Hult International Business School, Inc.Higher Education

General Background Language During the 2024-2025 award year, Hult’s financial aid department effectively managed Title IV funds. Hult successfully carried out the administrative improvements implemented beginning Summer 2024. These improvements were the result of first, our own internal review of our financial aid operations, and feedback from the prior year’s 2023-2024 award year audit. The mitigating circumstances previously experienced were isolated to the 2023-2024 award year and do not reflect Hult’s ongoing ability to effectively manage Title IV funds. In the 2023-2024 corrective action plan, we noted that our goal was not just to rectify past mistakes but to build a stronger, more resilient foundation moving forward. Over the last year, we have followed through on these corrective actions, including: 1.Continued collaboration with Financial Aid Solutions (FAS) to effectively manage Hult’s core Title IV functions, including awarding, disbursement, and cash management activities, and utilize this resource for timely compliance support of our internal financial aid team 2. Conducted a full review and overhaul of our internal processes, procedures, and Regent system configuration to align with Hult’s business needs and maintain Title IV compliance 3. Maintaining a qualified, in-house financial aid team, with a focus on cross-training and succession planning, to ensure continuity and operational stability 4. Revision of our existing internal controls managed by the financial aid team, and implementing additional internal controls, independently managed by our central finance team, to ensure data accuracy, monitor for discrepancies, and enable prompt resolution of any identified issues Committing dedicated project management resources to identify process gaps, streamline operations, and optimize our use of system tools The successful implementation of these measures represents a deep and sustained investment in the integrity, compliance, and effectiveness of our Title IV operations. With these systems in place, we prevented a recurrence of last year’s findings related to the awarding, disbursement, or management of 2024-2025 Title IV funds. This year’s finding, in our view, was not a new finding, as these instances reflect a corrective action taken as a result of the 2023-2024 audit findings, with the correction happening within this recent audit period. Finding No. 2025-001 Return of Title IV Funds Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.268 - Federal Direct Student Loans 84.063 - Federal Pell Grant Program Responsible Individual: Marcus Friberg, VP of Finance Date Action Taken: Fiscal Year 2025 Hult acknowledges that Title IV funds were returned outside the 45-day window in four instances; however, all of which were made as a part of our corrective action plan from the FY2024 audit period. No new instances of returns outside of 45 days occurred with 2024-2025 Title IV funds. Of the four instances noted, three were directly attributable to items identified in the 2023–2024 audit, while the fourth was identified and resolved through our internal reconciliation performed to ensure no additional students were impacted. All returns of 2024-2025 Title IV funds were properly managed and made with the 45-day window. Hult’s collaboration with Financial Aid Solutions (FAS) continues to reinforce our compliance functions, cash management, and provide us with expert support. We implemented a comprehensive set of corrective actions beginning in Summer 2024 which strengthened our internal controls, which include: 1. Extensively redeveloped and tested our Regent infrastructure – in close collaboration with Regent and FAS – to ensure the system operates effectively within Hult’s academic structure, ensures the accuracy of data outputs, and maintains compliance with Title IV regulations 2. Hired a qualified, experienced, in-house financial aid team. We have, and continue, to prioritize cross-training and succession planning to ensure operational continuity 3. Implemented a dual-review process for all Title IV awards, with FAS processing calculations in Regent and Hult staff independently verifying them before disbursing funds 4. Introduced independent, recurring reconciliations of Title IV transactions by Hult’s central finance team, to ensure record accuracy and promptly resolve any issues identified These ongoing efforts have established a more resilient and accountable operational framework. We have demonstrated that with these controls in place, Hult will remain fully compliant with Title IV regulations, as there were no repeat instances of late returns in the 2024–2025 award year.

