EIN: 440618839
UEI: K7HDPXZ7EAC1
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 20, 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 July 20, 2026 (45 days ago).
What is a management decision? →FAC accepted this audit on October 22, 2024 — management decision was due April 22, 2025.
FAC accepted this audit on November 14, 2023 — management decision was due May 14, 2024.
The Seminary did not sufficiently comply with all the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has put forth significant effort towards GLBA compliance. The remaining areas are on the Seminary’s road map to codify and document or approve exceptions. • Update the written information security program to address all updated areas from the 2023 legislation change including safeguards specified in the legislation. • Implement multi-factor authentication on all systems containing personally identifiable information (PII) or approve in writing qualified exceptions. • Provide a written, annual report to the board covering all areas of GLBA. Cause: The Seminary has been working through legacy systems and exploring options that are feasible to implement and maintain appropriate security posture. Effect: The Seminary has additional documentation to perform to ensure all updated components are addressed and any residual risk is approved by the board. This will reduce unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the Seminary allocate sufficient resources to document and/or implement all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with all the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has put forth significant effort towards GLBA compliance. The remaining areas are on the Seminary’s road map to codify and document or approve exceptions. • Update the written information security program to address all updated areas from the 2023 legislation change including safeguards specified in the legislation. • Implement multi-factor authentication on all systems containing personally identifiable information (PII) or approve in writing qualified exceptions. • Provide a written, annual report to the board covering all areas of GLBA. Cause: The Seminary has been working through legacy systems and exploring options that are feasible to implement and maintain appropriate security posture. Effect: The Seminary has additional documentation to perform to ensure all updated components are addressed and any residual risk is approved by the board. This will reduce unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the Seminary allocate sufficient resources to document and/or implement all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: To be in full compliance with all the elements of the GLBA update that became effective on June 9, 2023, the Seminary will do the following: • Update the written information security program to address all updated areas from the 2023 legislation change including safeguards specified in the legislation. • Implement multi-factor authentication on all systems containing personally identifiable information (PII) or approve in writing qualified exceptions. • Provide a written, annual report to the board covering all areas of GLBA. Person Responsible for Corrective Action Plan: Steve Stone, Director of Information Technology Anticipated Date of Completion: December 31, 2023
FAC accepted this audit on November 2, 2022 — management decision was due May 2, 2023.
FAC accepted this audit on December 1, 2021 — management decision was due June 1, 2022.
FAC accepted this audit on December 1, 2020 — management decision was due June 1, 2021.
Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268 and 84.063 Federal Direct Student Loans - Award Year 2020 Federal Pell Grant Program - Award Year 2020 Criteria or Specific Requirement - Special Tests & Provisions: Enrollment Reporting (34 CFR 690.83, 34 CFR 685.309) Federal regulations state that under the Pell grant and Direct and FFEL loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) Condition ? Enrollment information was not submitted within the required timeframe. Context - Out of a population of 6 Enrollment Reporting roster files during the year, 5 were returned within the 15 day reporting requirement. One of the roster files was retuned in 45 days, which is not in compliance to the 15 day requirement. Questioned Costs ? None noted. Effect ? Any student enrollment changes in that time period may not have been reported timely. Cause ? During the summer months, the Seminary adopted a practice of returning the roster file every two months due to an oversight. Identification as a Repeat Finding ? Not applicable. Recommendation ? The Seminary should establish monitoring procedures to ensure that all Enrollment Reporting roster files are returned within 15 days.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster U.S. Department of Education CFDA Nos. 84.268 and 84.063 Federal Direct Student Loans - Award Year 2020 Federal Pell Grant Program - Award Year 2020 Criteria or Specific Requirement - Special Tests & Provisions: Enrollment Reporting (34 CFR 690.83, 34 CFR 685.309) Federal regulations state that under the Pell grant and Direct and FFEL loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) Condition ? Enrollment information was not submitted within the required timeframe. Context - Out of a population of 6 Enrollment Reporting roster files during the year, 5 were returned within the 15 day reporting requirement. One of the roster files was retuned in 45 days, which is not in compliance to the 15 day requirement. Questioned Costs ? None noted. Effect ? Any student enrollment changes in that time period may not have been reported timely. Cause ? During the summer months, the Seminary adopted a practice of returning the roster file every two months due to an oversight. Identification as a Repeat Finding ? Not applicable. Recommendation ? The Seminary should establish monitoring procedures to ensure that all Enrollment Reporting roster files are returned within 15 days.
Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and has established the following corrective action plan. Effective October 15, 2020, management intends to alter its summer enrollment reporting in future years in order to comply with the 15-day requirement that the NSLDS sends a roster file to the school.
FAC accepted this audit on November 10, 2019 — management decision was due May 10, 2020.
FAC accepted this audit on October 25, 2018 — management decision was due April 25, 2019.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 1, 2017 — management decision was due May 1, 2018.
FAC accepted this audit on November 15, 2016 — management decision was due May 15, 2017.
GSA_MIGRATION
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