Fund
               documented these reviews and justifications in accordance with
               the NOFA and internal policies and procedures.

               The CDFI Fund Administered CDFI ERP Awards in
               Accordance With Federal Guidance
               The CDFI Fund administered CDFI ERP awards in compliance
               with applicable federal requirements, specifically 2 CFR
               Part 200, Subpart C, Pre-Federal Award Requirements and
               Contents of Federal Awards, and 12 CFR Part 1805, Subpart G,
               Evaluation and Selection of Applications.

               The CDFI Fund established recipients’ PG&Ms in each
               Assistance Agreement to achieve the statutory goals of the
               program and in compliance with 2 CFR Part 200.211(a), which
               states the following: “performance goals, indicators, targets,
               and baseline data must be included in the federal award, where
               applicable. The federal awarding agency must also specify how
               performance will be assessed in the terms and conditions of the
               federal award, including the timing and scope of expected
               performance.” The PG&Ms ensure that recipients: (1) expend
               awards by a certain timeframe; (2) expend awards by a certain
               period to achieve applicable policy priorities; (3) expend funds in
               authorized eligible activities; and (4) expend a specific
               percentage of the award in program activities in ERP-Eligible
               Geographies. Recipients must also meet reporting requirements,
               maintain CDFI certification, and have no pending resolutions of
               noncompliance that would preclude them from receiving an
               award, prior to executing their Assistance Agreement. To
               ensure that recipients are meeting and will continue to meet
               these requirements, the CDFI Fund incorporated post-award
               monitoring steps within the OCME SOPs and conducted
               compliance checks prior to award funds being disbursed.

               Furthermore, per 12 CFR Part 1805.803(a), “a recipient shall
               maintain such records as may be prescribed by the CDFI Fund
               that are necessary to: (1) disclose the manner in which CDFI
               Fund assistance is used; (2) demonstrate compliance with the
               requirements of this part and an Assistance Agreement; and


Audit of the Community Development Financial Institutions Fund’s Award and Post-
Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        19
               (3) evaluate the impact of the CDFI Fund program.” The CDFI
               Fund incorporated these requirements into the award terms and
               conditions in the Assistance Agreement.

               In accordance with 12 CFR Part 1805.802, which states that
               “assistance provided pursuant to this part may be provided in a
               lump sum or over a period of time, as determined appropriate by
               the CDFI Fund,” payment of an initial award amount was made
               at the initial closing when the Assistance Agreement and related
               documents were properly executed and delivered. The first
               payment was the estimated amount that the recipient stated
               they would use for eligible CDFI ERP activities in the
               first 12 months after the award. Following the initial closing,
               there may be subsequent closings involving additional award
               payments, up to a maximum of four subsequent award
               payments. Recipients may request subsequent payments once
               they expend at least 90 percent of the previous payment in a
               CDFI ERP eligible activity.

               The CDFI Fund Designed and Implemented the CDFI
               ERP Post-Award Administration and Monitoring
               Policies, Procedures, and Processes in Accordance
               With Federal Guidance, the CDFI ERP NOFA, and the
               GAO Green Book
                          Federal Guidance

                           The CDFI Fund designed and implemented CDFI ERP
                           post-award administration and monitoring policies
                           and procedures in compliance with applicable
               requirements outlined in 2 CFR Part 200, Subpart D, Post
               Federal Award Requirements, sections 200.300 through
               200.346, and 12 CFR Part 1805, Subpart H, Terms and
               Conditions of Assistance, sections 1805.800 through
               1805.811. Specifically, the CDFI Fund designed the CDFI ERP
               NOFA, Assistance Agreement, and the OCME SOPs to include
               the Uniform Guidance post-award monitoring requirements.
               Furthermore, the CDFI Fund required CDFI ERP recipients to
               attest to adhering to the terms and conditions in their
               Assistance Agreement prior to disbursing award funds. The
               CDFI Fund also established protocols for data collection,



Audit of the Community Development Financial Institutions Fund’s Award and Post-
Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        20
               reporting, and compliance with government requirements,
               consistent with 12 CFR Part 1805.

