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Audit Report - Oig 25 011 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Air Carrier

Summary

Department of the Treasury Office of Inspector General Audit Report OIG-25-011, Audit of Air Carrier Worker Support Certifications - AerSale, Inc., dated November 19, 2024, with a memorandum from Deborah L. Harker, Assistant Inspector General for Audit, to Jessica Milano, Chief Program Officer. It states that the audit, performed by Saggar & Rosenberg, P.C. under a contract monitored by OIG, assessed the accuracy, completeness and sufficiency of AerSale's sworn financial statement or other data used to certify compensation amounts for the Air Carrier Payroll Support Program (PSP1), covering April 1, 2019 through September 30, 2019. It states that AerSale incorrectly compiled data in the Awardable Amounts section of its application, but understated its requested amount by $559,783 and did not over-request PSP1 financial assistance.

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Inspector general and oversight reports
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Audit Report
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Oig 25 011 Coronavirus Disease 2019 Pandemic Relief Programs Audit Of Air Carrier

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Full text

Audit Report




OIG-25-011


CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF
PROGRAMS


Audit of Air Carrier Worker Support
Certifications - AerSale, Inc.



November 19, 2024




Office of Inspector General
Department of the Treasury
This Page Intentionally Left Blank
                                     November 19, 2024



MEMORANDUM FOR JESSICA MILANO
               CHIEF PROGRAM OFFICER

FROM:                    Deborah L. Harker /s/
                         Assistant Inspector General for Audit

SUBJECT:                 Audit of Air Carrier Worker Support Certifications – AerSale,
                         Inc.

Attached is our audit report for the Audit of Air Carrier Worker Support Certification –
AerSale, Inc. (AerSale) (OIG-25-011); dated November 19, 2024. Under a contract
monitored by our office, Saggar & Rosenberg, P.C. (S&R), a certified independent
public accounting firm, performed the audit. The objective of this audit was to assess
the accuracy, completeness, and sufficiency of AerSale’s sworn financial statement or
other data used to certify the wages, salaries, benefits, and other compensation
amounts submitted and approved by the Department of the Treasury (Treasury) for the
Air Carrier Payroll Support Program (PSP1). This audit was mandated by Title IV,
Subtitle B, Air Carrier Worker Support, of the Coronavirus Aid, Relief, and Economic
Security Act (CARES Act). 1 The scope of this audit covered the period from
April 1, 2019 through September 30, 2019, and included the certified PSP1
Application, sworn financial statement, tax returns, and other documentation
submitted to Treasury.

In its audit report, S&R found that AerSale incorrectly compiled data used for the
Awardable Amounts section of the PSP1 Application. Specifically, the:

    •   Inclusion of unsupported life insurance benefit amounts, resulted in an
        overstatement of           .

However, the overstatements were entirely offset by:




1
    P.L. 116–136 (March 27, 2020).
      •   Differences between actual healthcare benefits paid and the application figures
          compiled using actuarial estimates, 2 resulting in an understatement of
          $235,593; and

      •   Exclusion of non-aviation leased employees’ compensation, resulting in an
          understatement of             .

Overall, AerSale understated its requested amount by $559,783 and did not
over-request PSP1 financial assistance despite partial non-compliance with application
requirements.

Our contract required that the audit be performed in accordance with generally
accepted government auditing standards. In connection with the contract, we
reviewed S&R’s report and related documentation and inquired of its representatives.
Our review, as differentiated from an audit performed in accordance with generally
accepted government auditing standards, was not intended to enable us to express an
opinion on AerSale’s compliance with Treasury’s PSP1 policies and procedures. S&R is
responsible for the attached auditor’s report and the conclusions expressed therein.
Our review found no instances in which S&R did not comply, in all material respects,
with generally accepted government auditing standards.

We appreciate the courtesies and cooperation provided to S&R and our staff during
the audit. If you have any questions or require further information, please contact me
at (202) 486-1420, or a member of your staff may contact Lisa DeAngelis, Audit
Director, at (202) 487-8371.

Attachment

cc:       Gregory Till, Chief Operating Officer, Office of Capital Access, Department of
            the Treasury
          Danielle Christensen, Deputy Chief Program Officer, Office of Capital Access,
            Department of the Treasury
          Jason Morrow, Senior Counsel, Department of the Treasury
          Jeff Davis, Partner, Saggar & Rosenberg, P.C.




