New Mexico Community Development Loan Fund, Inc.

Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of suspension and debarment. The Loan Fund should have internal controls designed to ensure compliance with this provision. 2 CFR 200.318-200.321 outline requirements to maintain records sufficient to detail the history of procurement, requirements for competition, methods and purchasing thresholds, as well as other requirements for contracting with organizations with using federal funds. The Loan Fund?s policies do not meet these requirements. Condition: During our testing, we noted that the Loan Fund internal controls and accounting policies were not sufficient in regard to federal requirements for procurements and for ensuring vendors and contractors used are not suspended or debarred. Questioned costs: None. The Loan Fund did not enter into any contracts with disallowed parties, and there were no issues with mircopurchases tested. The Loan Fund policies and procedures do not contain necessary controls to ensure compliance with the requirements for suspension and debarment or procurements. As such, they were not sufficient to ensure material compliance with this compliance requirement. Context: See Condition. Cause: Lack of established controls and procedures over requirements for procurements and federal principals for suspension and debarment. Effect: Possible noncompliance with federal requirements for procurements using federal monies. Possibility to enter into a covered transaction with a noneligible contractor or vendor. Recommendation: We recommend that the Loan Fund reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Views of responsible officials: There is no disagreement with the audit finding. Management accepts this finding and has made efforts to review and update our policies to meet federal cost principals and requirements. These are currently pending approval by the Board of Directors for implementation.

Criteria or specific requirement: According to ?200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing, we noted that the Loan Fund?s internal controls were not sufficient in order to prevent miscalculation of allowable payroll costs. Questioned costs: $388 Context: During our testing, 1 of the 45 tested payroll disbursements was incorrectly calculated. The total hours per the timesheet did not agree to the amount used for payment. The overall hours per timesheet were 4 hours less than the amount paid on check. Cause: Error that was not identified by established controls and procedures over allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Recommendation: We recommend that NMLF ensure that approvals of timesheets are correct in order to ensure compliance with federal allowable cost principals. Views of responsible officials: There is no disagreement with the audit finding. Management accepts this finding and has made efforts to review and update our policies and procedures to prevent future noncompliance with federal cost principals and requirements.

Criteria or specific requirement: Per ?200.309 Period of Performance, a non-federal entity may charge to the Federal Award only allowable costs incurred during the period of performance. Condition: During our testing, we noted the Loan Fund did not comply with the period of performance requirements. Questioned costs: $4,377 Context: We noted during out testing over allowable costs that 3 of the 45 tested payroll disbursements were for a pay period before the start of the period of performance. Cause: Lack of established controls and procedures over period of performance and allowable costs principals. Effect: Possible noncompliance with federal cost principals or grant requirements. Recommendation: We recommend that the Loan Fund reviews the period of performance for grants when applying expenditures to the grant. Views of responsible officials: There is no disagreement with the audit finding. Management accepts this finding and has made efforts to review and update our policies and procedures to prevent future noncompliance with federal cost principals and period of performance requirements.