               CDFI ERP NOFA

               The CDFI Fund designed and implemented the CDFI ERP post-
               award administration and monitoring policies and procedures, as
               set forth in the Assistance Agreement and the OCME SOPs, in
               compliance with the CDFI ERP NOFA. According to the NOFA,
               CDFI ERP recipients must submit compliance reports annually
               during the period of performance based on the reporting
               schedules in their Assistance Agreements. The CDFI Fund uses
               these reports to monitor recipients’ compliance with their
               PG&Ms and the requirements in the Assistance Agreement and
               the NOFA, and to assess the program’s impact. Additionally,
               the Assistance Agreement includes the requirement that
               recipients must collect and report data on the race and ethnicity
               of borrowers and/or beneficiaries of the program, which the
               NOFA noted as an intention of the program.

               GAO Green Book

               The CDFI Fund designed report review processes for each of the
               required CDFI ERP compliance reports and a noncompliance
               process in AMIS consistent with GAO Green Book Principle 10,
               which states that “management should design control activities
               to achieve objectives and respond to risks,” and GAO Green
               Book Principle 11, which states that “management should
               design the entity’s information system and related control
               activities to achieve objectives and respond to risks.” For each
               type of report, the review process starts with AMIS completing
               an automated compliance review to ensure validity,
               completeness, and accuracy. If a recipient’s report does not
               pass the automated compliance review, the assigned OCME
               Portfolio Manager manually reviews the report to determine
               whether the recipient is compliant. If a recipient is found to be
               noncompliant, they are provided the opportunity to remedy the
               issue before sanctions are imposed by the CDFI Fund.

               Also consistent with GAO Green Book Principle 10, the CDFI
               Fund designed processes for performing site visits and desk
               reviews. Site visits and desk reviews are conducted for



Audit of the Community Development Financial Institutions Fund’s Award and Post-
Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        21
                       recipients who received a high noncompliance severity level
                       based on OCME’s risk-rating tool and were deemed
                       noncompliant in previous periods of performance, or for those
                       recipients with other indicators that show they would benefit
                       from technical assistance. The CDFI Fund designed the site
                       visits and desk reviews to detect mismanagement and abuse,
                       assess performance, check compliance, and test the integrity of
                       the data the recipients submit to document their PG&Ms.

                       Additionally, the CDFI Fund established CDFI ERP post-award
                       administration and monitoring policies and procedures
                       consistent with GAO Green Book Principle 12, which states that
                       “management should implement control activities through
                       policies.” Specifically, the CDFI Fund established the OCME
                       SOPs and the OCME Site Visit and Desk Review SOPs 37 which
                       outline the CDFI ERP compliance report review, noncompliance,
                       and site visits and desk reviews processes, including staff
                       responsibilities.

                       Furthermore, the CDFI Fund designed and implemented
                       monitoring policies and procedures consistent with GAO Green
                       Book Principle 16, which states that “management should
                       establish and operate monitoring activities to monitor the
                       internal control system and evaluate the results,” and GAO
                       Green Book Principle 17, which states that “management
                       should remediate identified internal control deficiencies on a
                       timely basis.” Specifically, the OCME Internal Controls
                       Framework Manual outlines the policies and procedures for
                       maintaining and monitoring relevant internal controls throughout
                       OCME’s processes, as internal controls are built into the OCME
                       SOPs and the OCME Site Visit and Desk Review SOPs, along
                       with possible corrective actions when internal control issues
                       arise. The CDFI Fund completes an annual Internal Control
                       Framework Assessment Workbook in which they evaluate the
                       17 principles and five components outlined in the GAO Green
                       Book to determine whether their system of internal control
                       reduces the risk of not achieving their objectives related to
                       operations, reporting, or compliance to an acceptable level.



37
     The OCME Site Visit and Desk Review SOPs document provided by the CDFI Fund was a draft
     version that was still being worked on as of June 12, 2024.



       Audit of the Community Development Financial Institutions Fund’s Award and Post-
       Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        22
                     While we were able to assess the design and implementation of
                     the CDFI Fund’s post-award administration and monitoring
                     policies, procedures, and processes, the audit team was unable
                     to evaluate the operational effectiveness of the post-award
                     monitoring process as only two of the required reports, the
                     Financial Statement Audit Report and the A-133/Single Audit
                     Report, were due from recipients prior to the end of fieldwork.