2
    An actuarial estimate is a mathematical model used to forecast uncertain variables or events for the
    purposes of calculating insurance premiums or benefits.
Contents
Audit Report
Results in Brief ...................................................................................................2

Background ........................................................................................................3

                   Treasury Disbursement Processes ....................................................5
                   PSP1 Interim Audit Report ...............................................................6
                   AerSale, Inc...................................................................................7

Audit Results......................................................................................................8

    Finding 1 AerSale Did Not Over-Request PSP1 Financial Assistance Despite Partial
              Non-Compliance with Application Requirements .................................9

Appendices
Appendix 1: Objective, Scope, and Methodology ..................................................11
Appendix 2: AerSale Management Response........................................................15
Appendix 3: Treasury Management Response ......................................................16
Appendix 4: Report Distribution ..........................................................................19


Abbreviations
AerSale                       AerSale, Inc.
CARES Act                     Coronavirus Aid, Relief, and Economic Security Act
COVID-19                      Coronavirus Disease 2019
DOT                           Department of Transportation
GAO                           Government Accountability Office
Guidelines                    Guidelines and Application Procedures for Payroll Support to Air
                                Carriers and Contractors
IRS                           Internal Revenue Service
OIG                           Treasury Office of Inspector General
PSP1                          Payroll Support Program, CARES Act
PSP2                          Payroll Support Program Extension, Consolidated Appropriations
                                Act, 2021
PSP3                          Payroll Support Program 3, American Rescue Plan Act of 2021
S&R                           Saggar & Rosenberg, P.C.
SOC 1                         System and Organizational Controls
Treasury                      Department of the Treasury


                                                                                                                    i
This Page Intentionally Left Blank
                        November 19, 2024

                        Jessica Milano
                        Chief Program Officer
                        Department of the Treasury

                        This report presents the results of our audit of AerSale, Inc.’s
                        (AerSale) certifications made to the Department of the
                        Treasury (Treasury) as part of its participation in the Air Carrier
                        Payroll Support Program (PSP1). This audit was mandated by
                        Title IV, Subtitle B, Air Carrier Worker Support, of the Coronavirus
                        Aid, Relief, and Economic Security Act (CARES Act). 1 Under the
                        CARES Act, Treasury was to provide $32 billion in financial
                        assistance to passenger air carriers, cargo air carriers, and certain
                        contractors to be exclusively used for the continuation of payment
                        of employee wages, salaries, and benefits, in response to the
                        economic impact of the Coronavirus Disease 2019 (COVID-19). 2
                        Furthermore, the Treasury Office of Inspector General (OIG) is
                        required to audit certifications made by passenger and cargo air
                        carriers that do not report salaries and benefits to the Department
                        of Transportation (DOT) (hereinafter referred to as non-241 air
                        carriers) 3 and contractors.

                        Under a contract with OIG, Saggar & Rosenberg, P.C. (S&R)
                        conducted this audit. Our audit objective was to assess the
                        accuracy, completeness, and sufficiency of AerSale’s sworn
                        financial statement or other data used to certify the wages,
                        salaries, benefits, and other compensation amounts submitted and
                        approved by Treasury for PSP1. The scope of our audit covered the
                        period from April 1, 2019 through September 30, 2019, and
                        included the certified PSP1 Application, sworn financial statement,


1
    P.L. 116–136 (March 27, 2020).
2
    The financial assistance provided under the CARES Act was split between Passenger Air Carriers
    ($25 billion), Cargo Air Carriers ($4 billion), and Contractors ($3 billion).
3
    Passenger and cargo air carriers that are not required to report salaries and wages to DOT under
    14 CFR, Part 241, “Uniform System of Accounts and Reports for Large Certificated Air Carriers”.



