EIN: 223880639
UEI: NSLQZJAHYMM5
Audited by: KCoe Isom, LLP
Oversight agency: 11 [Department of Commerce]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 27, 2026 (25 days from today).
What is a management decision? →FAC accepted this audit on December 30, 2024 — management decision was due June 30, 2025.
Late Submission of Form ED-209 Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Audit Requirements Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria Per the CARES Act Revolving Loan Fund Standard Terms and Conditions, the Form ED-209 must be submitted within 30 days after the reporting period ending June 30, 2024. Condition The Organization did not submit Form ED-209 within the required timeframe. The initial submission occurred on September 25, 2024, which was after the 30-day deadline. Furthermore, errors identified at the federal level necessitated a resubmission of the form. The final submission was completed on October 18, 2024, resulting in a delayed submission beyond the allowable period. Cause The oversight occurred due to inadequate internal controls in reviewing the Form ED-209. Subsequent errors identified by federal reviewers required corrections, further extending the submission timeline. Effect Late submission of required federal reports constitutes noncompliance with federal reporting requirements. This may result in increased scrutiny from federal agencies, potential penalties, or impacts on future funding and grant opportunities. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization implement stricter internal controls and monitoring procedures to ensure all federal reports, including Form ED-209, are prepared accurately and submitted within the required deadlines. Additionally, a review process should be established to promptly address and correct any errors identified by federal agencies to prevent further delays. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Show full finding ▾Hide full finding ▴Late Submission of Form ED-209 Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Audit Requirements Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria Per the CARES Act Revolving Loan Fund Standard Terms and Conditions, the Form ED-209 must be submitted within 30 days after the reporting period ending June 30, 2024. Condition The Organization did not submit Form ED-209 within the required timeframe. The initial submission occurred on September 25, 2024, which was after the 30-day deadline. Furthermore, errors identified at the federal level necessitated a resubmission of the form. The final submission was completed on October 18, 2024, resulting in a delayed submission beyond the allowable period. Cause The oversight occurred due to inadequate internal controls in reviewing the Form ED-209. Subsequent errors identified by federal reviewers required corrections, further extending the submission timeline. Effect Late submission of required federal reports constitutes noncompliance with federal reporting requirements. This may result in increased scrutiny from federal agencies, potential penalties, or impacts on future funding and grant opportunities. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization implement stricter internal controls and monitoring procedures to ensure all federal reports, including Form ED-209, are prepared accurately and submitted within the required deadlines. Additionally, a review process should be established to promptly address and correct any errors identified by federal agencies to prevent further delays. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Late Submission of Form ED-209 Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not submit Form ED-209 within the required timeframe. The initial submission occurred on September 25, 2024, which was after the 30-day deadline. Errors were identified which required correction and resubmission of the form. The final submission was completed on October 18, 2024, which was after the deadline. Planned Corrective Actions: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director will implement stricter internal controls and monitoring procedures to ensure all federal reports, including Form ED-209, are prepared accurately and submitted within the required deadlines. A review process will be added to the monitoring procedures to promptly address and correct any errors identified by federal agencies. Timeline for Completion: BSEDC will implement the internal controls and monitoring procedures with the next reporting that is due secondary review process in October 2024 with the completion and submission of the FY24 annual report to Federal EDA. Responsible Person or Party: BSEDC’s Senior Director of Finance is responsible for implementing the corrective action. Responsible Person or Party: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director are both responsible for ensuring that the secondary review is complete before submitting reporting to Federal EDA.