Next Steps

                     Post-Award Compliance Review for CDFI ERP
                     Recipients
                     As of the end of our fieldwork, CDFI Fund management was in
                     the process of completing user acceptance testing of the CDFI
                     ERP Uses of Award Reports and Performance Progress Reports
                     in AMIS with the first reports due July 31, 2024. CDFI Fund
                     management anticipates the CDFI ERP recipients’ SF-425
                     Federal Financial Reports and ACRs by the annual deadlines of
                     October 15, 2024, and December 20, 2024, respectively.


                                                ******

                     We appreciate the courtesies and cooperation provided to our
                     staff during the audit. If you wish to discuss the report, you
                     may contact me at (202) 270-2766 or James Fuller, Audit
                     Manager, at (202) 961-1080. Major contributors to this report
                     are listed in appendix 3. A distribution list for this report is
                     provided as appendix 4.

                     /s/

                     Daniel F. Gerges
                     Audit Director, State and Local Fiscal Recovery, RESTORE, and
                     CDFI Programs
Appendices




      Audit of the Community Development Financial Institutions Fund’s Award and Post-
      Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        23
Appendix 1: Objective, Scope, and Methodology

                  The objective of this audit was to assess the Community
                  Development Financial Institutions (CDFI) Fund’s award process
                  for ensuring the accuracy of the CDFI Equitable Recovery
                  Program (CDFI ERP) payments and the design of the post-award
                  administration over recipient monitoring in compliance with
                  applicable laws, regulations, and policies and procedures.

                  The scope of our audit included, but was not limited to, the:
                  (1) assessment of the CDFI Fund’s allocation methodologies;
                  (2) determination of ERP-Eligible Geographies; (3) accuracy of
                  award amounts and payments; and (4) adequacy of the CDFI
                  ERP post-award reporting process. Our audit scope included the
                  CDFI Fund’s activities related to CDFI ERP applications, awards,
                  and payments from June 24, 2022, through November 30,
                  2023.

                  To accomplish this audit objective, we performed the following
                  procedures during audit fieldwork, conducted remotely from
                  March 2024 to July 2024:

                  •   Reviewed applicable laws, regulations, and policies and
                      procedures, including:
                         o Public Law 116-260, Title V, Subtitle B in Division N
                           of the Consolidated Appropriations Act, 2021,
                           December 27, 2020;
                         o Public Law 103-325, Riegle Community Development
                           and Regulatory Improvement Act of 1994,
                           September 23, 1994;
                         o 12 Code of Federal Regulations Part 1805,
                           “Community Development Financial Institutions
                           Program,” August 31, 2015;
                         o Office of Management and Budget (OMB), Uniform
                           Administrative Requirements, Cost Principles, and
                           Audit Requirements for Federal Awards, 2 Code of
                           Federal Regulations 200, updated August 13, 2020
                           (effective November 12, 2020) and April 4, 2024
                           (effective October 1, 2024);




  Audit of the Community Development Financial Institutions Fund’s Award and
  Post-Award Administration of the CDFI Equitable Recovery Program (OIG-24-
  037)                                                                          24
Appendix 1: Objective, Scope, and Methodology

                         o Government Accountability Office (GAO), Standards
                           for Internal Control in the Federal Government,
                           September 2014;
                         o GAO, Assessing Data Reliability, December 2019; and
                         o OMB Circular A-123, Management’s Responsibility for
                           Enterprise Risk Management and Internal Control,
                           July 15, 2016.
                  •   Reviewed GAO’s Standards for Internal Control in the
                      Federal Government to identify the components and
                      principles of internal control that were significant in the
                      context of the audit objective. Specifically, we evaluated the
                      control environment, risk assessment, control activities,
                      information and communication, and monitoring internal
                      control components; and assessed policies, procedures, and
                      guidance against the following principles:
                         o Principle 3: Management should establish an
                           organizational structure, assign responsibility, and
                           delegate authority to achieve the objectives;
                         o Principle 8: Management should consider the potential
                           for fraud when identifying, analyzing, and responding
                           to risks;
                         o Principle 9: Management should identify, analyze, and
                           respond to significant changes that could impact the
                           internal control system;
                         o Principle 10: Management should design control
                           activities to achieve objectives and respond to risks;
                         o Principle 11: Management should design the entity’s
                           information system and related control activities to
                           achieve objectives and respond to risks;
                         o Principle 12: Management should implement control
                           activities through policies;
                         o Principle 13: Management should use quality
                           information to achieve the entity’s objectives;
                         o Principle 14: Management should internally
                           communicate the necessary quality information to
                           achieve the entity’s objectives;