                        Audit of Air Carrier Worker Support Certifications – AerSale, Inc.
                        (OIG-25-011)                                                              1
                        tax returns, and other documentation submitted to Treasury on
                        April 10, 2020. 4

                        To accomplish the objective, we reviewed applicable laws,
                        regulations, and Treasury’s policies and procedures, including but
                        not limited to, Title IV, Subtitle B, Air Carrier Worker Support of the
                        CARES Act; Guidelines and Application Procedures for Payroll
                        Support to Air Carriers and Contractors (Guidelines); PSP1
                        Agreement; and Frequently Asked Questions: Application
                        Procedures for Payroll Support to Air Carriers and Contractors. We
                        interviewed key personnel from AerSale, Treasury, and contracted
                        consultants engaged by Treasury to evaluate certified company
                        applications. We conducted our fieldwork from August 2023
                        through June 2024. Appendix 1 contains a more detailed
                        description of our objective, scope, and methodology.


Results in Brief

                        In brief, S&R found that AerSale, a contractor, reported correct
                        information for three of the four sections reviewed on its PSP1
                        Application. 5 These sections are: (1) Applicant Information,
                        (2) Applicant Type, and (3) Certification. For the Awardable
                        Amounts section, we found that AerSale was unable to provide
                        sufficient supporting documentation to demonstrate that
                        requested for life insurance benefits were eligible for PSP1.
                        However, the unsupported life insurance benefit amounts were
                        entirely offset by (1) differences between actual healthcare
                        benefits paid and the application figures compiled using actuarial
                        estimates, 6 resulting in an understatement of $235,593; and
                        (2) exclusion of non-aviation leased employees’ compensation,
                        resulting in an understatement of             . Overall, AerSale
                        understated its requested amount by $559,783 and did not


4
    AerSale submitted its initial PSP1 Application and related support documentation totaling
                  on April 10, 2020. AerSale later revised its awardable amount to                  on
    May 20, 2020.
5
    The PSP1 Application is comprised of eight sections. Four sections - Financial Institution Information,
    Employment Levels, Taxpayer Protection, and Additional Information, were not subject to audit
    procedures. Details regarding the sections not reviewed can be found in appendix 1.
6
    An actuarial estimate is a mathematical model used to forecast uncertain variables or events for the
    purposes of calculating insurance premiums or benefits.



                        Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                        (OIG-25-011)                                                                 2
             over-request PSP1 financial assistance despite partial
             non-compliance with application requirements.

             As part of our reporting process, we provided Aersale management
             with an opportunity to comment on a draft of this report. In a
             written response, Aersale management stated it does not dispute
             that substantiation was not provided for life insurance expenses.
             The company also noted it did not pursue additional support in the
             interest of time, as well as consideration of the offsetting
             understatements that greatly exceeded this amount. Aersale
             management’s response, in its entirety, is included as appendix 2
             of this report.

             In a written response, Treasury management stated the draft report
             describes work performed by OIG’s contractor to determine
             whether the recipient’s requested awardable amount complied with
             Treasury’s program requirements. The draft report notes the
             extensive fieldwork conducted for this review between
             August 2023 and June 2024, including interviewing AerSale’s
             management and reviewing a wide range of the company’s
             financial records and corporate documents. In relation to AerSale,
             Treasury management noted that OIG’s contractor found no
             amounts were overpaid. Treasury management appreciates the
             OIG’s work on this engagement and looks forward to working with
             the OIG to protect the integrity of the PSP and other recovery
             programs. Treasury management’s response, in its entirety, is
             included as appendix 3 of this report.


Background

             Title IV, Subtitle B, of the CARES Act, Air Carrier Worker Support,
             requires Treasury to provide financial assistance to air carriers and
             contractors that must exclusively be used for the continuation of
             payments of employees’ wages, salaries, and benefits. Financial
             assistance is to be provided to:

                (1) passenger air carriers, in an aggregate amount up to
                    $25 billion;
                (2) cargo air carriers, in an aggregate amount up to $4 billion;
                    and
                (3) contractors, in an aggregate amount up to $3 billion.


             Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
             (OIG-25-011)                                                         3
                         According to the CARES Act, Treasury is required to provide
                         financial assistance to air carriers that report salaries and benefits
                         to DOT (referred to as 241 air carriers), 7 in an amount equal to the
                         salaries and benefits reported to DOT for the period April 1, 2019
                         through September 30, 2019. For air carriers that do not report
                         such data to DOT (referred to as non-241 carriers), and
                         contractors, financial assistance is required to be in an amount that
                         the air carrier or contractor certifies using sworn financial
                         statements or other appropriate data as the amount of wages,
                         salaries, benefits, and other compensation paid to employees
                         during the period of April 1, 2019 through September 30, 2019.
                         The amounts submitted on the application to Treasury were
                         considered sworn financial statements. To be eligible for payments,
                         air carriers and contractors must enter into agreements with
                         Treasury certifying that they meet certain required assurances,
                         terms, and conditions.