Noncompliance with Davis-Bacon Wage Requirements Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency Category of Finding: Special Tests and Provisions – Davis-Bacon Act Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria In accordance with section 602 of PWEDA (42 U.S.C. § 3212), all laborers and mechanics employed by contractors or subcontractors on construction-related projects receiving investment assistance under PWEDA shall be paid wages not less than those prevailing on similar construction in the locality, as determined by the U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, United States Code. See 13 CFR § 302.13. Condition During the fiscal year ended June 30, 2024, the Organization did not disburse any loans that were subject to Davis-Bacon wage requirements. However, we noted there are no internal controls in place to verify compliance with prevailing wage rates in the event that such loans are disbursed in the future. Cause There are no controls in place to verify compliance with prevailing wage rates for federally funded projects, risking legal and financial penalties due to potential noncompliance with federal wage laws. Effect Without proper controls, the Organization risks noncompliance with federal wage laws if loans subject to Davis-Bacon requirements are disbursed. This could lead to legal and financial penalties, including potential repayment of federal funds or jeopardizing future funding opportunities. Repeat Finding This is a repeat finding from the prior year. Recommendation We recommend that the Organization implement procedures to ensure compliance with Davis-Bacon wage requirements. This includes training staff on federal wage laws, incorporating compliance checks into the loan disbursement process, and regularly monitoring contractor adherence to prevailing wage rates. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Show full finding ▾Hide full finding ▴Noncompliance with Davis-Bacon Wage Requirements Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency Category of Finding: Special Tests and Provisions – Davis-Bacon Act Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria In accordance with section 602 of PWEDA (42 U.S.C. § 3212), all laborers and mechanics employed by contractors or subcontractors on construction-related projects receiving investment assistance under PWEDA shall be paid wages not less than those prevailing on similar construction in the locality, as determined by the U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, United States Code. See 13 CFR § 302.13. Condition During the fiscal year ended June 30, 2024, the Organization did not disburse any loans that were subject to Davis-Bacon wage requirements. However, we noted there are no internal controls in place to verify compliance with prevailing wage rates in the event that such loans are disbursed in the future. Cause There are no controls in place to verify compliance with prevailing wage rates for federally funded projects, risking legal and financial penalties due to potential noncompliance with federal wage laws. Effect Without proper controls, the Organization risks noncompliance with federal wage laws if loans subject to Davis-Bacon requirements are disbursed. This could lead to legal and financial penalties, including potential repayment of federal funds or jeopardizing future funding opportunities. Repeat Finding This is a repeat finding from the prior year. Recommendation We recommend that the Organization implement procedures to ensure compliance with Davis-Bacon wage requirements. This includes training staff on federal wage laws, incorporating compliance checks into the loan disbursement process, and regularly monitoring contractor adherence to prevailing wage rates. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Noncompliance with Davis-Bacon Wage Requirements Description of the Finding: BSEDC does not have internal controls in place to verify compliance with prevailing wage rates in the event that such loans are disbursed. Planned Corrective Actions: BSEDC’s Director of Business Finance/Program Finance Director has amended the organization’s EDA-RLF Plan, including details on the Davis-Bacon requirements for any loan funding construction or renovations of more than $2,000. It will be the responsibility of Big Sky Finance to notify the borrower as soon as possible regarding the Davis-Bacon requirements for wages paid. The borrower will in turn notify their contractor of the requirement. Big Sky Finance will require evidence from the general contractor of the prevailing wages being paid prior to loan funds being disbursed. Timeline for Completion: The Davis-Bacon requirement for funds disbursed through BSEDC’s Federal EDARLF loan fund will be immediately implemented for all EDA-RLF loans funded going forward. BSEDC’s EDARLF Plan will be amended and approved by its Board of Directors within a reasonable amount of time. A draft of this change is in place. However, as a matter of practice, Davis-Bacon requirements will be adhered to from this date forward. Responsible Person or Party: BSEDC’s Director of Business Finance/Program Finance Director, will be responsible for making the changes to the plan, presenting to the Board and adhering to the plan going forward.
2023-003
FAC accepted this audit on December 30, 2024 — management decision was due June 30, 2025.