   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        25
Appendix 1: Objective, Scope, and Methodology

                         o Principle 15: Management should externally
                           communicate the necessary quality information to
                           achieve the entity’s objectives;
                         o Principle 16: Management should establish and
                           operate monitoring activities to monitor the internal
                           control system and evaluate the results; and
                         o Principle 17: Management should remediate identified
                           internal control deficiencies on a timely basis.
                  •   Reviewed the CDFI Fund’s policies, procedures, and
                      guidelines related to the administration of the CDFI ERP,
                      including, but not limited to:
                         o CDFI Equitable Recovery Program Standard Operating
                           Procedures Fiscal Year (FY) 2022 Steps A Thru E,
                           November 1, 2022;
                         o FY 2022 CDFI Equitable Recovery Program Step 1:
                           Eligibility Review Job Aid, October 18, 2022;
                         o FY 2022 CDFI Equitable Recovery Program Step 2:
                           Financial Analysis and Compliance Risk Evaluation Job
                           Aid, October 7, 2022;
                         o FY 2022 CDFI Equitable Recovery Program External
                           Review Guide, (undated), provided on February 9,
                           2024;
                         o CDFI ERP Internal Review Guidance: Federal Reviewer,
                           Reviewing Official and Selecting Official,
                           October 25, 2022;
                         o FY 2022 CDFI Equitable Recovery Program: Debriefing
                           Report Creation Job Aid, May 17, 2023;
                         o CDFI ERP Regulator Data Job Aid, (undated), provided
                           on February 9, 2024;
                         o CDFI Equitable Recovery Program Job Aid – Award
                           Workflow: Program Manager Guidance, August 1,
                           2023;
                         o CDFI Equitable Recovery Program Job Aid –
                           Assistance Agreement Closing Process – First Level
                           Review, August 1, 2023;
                         o FY 2022 Community Development Financial
                           Institutions Equitable Recovery Program Assistance



   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        26
Appendix 1: Objective, Scope, and Methodology

                            Agreement Generation and Distribution Guidance,
                            (undated), provided on February 9, 2024;
                         o Community Development Financial Institutions Fund
                           Standard Operating Procedures Monetary
                           Programs - Award Accounting, (undated), provided on
                           March 1, 2024;
                         o CDFI Equitable Recovery Program Assistance
                           Agreement Modification Policy, September 6, 2023;
                         o CDFI Equitable Recovery Program Job Aid –
                           Subsequent Payment Requests, November 29, 2023;
                         o Grant Refund Process, (undated), provided on
                           February 2, 2024;
                         o CDFI ERP Notice of Funds Availability (NOFA),
                           June 24, 2022;
                         o CDFI ERP Key Staff List, as of January 25, 2024;
                         o CDFI Fund Organizational Chart, as of March 21,
                           2024; and
                         o Memorandum of Understanding Between the
                           Community Development Financial Institutions Fund
                           and the National Credit Union Administration,
                           January 21, 2016.
                  •   Reviewed the CDFI Fund’s policies, procedures, and
                      guidelines related to the post-award administration and
                      monitoring of the CDFI ERP, including, but not limited to:
                         o Compliance Monitoring and Evaluation Unit Standard
                           Operating Procedures, August 10, 2023;
                         o Compliance Monitoring and Evaluation Unit Internal
                           Controls Framework Manual, August 10, 2023;
                         o Awards Management Information System (AMIS)
                           Training Manual: Certification of Material Events Form
                           for all CDFI Fund Programs, September 2023;
                         o AMIS Training Manual: Standard Form 425 Federal
                           Financial Report Completion Guidance
                           September 2023; and
                         o Compliance Monitoring and Evaluation Unit Site Visit
                           and Desk Review Standard Operating Procedures,
                           Draft version, April 2024.