                         On March 30, 2020, Treasury posted on its website the
                         Guidelines, which included the PSP1 Application. The PSP1
                         Application is comprised of eight sections:

                         1. Applicant Information ─ (1) applicant name; (2) taxpayer
                            identification number and address; and (3) contact person’s
                            name, title, phone number, and email address.

                         2. Applicant Type ─ selection of applicant type whether it is
                            passenger air carrier, cargo air carrier, or contractor.
                            Additionally, if the applicant is a contractor, this section would
                            identify the contractor’s service functions and the name of the
                            air carrier or airport to which services are provided. Finally, this
                            section includes affiliate and parent company information.

                         3. Financial Institution Information ─ (1) the applicant’s account
                            number and routing number; and (2) the financial institution’s
                            name, address, and telephone number.

7
    14 CFR, Part 241 “Uniform System of Accounts and Reports for Large Certificated Air Carriers”
    defines “Air carrier, large certificated” as an air carrier holding a certificate issued under 49 U.S.C.
    41102, as amended, that: (1) operates aircraft designed to have a maximum passenger capacity of
    more than 18,000 pounds; or (2) conducts operations where one or both terminals of a flight stage
    are outside the 50 states of the United States, the District of Columbia, the Commonwealth of
    Puerto Rico, and the U.S. Virgin Islands. These air carriers are required to report financial information
    to DOT. AerSale is not a Large Certificated Air Carrier.



                         Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                         (OIG-25-011)                                                                   4
                        4. Employment Levels ─ applicant’s average number of employees
                           for 2019 and involuntary reductions after March 1, 2020.

                        5. Awardable Amounts ─ applicant’s sworn financial statement
                           consisting of salaries, wages, benefits, and other compensation
                           for the period April 1, 2019 through September 30, 2019.

                        6. Taxpayer Protection ─ a table that outlines in detail the
                           proposed financial instrument to be issued to Treasury.

                        7. Additional Information ─ applicant’s verification of submitting its
                           Internal Revenue Service (IRS) Form 941, Employer’s Quarterly
                           Federal Tax Return, 8 covering the period April 1, 2019 through
                           September 30, 2019, along with the PSP1 Application
                           submitted to Treasury.

                        8. Certification ─ names, titles, and signatures of two certifying
                           officials 9 and the applicant’s name and application submission
                           date.

                        On April 18, 2020, Treasury published a sample PSP1 Agreement
                        on its website, which provided definitions, terms, and conditions
                        for participation in PSP1, and required applicants to submit
                        completed applications by April 27, 2020. After Treasury reviewed
                        and approved an application, both parties were required to sign the
                        PSP1 Agreement.

                        Treasury Disbursement Processes
                        To disburse PSP1 payments to contractor applicants as quickly as
                        possible and prior to the application deadline of April 27, 2020,
                        Treasury applied an initial estimated pro-rata rate of 69.7 percent
                        to the awardable amount because not all applications had been
                        submitted at the time. After the application deadline, Treasury
                        determined the total amount requested by all contractors was
                        approximately $4.1 billion, which exceeded the $3 billion available

8
    IRS Form 941 is a tax form that businesses file quarterly to report income taxes, Social Security
    taxes, and Medicare taxes they withheld from employees’ paychecks.
9
    The certifying officials attested under penalty of perjury that the information and certifications
    provided in the application and its attachments are true and correct.



                        Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                        (OIG-25-011)                                                                     5
                         financial assistance. Because its initial estimated pro-rata rate was
                         low, Treasury calculated an additional 20.3 percent, the top-off
                         amount, for contractors making the final pro-rata rate 90 percent.
                         Treasury explained that 17 contractors did not accept the top-off
                         amount; as such, the final awardable amount for those contractors
                         was 69.7 percent.