Compliance with Single Audit Requirements Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Audit Requirements Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria According to the Uniform Guidance (2 CFR Part 200.501), non-federal entities that expend $750,000 or more in federal awards during their fiscal year are required to have a single audit conducted. The audit report must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (2 CFR Part 200.512). Condition The Organization did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the prescribed due dates. This oversight necessitated the reissuance of the FY23 financial statement audit to complete and issue a single audit. Cause The oversight occurred due to inadequate internal controls, a lack of understanding of federal expenditure calculation for the loan program, and turnover in the Finance Director’s role. The transition in finance leadership led to an isolated weakness in the Organization’s control process as it relates to the management of this federal award. Management did not apply the appropriate methodology for calculating federal expenditures related to the revolving loan fund for reporting in the Schedule of Federal Expenditures. There was also insufficient oversight and review processes to detect and correct the error in a timely manner. Effect As a result of the incorrect calculation, the Organization did not engage to conduct the required single audit within the stipulated deadlines, leading to noncompliance with federal regulations. Failure to submit the single audit report within the required timeframe increases the risk of noncompliance with federal regulations, which could lead to sanctions, penalties, or the retraction of federal funding. Late submission may also affect the organization's eligibility for future federal awards and could result in increased scrutiny from federal agencies. Repeat Finding This is not a repeat finding. Recommendation We recommend that management implement robust policies and internal control procedures to ensure accurate calculation and reporting of federal expenditures in the Schedule of Federal Expenditures, particularly for complex programs like revolving loan funds. We also recommend an increase in oversight by senior management and the board to ensure that financial reporting and compliance responsibilities are adequately fulfilled. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Show full finding ▾Hide full finding ▴Compliance with Single Audit Requirements Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Audit Requirements Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria According to the Uniform Guidance (2 CFR Part 200.501), non-federal entities that expend $750,000 or more in federal awards during their fiscal year are required to have a single audit conducted. The audit report must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (2 CFR Part 200.512). Condition The Organization did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the prescribed due dates. This oversight necessitated the reissuance of the FY23 financial statement audit to complete and issue a single audit. Cause The oversight occurred due to inadequate internal controls, a lack of understanding of federal expenditure calculation for the loan program, and turnover in the Finance Director’s role. The transition in finance leadership led to an isolated weakness in the Organization’s control process as it relates to the management of this federal award. Management did not apply the appropriate methodology for calculating federal expenditures related to the revolving loan fund for reporting in the Schedule of Federal Expenditures. There was also insufficient oversight and review processes to detect and correct the error in a timely manner. Effect As a result of the incorrect calculation, the Organization did not engage to conduct the required single audit within the stipulated deadlines, leading to noncompliance with federal regulations. Failure to submit the single audit report within the required timeframe increases the risk of noncompliance with federal regulations, which could lead to sanctions, penalties, or the retraction of federal funding. Late submission may also affect the organization's eligibility for future federal awards and could result in increased scrutiny from federal agencies. Repeat Finding This is not a repeat finding. Recommendation We recommend that management implement robust policies and internal control procedures to ensure accurate calculation and reporting of federal expenditures in the Schedule of Federal Expenditures, particularly for complex programs like revolving loan funds. We also recommend an increase in oversight by senior management and the board to ensure that financial reporting and compliance responsibilities are adequately fulfilled. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Finding No. 2023-001: Compliance with Single Audit Requirements Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the prescribed due dates. This oversight necessitated the reissuance of the FY23 financial statement audit to complete and issue a single audit. Planned Corrective Actions: BSEDC’s Senior Director of Finance engaged with an independent auditor to complete the single audit for FY23 and re-issue the financial statement audit which was missed during the performance of the FY23 financial statement audit due to the Senior Director of Finance and the parties they engaged to perform the audit not having a clear understanding of the calculation for federal expenditures for the federal revolving loan fund. The Senior Director of Finance now has a clear understanding of the requirements for the calculation and reporting of federal expenditures in the Schedule Expenditures of Federal Awards as it relates to the federal revolving laon fund. Timeline for Completion: BSEDC engaged with an independent auditor to complete the single audit for FY23 and reissue the FY23 financial statement audit in June 2024. Expected completion is November 2024. Responsible Person or Party: BSEDC’s Senior Director of Finance is responsible for implementing the corrective action.