   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        27
Appendix 1: Objective, Scope, and Methodology

                  •   Reviewed the Department of the Treasury (Treasury) Office
                      of Inspector General (OIG) reports and GAO reports,
                      including, but not limited to:
                         o Treasury OIG, Audit of the Community Development
                           Financial Institutions Fund’s Implementation of the
                           CDFI Equitable Recovery Program, OIG-23-033
                           (September 13, 2023);
                         o Treasury OIG, Audit of the Community Development
                           Financial Institutions Fund’s Award and Post-Award
                           Administration of the CDFI Rapid Response Program,
                           OIG-23-032 (September 13, 2023);
                         o Treasury OIG, Audit of the Community Development
                           Financial Institutions Fund’s Implementation of the
                           CDFI Rapid Response Program, OIG-22-023
                           (December 21, 2021);
                         o Treasury OIG, Audit of the Community Development
                           Financial Institutions Fund’s Financial Statements for
                           Fiscal Year 2023, OIG-24-024 (January 29, 2024);
                           and
                         o GAO, Community Development Financial Institutions:
                           Analysis of Annual and Emergency Assistance and
                           Treasury Efforts to Address Program Risks,
                           GAO-23-105952 (December 21, 2022).
                  •   Assessed the reliability of CDFI ERP payment data as of
                      January 26, 2024, from the Bureau of the Fiscal Service’s
                      accounting system and CDFI ERP award data as of
                      November 30, 2023, from the CDFI Fund’s AMIS. Both sets
                      of information were provided to us by the CDFI Fund. We
                      assessed the reliability of data by (1) performing electronic
                      testing and reconciliation of the selected data elements for
                      accuracy and completeness; (2) reviewing existing
                      information about the payment data and systems that store
                      the data; and (3) obtaining written statements from CDFI
                      Fund officials knowledgeable about the data. We determined
                      that the data was sufficiently reliable for the purposes of this
                      audit report, therefore the data can be used for sampling.
                  •   Obtained a statistical sample of 27 CDFI ERP payment
                      recipients out of a universe of 596 CDFI ERP initial award
                      payments issued prior to November 30, 2023, with a total
                      outlay amount equal to $1.4 billion. The sample selection


   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        28
Appendix 1: Objective, Scope, and Methodology

                      was based on a 90 percent confidence level with a +/-
                      7 percent precision rate and a 5 percent anticipated error
                      rate. We used a statistical sample instead of a judgmental
                      sample because a statistical sample could be used to project
                      results to the universe population of 596 CDFI ERP initial
                      payments, whereas a judgmental sample could not be
                      projected.
                  •   Reviewed documentation related to the CDFI Fund’s
                      issuance of CDFI ERP payments to test for accuracy,
                      including, but not limited to:
                         o Payment Approval Process Flowchart, (undated),
                           provided on February 9, 2024;
                         o CDFI ERP Assistance Agreement (Assistance
                           Agreement) template, July 2023;
                         o CDFI ERP Award Sizing Workbook, April 7, 2023;
                         o CDFI Certification List as of June 24, 2022, and
                           March 15, 2024;
                         o For each of the 27 sampled recipients, we reviewed
                           each CDFI ERP recipient’s:
                                  2022 CDFI ERP Application;
                                  OMB Standard Form 424;
                                  Unique Entity Identifier Profile;
                                  CDFI ERP Scorecard;
                                  Internal Review Record;
                                  Executed Assistance Agreement;
                                  Initial Payment Request; and
                                  Award Detail Page.
                  •   Reviewed the entire universe of 92 CDFI ERP applicants who
                      did not receive an award to assess whether the CDFI Fund
                      correctly determined the applicants’ ineligibility in
                      accordance with the applicable requirements in the CDFI ERP
                      NOFA. Specifically, we reviewed the criteria set forth in the
                      NOFA and compared the CDFI Fund’s actions and
                      justifications for determining whether CDFI ERP applicants
                      who did not receive an award and evaluated whether it was
                      justified. We reviewed the CDFI Fund’s written explanations,