                         Treasury disbursed an initial lump sum payment of one-third of the
                         awardable amount, followed by four equal subsequent payments to
                         ensure it provided sufficient and timely financial assistance
                         corresponding to the applicants’ payroll schedule. In instances
                         where Treasury needed to perform additional follow-up with
                         contractors or needed additional time to approve applications,
                         Treasury compressed the payment schedule on a case-by-case
                         basis. Generally, Treasury disbursed the top-off amounts for
                         contractors in February 2021.

                         PSP1 Interim Audit Report
                         In a prior audit report, 10 OIG identified two systemic issues
                         affecting the payment amounts administered to all PSP1 recipients
                         for non-241 air carriers and contractors. Specifically, some of the
                         recipients audited included unallowable employer-side payroll taxes
                         and/or corporate officer compensation in their calculation of the
                         awardable amounts on their PSP1 applications. Treasury
                         management acknowledged these issues and agreed to: (1) review
                         payments issued under PSP1 to ensure awarded amounts are
                         allowable per the CARES Act and Treasury guidance; and
                         (2) remedy the incorrect amounts awarded under PSP1. Based on
                         our recommendations, in March 2022 Treasury implemented a
                         PSP1 recertification process whereby recipients had to certify
                         whether they excluded employer-side payroll taxes and corporate
                         officer compensation in their calculation of the awardable amounts
                         on their PSP1 applications. Treasury’s goal was to determine if
                         overpayments were made to recipients based on inaccurate
                         information included in PSP1 applications.

                         Treasury officials told us that if recoupment was necessary for an
                         applicant’s inclusion of unallowable expenses, such as corporate

10
     OIG-21-025, Interim Audit Update – Air Carrier and Contractor Certifications for Payroll Support
     Program (Interim Audit), March 31, 2021.



                         Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                         (OIG-25-011)                                                                   6
officer compensation and employer-side payroll taxes in the
application, the recoupment method was dependent on timing. Any
overpayment was first offset against the approved top-off
payment. If an overpayment remained, or the overpayment was
identified after all PSP1 disbursements were made, and the
recipient was entitled to PSP2 or PSP3 funding, the overpayment
was offset against the PSP2 and/or PSP3 awards prior to issuance.
All remaining PSP1 overpayments not previously collected where
the recipient did not qualify for, or apply for, PSP2 and PSP3
funding, were required to be repaid to Treasury.

AerSale, Inc.
Headquartered in Doral, Florida, AerSale is a contractor that
provides a variety of services to commercial airlines including, but
not limited to, aircraft and component maintenance, repair and
overhaul, aircraft and engine sales and leasing, and used
serviceable material sales and parts exchange.

AerSale submitted its initial PSP1 Application totaling
on April 10, 2020. AerSale later revised its awardable amount to
              on May 20, 2020, during Treasury’s application
review process. The company accepted the contractor top-off for a
total award amount of $16,389,428, or 90 percent of the
company’s requested amount. Treasury’s disbursements to AerSale
were as follows:

   •   June 10, 2020: $6,346,351

   •   July 1, 2020: $2,115,450

   •   August 3, 2020: $2,115,450

   •   September 1, 2020: $2,115,450

   •   February 22, 2021: $3,696,727




Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
(OIG-25-011)                                                         7
                       In addition to PSP1, Treasury awarded AerSale $5,535,985 under
                       the Payroll Support Program Extension (PSP2) 11 authorized by the
                       Consolidated Appropriations Act, 2021 and $5,535,985 under the
                       Payroll Support Program 3 (PSP3) 12 authorized by the American
                       Rescue Plan Act of 2021. PSP2 and PSP3 were not the subject of
                       this audit.


Audit Results

                       We found that AerSale reported correct information for three of the
                       four sections reviewed on its PSP1 Application. These sections are:
                       (1) Applicant Information, (2) Applicant Type, and (3) Certification.
                       We compared information provided in each section of the PSP1
                       Application to supporting documentation including general ledger
                       data, company sworn financial statement, IRS Form 941,
                       executive-level business charts, payroll registers, and third-party
                       benefit claims and invoices.

