Wyoming Women's Business CenterNon-Profit

2020-002 – Allowable Costs & Period of Performance Material Weakness in Internal Controls Over Compliance and Instances of Noncompliance Assistance Listing Number: 59.046 Federal Agency/Pass-through Entity - Program Name: Small Business Administration - Microloan Program Award Number(s): SBAHQ19Y0115 & SBAOCAML200065-01-00 Award Year(s): 2019 & 2020 Criteria or specific requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Lastly, according to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Condition: The Organization was unable to provide underlying details and/or related documentation for $5,981 in expenditures reported under the Microloan Program to support the allowability or period of performance. Questioned Costs: $5,981 Context: During our audit procedures, we were unable to obtain general ledger detail or supporting documentation for $962 for Award #SBAOCAML200065-01-00 and $4,878 for Award #SBAHQ19Y0115 to substantiate total program non-payroll expenditures or period of performance. Additionally, during testing, three (3) out of 15 non-payroll disbursements, totaling $141, did not have supporting documentation. Cause: The Organization did not have internal controls in place to ensure adequate documentation and records retention to ensure compliance with grant requirements. Effect or potential effect: The Organization is out of compliance with 2 CFR Section 200.403(g) and the awards' periods of performance. Repeat Finding: No Recommendation: The Organization should implement controls to ensure accurate recordkeeping and document retention to substantiate expenditures allocated to grants. Views of responsible officials: The Organization agrees with the finding and has implemented controls to ensure accurate recordkeeping, and to ensure that documents are retained to substantiate all expenditures allocated to grants. For additional information, see the Organization’s separate report for planned corrective actions.

2020-003 – Period of Performance Significant Deficiency in Internal Controls Over Compliance and Instances of Noncompliance Assistance Listing Number: 59.046 Federal Agency/Pass-through Entity - Program Name: Small Business Administration - Microloan Program Award Number(s): SBAOCAML200065-01-00 Award Year(s): 2020 Criteria or specific requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.1, Period of Performance is defined as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods." Condition: The Organization allocated three expenditures to Grant Award #SBA OCAML200065-01-00, which were outside the grant's period of performance. Questioned costs: $177 Context: During our audit procedures, we tested the entire population of costs associated with Award #SBAOCAML200065-01-00 and noted three rent payments were charged to the grant totaling $177 that were for months prior to the 07/01/2020-06/30/2021 period of performance. Cause: The Organization did not have internal controls in place to ensure funds were allocated to the correct grant's period of performance. Effect or potential effect: The Organization is out of compliance with Award #SBA OCAML200065-01-00's period of performance. Repeat finding: No Recommendation: The Organization should implement controls to ensure all expenditures allocated to grants are for costs incurred during the specified period of performance. Views of responsible officials: The Organization agrees with the finding and has implemented controls to ensure all expenditures allocated to grants are for costs incurred during the specified period of performance. For additional information, see the Organization’s separate report for planned corrective actions.

2020-004 – Reporting Significant Deficiency in Internal Controls Over Compliance and Instance of Noncompliance Assistance Listing Number: 59.046 Federal Agency/Pass-through Entity - Program Name: Small Business Administration - Microloan Program Award Number(s): SBAHQ19Y0115 Award Year(s): 2019 Criteria or specific requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to 2 CFR 200.329(c)(1) states, "Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period." Condition: The Organization submitted their "Combined MRF & LLRF Status Reports" for the quarter ending June 30, 2020, more than 30 days after the end of the quarter. Questioned costs: None Context: During our audit procedures, we tested two of the four quarterly “Combined MRF & LLRF Status Reports” and noted that the report for the period ending June 30, 2020, was submitted on October 13, 2020, which is 106 calendar days after period-end. The report is due 30 days after the period ends. Cause: The Organization did not have internal controls in place to ensure the “Combined MRF & LLRF Status Reports” were being filed within 30 calendar days of period end. Effect or potential effect: The Organization is out of compliance with 2 CFR 200.329(c)(1). Repeat finding: No Recommendation: The Organization should implement controls to ensure all reporting, both financial and performance, is completed, reviewed, and submitted before the specific report deadlines. Views of responsible officials: The Organization agrees with the finding and has implemented controls to ensure all reports are completed, reviewed, and submitted by specific report deadlines. For additional information, see the Organization’s separate report for planned corrective actions.

2019-002: U.S. Small Business Administration CFDA #59.046, Microloan Program Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria - The Code of Federal Regulations CFR 200.514(c) governing eligibility of federal funds and further, CFR 200.514(d) states that the auditor perform procedures to determine whether the non-Federal entity has complied with laws, regulations, and the provisions of the Federal award that could have a direct and material effect on each major program. Per the loan agreements under the program, the entity is required: (a) To make microloans to small business concerns pursuant to Section 7(m) of the Small Business Act; Title 13 of the Code of Federal Regulations, Parts 112, 113, 117, 120 and 121; and pertinent SBA Program Announcements. (b) Make microloans only in those geographic areas for which you are approved. (c) Maintain all documents required to record and secure the loan, which include; 1. A signed loan agreement with the entity and recipient and 2. A letter from a bank demonstrating that the applicant possesses a need for credit when the disbursement will be in excess of $20,000. Condition - We reviewed the eligibility of four loan applicants and determined two of the four loan files that were tested had information omitted from the files. The first loan folder lacked a signed loan application from the applicant, and the other loan folder lacked a letter from the bank stating that the applicant demonstrated a need for credit as the loan was greater than $20,000. Cause - WWBC did not have adequate written policies and procedures in place to ensure that proper documentation was maintained in files in accordance with the guidelines provided in the loan agreements. Effect or Potential Effect ? WWBC could make a microloan under the program to a small business that does not meet the eligibility requirements under this program. Questioned Costs ? None noted. Context ? We examined the eligibility of four loan applicants and determined two of the four loan files that were tested had information omitted from the files. The first loan folder lacked a signed loan application from the applicant, and the other loan folder lacked a letter from the bank stating that the applicant demonstrated a need for credit as the loan was greater than $20,000. Repeat Finding - This is a not a repeat finding from prior year. Recommendation - We recommend that WWBC comply with the requirements of CFR 200.514(c) and the loan agreements under this program to have written procedures in place that ensure proper documentation is maintained in each loan folder. Views of Responsible Officials ? Management will put written procedures into place to ensure all eligibility requirements are met in regard to record keeping so that WWBC is in compliance with the requirements of CFR 200.514(c) and the loan agreements under this program.