2024-001

General Background During the 2023-2024 award year, Hult International Business School, Inc.’s (“Hult”) financial aid department faced a convergence of challenges that led to the findings noted in this audit. These included the transition to the Regent Education system, unexpected staff turnover - including the departure of the Director and subsequently, remaining team - complications stemming from the Department of Education’s FAFSA simplification rollout, and a transition to a new third-party servicer. While these disruptions created a challenging environment in AY23–24, they do not reflect Hult’s current or ongoing ability to effectively manage Title IV funds. Each of the former mitigating issues have since been addressed and resolved, and Hult took steps to significantly limit how students were impacted during this transitional period. Following the departure of key personnel in Spring 2024, we identified gaps in oversight and internal controls that warranted further attention. In response, we immediately removed the individual who had been responsible for oversight of the Financial Aid team and launched a cross-functional committee to conduct an internal audit and process overhaul. Our goal was not only to correct past mistakes but to build a stronger, more resilient foundation moving forward. Key corrective actions include: • Contracting Financial Aid Solutions (FAS) to manage core Title IV functions, including awarding, disbursement, and cash management activities for immediate compliance support, while we rebuilt our internal capacity • Conducting a full review and overhaul of our processes, procedures, and Regent system configuration to align with business needs and Title IV compliance • Hiring and training a qualified, in-house financial aid team, with a focus on cross-training and succession planning, to ensure continuity and operational stability • Revising our existing internal controls managed by the financial aid team, and implementing new internal controls, independently managed by our central finance team, to ensure data accuracy, monitor for discrepancies, and enable prompt resolution of any identified issues • Committing dedicated project management resources to identify process gaps, streamline operations, and optimize our use of system tools These measures represent a deep and sustained investment in the integrity, compliance, and effectiveness of our Title IV operations. We take full responsibility for the instances raised and addressed in this report and are fully committed to preventing their recurrence. With these systems now in place, we are confident in our ability to maintain high-quality, compliant financial aid administration moving forward. Corrective Action Plan - Finding 2024-001 Hult acknowledges that Title IV funds were returned outside the 45-day window in three instances, two of which were identified during the course of this audit preparation. These delays, caused by human errors from former staff who failed to follow timely reconciliation procedures and follow through on system-initiated returns, have since been corrected and all ineligible funds have been returned in full. At this time, Hult was transitioning to a new Regent Education platform under two successive, financial aid directors. The second, despite claiming expertise with Regent, lacked the operational understanding needed for effective implementation and ongoing oversight of this system. While the individuals responsible for these occurrences are no longer with Hult, we accept full accountability for the errors and are committed to ensuring consistent, Title IV compliance moving forward. Following the departure of our most recent director in late Spring 2024, we undertook a thorough review of our financial aid operations. This assessment identified key areas for administrative improvement, which we addressed immediately by engaging Financial Aid Solutions (FAS) to reinforce our compliance functions and provide us with interim, expert support. Throughout Summer 2024, Hult implemented a comprehensive set of corrective actions to strengthen our internal controls and safeguard against future errors. These include: • Extensively redeveloped and tested our Regent infrastructure – in close collaboration with Regent and FAS – to ensure the system operates effectively with Hult’s academic structure, ensures the accuracy of data outputs, and maintains compliance with Title IV regulations • Hired a qualified, experienced, in-house financial aid team of three. We have and continue to prioritize cross-training and succession planning to ensure operational continuity • Implemented a dual-review process for all Title IV awards, with FAS processing calculations in Regent and Hult staff independently verifying them before disbursing funds • Introduced independent, recurring reconciliations of Title IV transactions by Hult’s central finance team, to ensure record accuracy and promptly resolve any issues identified These ongoing efforts have established a more resilient and accountable operational framework. We are confident that with these controls in place, Hult will remain fully compliant with Title IV regulations, and there will be no repeat instances of late returns in the 2024–25 award year.