Financial Reporting and Review Processes Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Reporting Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria Per the Uniform Guidance (2 CFR Part 200.303), non-federal entities must establish and maintain effective internal control over the federal award to provide reasonable assurance that they are managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per the Uniform Guidance (2 CFR Part 200.307), program income means gross income earned by the non-federal entity that is directly generated by a supported activity or earned as a result of the federal award during the period of performance. Additionally, the Form ED-209 Instructions specify that loan origination fee income and interest income must be included in the appropriate line items when completing the ED-209 report. Condition The Program Finance Director creates the financial report using information from the Senior Director of Finance. Once completed, the report is sent to directly to the Federal EDA without further review, except by their main contact at the Federal EDA. Additionally, the compliance test over the ED-209 report revealed that the Organization is consistently omitting loan origination fee income and interest income from federal program income calculations, with a discrepancy of $3,614 identified. Cause The lack of a secondary review process allowed errors and omissions to go undetected. There was a misunderstanding regarding what constitutes program income under federal guidelines, leading to the exclusion of certain income sources from reports. Effect Potential inaccuracies and errors in financial reporting could lead to misrepresentation of the Organization's financial position and noncompliance with federal regulations. This could result in financial penalties, increased scrutiny from federal agencies, or impacts on future funding eligibility. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization establish a formal review process for financial reports before submission to federal agencies. This should include verification of all income sources that qualify as program income under federal guidelines. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Show full finding ▾Hide full finding ▴Financial Reporting and Review Processes Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Reporting Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria Per the Uniform Guidance (2 CFR Part 200.303), non-federal entities must establish and maintain effective internal control over the federal award to provide reasonable assurance that they are managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per the Uniform Guidance (2 CFR Part 200.307), program income means gross income earned by the non-federal entity that is directly generated by a supported activity or earned as a result of the federal award during the period of performance. Additionally, the Form ED-209 Instructions specify that loan origination fee income and interest income must be included in the appropriate line items when completing the ED-209 report. Condition The Program Finance Director creates the financial report using information from the Senior Director of Finance. Once completed, the report is sent to directly to the Federal EDA without further review, except by their main contact at the Federal EDA. Additionally, the compliance test over the ED-209 report revealed that the Organization is consistently omitting loan origination fee income and interest income from federal program income calculations, with a discrepancy of $3,614 identified. Cause The lack of a secondary review process allowed errors and omissions to go undetected. There was a misunderstanding regarding what constitutes program income under federal guidelines, leading to the exclusion of certain income sources from reports. Effect Potential inaccuracies and errors in financial reporting could lead to misrepresentation of the Organization's financial position and noncompliance with federal regulations. This could result in financial penalties, increased scrutiny from federal agencies, or impacts on future funding eligibility. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization establish a formal review process for financial reports before submission to federal agencies. This should include verification of all income sources that qualify as program income under federal guidelines. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Financial Reporting and Review Process Description of the Finding: BSEDC did not have a secondary review process over the required financial reporting to Federal EDA. The lack of a secondary review process allowed for errors and omissions to go undetected, thus resulting in omission of $3,614 of loan origination fee income and interest income from federal program income calculations. Planned Corrective Actions: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director have implemented processes for the Senior Director of Finance to perform a secondary review of the required reporting to Federal EDA before it is submitted. Timeline for Completion: BSEDC implemented the secondary review process in October 2024 with the completion and submission of the FY24 annual report to Federal EDA. Responsible Person or Party: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director are both responsible for ensuring that the secondary review is complete before submitting reporting to Federal EDA.