                       For the Awardable Amounts section, we found that AerSale was
                       unable to provide sufficient supporting documentation to
                       demonstrate that            requested for life insurance benefits
                       were eligible for PSP1. However, the unsupported life insurance
                       benefit amounts were entirely offset by (1) differences between
                       actual healthcare benefits paid and the application figures compiled
                       using actuarial estimates, resulting in an understatement of
                       $235,593; and (2) exclusion of non-aviation leased employees’
                       compensation, resulting in an understatement of              .
                       Overall, AerSale understated its requested amount by $559,783
                       and did not over-request PSP1 financial assistance despite partial
                       non-compliance with application requirements.




11
   The Consolidated Appropriations Act, 2021 (P.L. 116–260), enacted on December 27, 2020,
   created the Airline Worker Support Extension for passenger air carriers and certain contractors.
   Treasury referred to this as Payroll Support Program Extension (PSP2).
12
   The American Rescue Plan of 2021 (P.L. 117–2), enacted on March 11, 2021, created the Air
   Transportation Payroll Support Program Extension authorizing Treasury to provide additional
   assistance to passenger air carriers and contractors that received financial assistance under PSP2.
   Treasury referred to this as Payroll Support Program 3 (PSP3).



                       Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                       (OIG-25-011)                                                                 8
Finding 1   AerSale Did Not Over-Request PSP1 Financial Assistance
            Despite Partial Non-Compliance with Application
            Requirements

            Both the CARES Act and Treasury’s Guidelines define “employee”
            as “an individual, other than a corporate officer, who is employed
            by an air carrier or contractor in the United States (including its
            territories and possessions).”

            Treasury’s Guidelines define wages, salaries, benefits, and other
            compensation as:
                remuneration paid by the applicant to its employees for
                personal services and includes salaries, wages, overtime pay,
                cost-of-living differentials, and other similar compensation, as
                distinguished from per diem allowances or reimbursement for
                expenses incurred by personnel for the benefit of the applicant.
            In addition, the Guidelines define Awardable Amounts as:

               an amount that such contractor certifies, using sworn financial
               statements or other appropriate data, as the amount of wages,
               salaries, benefits, and other compensation that such contractor
               paid its employees during the time period.

            AerSale did not provide sufficient supporting documentation to
            demonstrate that             of the amounts requested for life
            insurance benefits were eligible for PSP1. The company was unable
            to provide life insurance invoices, itemized at the employee-level,
            to quantify the amounts associated with ineligible corporate
            officer’s benefits.

            However, the              unsupported benefits overstatement was
            entirely offset by differences between actual healthcare benefits
            paid and the application figures compiled using actuarial estimates,
            totaling $235,593. This resulted in a total benefits understatement
            of            . Additionally, AerSale understated its salaries and
            wages by not claiming amounts paid for non-aviation leased
            employees, totaling             , resulting in an aggregate
            understatement of $559,783.

            For healthcare benefits, AerSale management stated that it used
            actuarial estimates, as opposed to actual payments, to exercise


            Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
            (OIG-25-011)                                                         9
                         conservatism. Further, AerSale management elected not to pursue
                         additional efforts to obtain itemized life insurance supporting
                         documentation, as there was already a sufficient understatement in
                         amounts requested.

                         For “Salaries and Wages”, AerSale management stated that its
                         interpretation of the CARES Act was that only employees who
                         supported aviation operations would be eligible for PSP1 and
                         therefore excluded non-aviation leased employees.

                         To remedy the findings listed in the prior OIG audit report, 13
                         Treasury required PSP2 applicants to recertify their PSP1
                         awardable amounts. AerSale certified to Treasury under PSP2, that
                         its PSP1 Application did not include corporate officer compensation
                         or employer-side payroll taxes. Although AerSale was unable to
                         provide sufficient documentation to support the exclusion of
                         corporate officers’ life insurance benefits from the requested
                         amount, the company did not over-request PSP1 financial
                         assistance because the actual compensation incurred exceeded the
                         requested amount.

                                                          ******

                         We appreciate the courtesies and cooperation provided to our staff
                         during the audit. A distribution list for this report is provided as
                         appendix 4.

                         Saggar & Rosenberg, P.C. /s/




13
     OIG-21-025, Interim Audit Update – Air Carrier and Contractor Certifications for Payroll Support
     Program (Interim Audit), March 31, 2021.