General Background During the 2023-2024 award year, Hult International Business School, Inc.’s (“Hult”) financial aid department faced a convergence of challenges that led to the findings noted in this audit. These included the transition to the Regent Education system, unexpected staff turnover - including the departure of the Director and subsequently, remaining team - complications stemming from the Department of Education’s FAFSA simplification rollout, and a transition to a new third-party servicer. While these disruptions created a challenging environment in AY23–24, they do not reflect Hult’s current or ongoing ability to effectively manage Title IV funds. Each of the former mitigating issues have since been addressed and resolved, and Hult took steps to significantly limit how students were impacted during this transitional period. Following the departure of key personnel in Spring 2024, we identified gaps in oversight and internal controls that warranted further attention. In response, we immediately removed the individual who had been responsible for oversight of the Financial Aid team and launched a cross-functional committee to conduct an internal audit and process overhaul. Our goal was not only to correct past mistakes but to build a stronger, more resilient foundation moving forward. Key corrective actions include: • Contracting Financial Aid Solutions (FAS) to manage core Title IV functions, including awarding, disbursement, and cash management activities for immediate compliance support, while we rebuilt our internal capacity • Conducting a full review and overhaul of our processes, procedures, and Regent system configuration to align with business needs and Title IV compliance • Hiring and training a qualified, in-house financial aid team, with a focus on cross-training and succession planning, to ensure continuity and operational stability • Revising our existing internal controls managed by the financial aid team, and implementing new internal controls, independently managed by our central finance team, to ensure data accuracy, monitor for discrepancies, and enable prompt resolution of any identified issues • Committing dedicated project management resources to identify process gaps, streamline operations, and optimize our use of system tools These measures represent a deep and sustained investment in the integrity, compliance, and effectiveness of our Title IV operations. We take full responsibility for the instances raised and addressed in this report and are fully committed to preventing their recurrence. With these systems now in place, we are confident in our ability to maintain high-quality, compliant financial aid administration moving forward. Corrective Action Plan - Finding 2024-002 The twenty impacted students noted in Finding 2024-002 were tied to just two disbursement batches - dated September 28, 2023, and February 28, 2024 — not twenty separate events. In both cases, disbursements were accurately recorded in COD, funds were available to students on time, and G-5 draws were eventually completed (during year-end reconciliation) in September 2024. Since the majority of the funds in these disbursement batches were FSEOG, there was not a significant impact on ED Title IV accounting due to FSEOG budgets being predetermined and capped. Additionally, the amounts of these disbursements were credited to students’ accounts, so they were not disadvantaged by this administrative delay. As with the instances in Finding 1 these delays resulted from administrative oversight and human error. While disbursements were initiated in Regent, the full-step process not properly completed, and the managing staff failed to conduct a timely review that would have identified that funds were requested but never received. These issues occurred during periods of major administrative transitions—first, during the initial implementation of Regent in the fall, and then in the spring, during the departure of the former Financial Aid Director and the handoff between third-party servicers. These were isolated incidents caused by temporary disruptions to our internal controls, not indicators of systemic risk. All underlying conditions have since been fully resolved. In response, as outlined in our response to Finding 1, we conducted a full review and overhaul of our Title IV processes. As of Spring 2024, Financial Aid Solutions (FAS) has assumed direct management of awarding, disbursement, and cash management for the 2024–25 academic year. This support has enabled us to fully leverage Regent’s compliance features, enforce strict reconciliation protocols through FAS, and add real-time oversight by Hult’s central finance team. Specifically, to ensure timely and accurate G-5 draws: • FAS manages Title IV disbursements, including the G5 draw downs and reconciliations with COD • All disbursement process steps are actioned within the same business day to reduce errors • Hult has implemented internal controls to reconcile Title IV cash transactions against student ledgers within 1-2 business days • Hult’s revised the monthly bank reconciliation of the federal account to specifically capture unfunded disbursements These measures have established strong safeguards for the Title IV cash management operations. With these protocols in place, we are confident that delayed G-5 draws will not recur in the 2024-2025 award year or beyond.

To ensure compliance with federal guidelines, the School has already in September 2023 implemented a process of validating received bank information from students by issuing a $1 transaction to ensure validity. The improvement of this internal control will only be reflected in next year's audit. Further, from September 2024, the School is implementing a policy of requiring verified bank information from students expecting a loan refund in order to matriculate, which will simplify the refund process. Additionally, in those rare instances in which electronic funds transfers cannot be made, our policies and procedures will be amended so that adequate documentation of check disbursements is maintained.

The School will file all future reports in an accurate and timely manner.

The School is in the process of developing a written procurement policy that will comply with the requirements of 2 CFR section 200.320.