   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        29
Appendix 1: Objective, Scope, and Methodology

                      applicants’ Internal Review Records, and CDFI ERP
                      applications to determine whether the applicants were
                      properly excluded from receiving a CDFI ERP award.
                  •   Reviewed reporting requirements and other documentation
                      relevant to the post-award administration and monitoring of
                      the CDFI ERP, including, but not limited to:
                         o Required Annual Reports outlined in the Assistance
                           Agreement:
                                  Financial Statement Audit Report;
                                  A-133/Single Audit Report (if applicable);
                                  Performance Progress Report;
                                  Transaction Level Report;
                                  Uses of Award Report;
                                  Annual Certification and Data Collection Report;
                                   and
                                  Standard Form 425 Federal Financial Report.
                         o Annual Report submission deadlines outlined in the
                           Assistance Agreement; and
                         o Performance Goals and Measures outlined in the
                           Assistance Agreement.
                  •   Performed walkthroughs of the CDFI Fund’s award
                      determination, award sizing, and the AMIS to gain an
                      understanding of the CDFI Fund’s award process and post-
                      award administration and monitoring process related to the
                      CDFI ERP. Additionally, we performed a walkthrough to test
                      the design of the CDFI Fund’s post-award administration and
                      monitoring CDFI ERP grant recipients in AMIS.
                  •   Interviewed key CDFI Fund personnel responsible for the
                      award and post-award administration of the CDFI ERP:
                         o Deputy Director for Policy and Programs and Program
                           Manager for the CDFI ERP;
                         o Senior Advisor to the Deputy Director of Policy and
                           Programs;
                         o Manager for Financial Strategies and Research;
                         o Research Analyst for Financial Strategies and
                           Research;


   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        30
Appendix 1: Objective, Scope, and Methodology

                        o Program Manager for the Office of Compliance
                          Monitoring and Evaluation;
                        o Program Manager for the Capital Magnet Fund and
                          Closing Manager for the CDFI ERP;
                        o Associate Program Manager, CDFI ERP Compliance;
                        o Senior Accountant; and
                        o Legal Counsel.

                  We conducted this performance audit 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.




   Audit of the Community Development Financial Institutions Fund’s Award and Post-
   Award Administration of the CDFI Equitable Recovery Program (OIG-24-037)        31
Appendix 2: Management Response




  Audit of the Community Development Financial Institutions Fund’s Award and
  Post-Award Administration of the CDFI Equitable Recovery Program (OIG-24-
  037)                                                                         32
Appendix 3: Major Contributors to This Report

                      James Fuller, Audit Manager
                      Lawrence Delva-Gonzalez, Auditor-in-Charge
                      Kristin Prestel, Auditor
                      Clint Hoellrigl, Auditor
                      Kenna Stroop, Referencer




  Audit of the Community Development Financial Institutions Fund’s Award and
  Post-Award Administration of the CDFI Equitable Recovery Program (OIG-24-
  037)                                                                         33
Appendix 4: Report Distribution

                  Department of the Treasury
                      Secretary
                      Deputy Secretary
                      Under Secretary for Domestic Finance
                      Assistant Secretary for Domestic Finance
                      Assistant Secretary for Financial Institutions
                      Deputy Assistance Secretary for Community and Economic
                      Development
                      Chief Program Officer, Office of Capital Access
                      Office of Strategic Planning and Performance Management
                      Office of the Deputy Chief Financial Officer, Risk and Control
                      Group
                  Community Development Financial Institutions Fund
                      Director
                      Deputy Director of Policy and Programs
                      Acting Deputy Director of Finance and Operations
                      Legal Counsel
                  Office of Management and Budget
                      OIG Budget Examiner
                  U.S. Senate
                      Chairman and Ranking Member
                      Committee on Banking, Housing, and Urban Affairs
                  U.S. House of Representatives
                      Chairman and Ranking Member
                      Committee on Financial Services




  Audit of the Community Development Financial Institutions Fund’s Award and
  Post-Award Administration of the CDFI Equitable Recovery Program (OIG-24-
  037)                                                                           34
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