                         Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                         (OIG-25-011)                                                              10
Appendix 1: Objective, Scope, and Methodology

                        Our objective was to assess the accuracy, completeness, and
                        sufficiency of AerSale, Inc.’s (AerSale) sworn financial statement
                        or other data used to certify the wages, salaries, benefits, and
                        other compensation amounts submitted and approved by the
                        Department of the Treasury (Treasury).

                        The scope of our audit covered the period from April 1, 2019
                        through September 30, 2019, and included the certified Payroll
                        Support Program (PSP1) Application, sworn financial statement,
                        tax returns, and other documentation submitted to Treasury on
                        April 10, 2020. 14

                        To accomplish this objective, Saggar & Rosenberg, P.C. (S&R)
                        performed the following activities during audit fieldwork from
                        August 2023 through June 2024:

                        •   Reviewed applicable laws and regulations, including:
                                o Title IV, Subtitle B, Air Carrier Worker Support, of the
                                  Coronavirus Aid, Relief, and Economic Security Act
                                  (CARES Act); 15 and
                                o 14 CFR, Part 241, 16 Uniform System of Accounts and
                                  Reports for Large Certificated Air Carriers,
                                  December 28, 2023.
                        •   Reviewed Treasury’s policies and procedures related to PSP1:
                                o Guidelines and Application Procedures for Payroll Support
                                  to Air Carriers and Contractors (Guidelines), which
                                  included the PSP1 Application, March 30, 2020;
                                o PSP1 Agreement;

14
   AerSale submitted its initial PSP1 Application and related support documentation totaling
                  on April 10, 2020. AerSale later revised its awardable amount request to
   on May 20, 2020.
15
   P.L. 116–136 (March 27, 2020).
16
   14 CFR, Part 241 “Uniform System of Accounts and Reports for Large Certificated Air Carriers”
   defines “Air carrier, large certificated” as an air carrier holding a certificate issued under 49 U.S.C.
   41102, as amended, that: (1) operates aircraft designed to have a maximum passenger capacity of
   more than 18,000 pounds; or (2) conducts operations where one or both terminals of a flight stage
   are outside the 50 states of the United States, the District of Columbia, the Commonwealth of
   Puerto Rico, and the U.S. Virgin Islands. These air carriers are required to report financial information
   to the Department of Transportation. AerSale is not a Large Certificated Air Carrier.



                        Audit of Air Carrier Worker Support Certifications – AerSale, Inc.
                        (OIG-25-011)                                                                 11
Appendix 1: Objective, Scope, and Methodology

                               o Question and Answer: Payroll Support to Air Carriers and
                                 Contractors, (April 2, 2020, April 3, 2020 and
                                 April 20, 2020 versions); and
                               o Frequently Asked Questions: Application Procedures for
                                 Payroll Support to Air Carriers and Contractors,
                                 April 3, 2020.
                       •   Performed 100 percent testing for four of the eight sections of
                           the PSP1 Application—specifically, the Applicant Information,
                           Applicant Type, Awardable Amounts, and Certification sections.
                           The other four sections were not reviewed because the
                           Taxpayer Protection section generally applied to 241 air
                           carriers, with exceptions; the Employment Levels, Financial
                           Institution Information, and Additional Information sections had
                           no impact on Treasury’s determination of recipients’ award
                           amounts.
                       •   Interviewed key Treasury personnel and contracted consultant
                           personnel engaged by Treasury to aid in its evaluation of the air
                           carriers’ and the contractors’ certified applications and other
                           data.
                       •   Interviewed AerSale management responsible for the completion
                           and submission of the sworn financial statement in the
                           Awardable Amounts section of the PSP1 Application.
                       •   Reviewed sworn financial statement and documents to support
                           the requested payroll support amount. The documentation
                           included general ledger data, company pay registers, benefit
                           claim information, Internal Revenue Service (IRS) Form 941,
                           Employer’s Quarterly Federal Tax Return 17 filings, and
                           organizational hierarchy information.
                       •   Reviewed Government Accountability Office’s (GAO) Standards
                           for Internal Control in the Federal Government 18 to identify the
                           components of internal control that are significant to the audit
                           objective. Understanding internal control within the context of
                           an entity’s internal control framework can help auditors
                           determine whether internal control deficiencies exist. We
                           concluded that one of the five internal control components,
                           Control Activities, as related to AerSale’s payroll system, was


17
   IRS Form 941 is a tax form that businesses file quarterly to report income taxes, Social Security
   taxes, and Medicare taxes they withheld from employees’ paychecks.
18
   GAO-14-704G (September 2014).