Noncompliance with Davis-Bacon Wage Requirements Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Special Tests and Provisions – Davis-Bacon Act Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria In accordance with section 602 of PWEDA (42 U.S.C. § 3212), all laborers and mechanics employed by contractors or subcontractors on construction-related projects receiving investment assistance under PWEDA shall be paid wages not less than those prevailing on similar construction in the locality, as determined by the U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, United States Code. See 13 CFR § 302.13. Condition The Organization failed to comply with Davis-Bacon wage requirements for a loan disbursed to one entity due to a lack of awareness of Davis-Bacon wage requirements. Cause There are no controls in place to verify compliance with prevailing wage rates for federally funded projects, risking legal and financial penalties due to potential noncompliance with federal wage laws. Effect Noncompliance in prevailing wages rates for federally funded projects, risking legal and financial penalties. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization implement procedures to ensure compliance with Davis-Bacon wage requirements. This includes training staff on federal wage laws, incorporating compliance checks into the loan disbursement process, and regularly monitoring contractor adherence to prevailing wage rates. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Show full finding ▾Hide full finding ▴Noncompliance with Davis-Bacon Wage Requirements Assistance Title: COVID-19 - Economic Adjustment Assistance - Coronavirus Aid, Relief, and Economic Security (CARES) Act Revolving Loan Fund Assistance Listing Number: 11.307 Federal Agency: U.S. Department of Commerce Type of Finding: Significant Deficiency and Noncompliance Category of Finding: Special Tests and Provisions – Davis-Bacon Act Known Questioned Costs: $0 Likely Questioned Costs: $0 Criteria In accordance with section 602 of PWEDA (42 U.S.C. § 3212), all laborers and mechanics employed by contractors or subcontractors on construction-related projects receiving investment assistance under PWEDA shall be paid wages not less than those prevailing on similar construction in the locality, as determined by the U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, United States Code. See 13 CFR § 302.13. Condition The Organization failed to comply with Davis-Bacon wage requirements for a loan disbursed to one entity due to a lack of awareness of Davis-Bacon wage requirements. Cause There are no controls in place to verify compliance with prevailing wage rates for federally funded projects, risking legal and financial penalties due to potential noncompliance with federal wage laws. Effect Noncompliance in prevailing wages rates for federally funded projects, risking legal and financial penalties. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Organization implement procedures to ensure compliance with Davis-Bacon wage requirements. This includes training staff on federal wage laws, incorporating compliance checks into the loan disbursement process, and regularly monitoring contractor adherence to prevailing wage rates. Management’s Response Management concurs with this finding. See Management’s Response and Corrective Action plan section.
Noncompliance with Davis-Bacon Wage Requirements Description of the Finding: BSEDC failed to comply with Davis-Bacon wage requirements for a loan disbursed to one entity due to a lack of awareness of Davis-Bacon wage requirements. Davis-Bacon wages are a requirement of the Federal EDA and apply to any Federal funds to ensure the prevailing wage is paid to workers on federally funded construction-related projects. The regulations apply to any loans that are used to fund directly or indirectly projects that cost over $2,000 involving construction and/or renovation. BSEDC received a grant from the U.S. Federal EDA in April 2021. BSEDC drafted an EDA-RLF Plan that was approved by the Federal EDA and BSEDC’s Board of Directors. Within the plan was a section on Environmental Issues and Davis Bacon. Within this section of the Plan, there was discussion and direction pertaining to Environmental Issues, but nothing pertaining to Davis-Bacon. Therefore, BSEDC’s Director of Business Finance/Program Finance Director was unaware of the specific requirements related to Davis-Bacon wages and construction/renovation projects funded by the EDA-RLF loans. Not having had any experience with this, it was thought Davis-Bacon requirements only applied to financing of public projects, and not to any project funded by Federal funds. The Director of Business Finance/Program Finance Director and BSEDC’s Senior Director of Finance are now aware of, and better educated on, the Davis-Bacon requirements. The specific cause of Big Sky Finance not requiring Davis-Bacon wages on its initial loans that fit the criteria was solely based on the Director of Business Finance/Program Finance Director’s lack of knowledge of this requirement, or any previous experience having had worked with Federal loan construction projects. Planned Corrective Actions: BSEDC’s Director of Business Finance/Program Finance Director has amended the organization’s EDA-RLF Plan, including details on the Davis-Bacon requirements for any loan funding construction or renovations of more than $2,000. It will be the responsibility of Big Sky Finance to notify the borrower as soon as possible regarding the Davis-Bacon requirements for wages paid. The borrower will in turn notify their contractor of the requirement. Big Sky Finance will require evidence from the general contractor of the prevailing wages being paid prior to loan funds being disbursed. Timeline for Completion: The Davis-Bacon requirement for funds disbursed through BSEDC’s Federal EDARLF loan fund will be immediately implemented for all EDA-RLF loans funded going forward. BSEDC’s EDARLF Plan will be amended and approved by its Board of Directors within a reasonable amount of time. A draft of this change is in place. However, as a matter of practice, Davis-Bacon requirements will be adhered to from this date forward. Responsible Person or Party: BSEDC’s Director of Business Finance/Program Finance Director, will be responsible for making the changes to the plan, presenting to the Board and adhering to the plan going forward.
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