River City Federal Credit UnionNon-Profit

CORRECTIVE ACTION PLAN June 22, 2023 Department of the Treasury - CDFI Fund Grant River City Federal Credit Union respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Doeren Mayhew 305 West Big Beaver Rd., Ste. 200 Troy, MI 48084 Audit period: January 1, 2022- December 31, 2022 The findings from the December 31, 2022, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY CDFI Program - CFDA No. 21.024 Significant Deficiency: See Finding 2022-001. Recommendation: Complete established procedures to identify and track eligible loans deployed during the RRP grant performance period and reconcile the totals to the underlying loan data. Action Taken: Management already has an established process to internally track eligible loans deployed during the RRP grant performance, some of the data compilation is automated and some require manual updating. Management has already replaced manual processes with excel functions like vlookup to reduce errors identified by Doeren. However, management has used this conservative process year after year and is confident with the method based on third party verification from Inclusiv, who reports annual data to the CDFI Fund, and acceptance by the CDFI Fund on an annual basis and by an additional independent 3rd party who reports annual grant requirements to the CDFI fund. Management is also confident that this current process appropriately tracks deployed loans required under the RRP Grant performance based on the sheer volume of loans granted annually. With under $2M in loans needed to satisfy the grant requirement in 2022, the credit union has identified a minimum of $20 million in eligible loans in eligible markets, well above the grant performance requirements. The current process would require a significant error rate of over 80% to fail in meeting grant performance requirement. Management does not agree with Doeren auditors' assessment of noncompliance based on the auditors performing a lin1ited scope, only reviewing 40 of the 3,676 loans funded in 2022. The 1.1% of loan evaluated is in1material and gives a false impression of the true effectiveness of the overall internal control process. With 2 errors identified in the sample of 40, Doreen auditors use this as a basis to recognize a significant deficiency- an evaluation management does not concur with. Doreen's evaluation was based on guidance for control-based auditing that is standard in the industry. Doreen's evaluation was also based on an assessment of the credit union's specific target markets, not in accordance with the grant agreement, which allows financial products in any eligible CDFI market and/or the credit union's approved target market. This generic industry standard assessment fails to consider household size in income evaluations and fails to consider underserved racial groups prevalent in Bexar County and identified as eligible CDFI targeted populations. Management is confident in its internal controls and welcomes the Department of Treasury to review its 2022 loan data and internal process by doing an in-depth analysis on a significant percentage of its total loans to verify internal controls are valid and acceptable to meet the grant performance in any eligible CDFI markets and the credit union's approved target market. If the Department of Treasury has questions regarding this plan, please call Michael Quintanilla, Chief Financial Officer at (210) 225-6866.