                       Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                       (OIG-25-011)                                                               12
Appendix 1: Objective, Scope, and Methodology

                           significant to the audit objective. 19 This component states that
                           control activities are the actions management establishes
                           through policies and procedures to achieve objectives and
                           respond to risks in the internal control system, which includes
                           the entity’s information system. To assess the controls over
                           AerSale’s payroll and accounting system, we examined
                           AerSale’s response to Data Supplier Questionnaires, 20 reviewed
                           a System and Organizational Controls 1 (SOC 1), 21 and
                           interviewed AerSale’s management responsible for generating
                           and using the data. Additional details regarding our assessment
                           of the reliability of the data is reported in the section below.
                       •   Reviewed GAO’s Assessing Data Reliability 22 guidance, which
                           states that a data reliability determination does not involve
                           attesting to the overall reliability of the data or database. For
                           this audit, the audit team has only determined the reliability of
                           the specific data sources needed to support the findings,
                           conclusions, or recommendations in the context of the audit
                           objective. AerSale prepared the PSP1 Application using payroll
                           and benefit compensation from April 2019 through
                           September 2019, which included information developed from
                           AerSale’s payroll and financial accounting systems. We
                           compared details generated from payroll registers at the
                           individual employee level, as well as third-party benefit data
                           from April 2019 through September 2019 to the amounts
                           presented in the Awardable Amounts section of the PSP1
                           Application.
                           To assess data reliability of these sources, we examined the
                           Data Supplier Questionnaires for the payroll and financial
                           accounting systems, reviewed the SOC 1 report for the payroll
                           system, and interviewed AerSale’s management responsible for
                           generating and using the data. Based on our assessment, we
                           determined that the data was sufficiently reliable to support the
                           findings and conclusions to answer the objective of this audit.

19
   The five components of internal control are Control Environment, Risk Assessment, Control
   Activities, Information and Communication, and Monitoring.
20
   A Data Reliability Assessment is completed to assess the reliability of data originating from a system
   to determine if it is reliable for the purposes of the audit. The Data Supplier Questionnaire would be
   one of the tools used during the Data Reliability Assessment.
21
   SOC 1 report addresses a company’s internal control over financial reporting, which pertains to the
   application of checks-and-limits. Essentially, it is the audit of a third-party vendor’s accounting and
   financial controls.
22
   GAO-20-283G (December 2019).



                       Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
                       (OIG-25-011)                                                                13
Appendix 1: Objective, Scope, and Methodology

               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 objective. We believe that the
               evidence obtained provides a reasonable basis for our findings and
               conclusions based on our audit objective.




               Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
               (OIG-25-011)                                                         14
Appendix 3: Treasury Management Response




            Audit of Air Carrier Worker Support Certifications – AerSale, Inc.
            (OIG-25-011)                                                         16
Appendix 3: Treasury Management Response




              Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
              (OIG-25-011)                                                         17
Appendix 3: Treasury Management Response




              Audit of Air Carrier Worker Support Certifications - AerSale, Inc.
              (OIG-25-011)                                                         18
Appendix 4: Report Distribution

              Department of the Treasury
                 Deputy Secretary
                 Treasury Audit Liaison
                 Office of Strategic Planning and Performance Improvement
                 Office of the Deputy Chief Financial Officer, Risk and Control
                   Group
              AerSale, Inc.
                 Chief Executive Officer
                 Chief Financial Officer
              Office of Management and Budget
                 OIG Budget Examiner
              United States Senate
                 Committee on Homeland Security and Governmental Affairs
                 Committee on Finance
                 Committee on Banking, Housing, and Urban Affairs
                 Committee on Commerce, Science, and Transportation
                 Committee on Appropriations
                 Committee on the Budget
              United States House of Representatives
                 Committee on Oversight and Accountability
                 Committee on Financial Services
                 Committee on the Budget
                 Committee on Transportation and Infrastructure




              Audit of Air Carrier Worker Support Certifications – AerSale, Inc.
              (OIG-25-011)                                                         19
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