EIN: 951699394
UEI: EA7CJXDYNU51
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 16, 2025. 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 June 16, 2026 (74 days ago).
What is a management decision? →FAC accepted this audit on November 4, 2024 — management decision was due May 4, 2025.
FAC accepted this audit on November 7, 2023 — management decision was due May 7, 2024.
The Seminary did not sufficiently comply with a couple of components of the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has certain policies in the safeguards and vendor sections of GLBA have not been fully documented. Cause: The Seminary made significant progress to address and document compliance with the updated requirements of GLBA and has a few areas left to complete. Effect: The Seminary may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the Seminary for significant work completed on GLBA. We recommend the Seminary complete documentation of the known policies and procedures related to safeguards and vendors be included in the information security program. 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, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with a couple of components of the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has certain policies in the safeguards and vendor sections of GLBA have not been fully documented. Cause: The Seminary made significant progress to address and document compliance with the updated requirements of GLBA and has a few areas left to complete. Effect: The Seminary may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the Seminary for significant work completed on GLBA. We recommend the Seminary complete documentation of the known policies and procedures related to safeguards and vendors be included in the information security program. 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: We are thankful for the recognition of the significant work that has been done to comply with GLBA and protect the PII of Fuller's students. In response to these findings Fuller will, by December of 2023, complete the following documentation of known policies and procedures: 1. Create a monthly calendar of information security that documents the information security activities undertaken each month. 2. Document Fuller's review of vendor SOC reports and contract language. Person Responsible for Corrective Action Plan: Jeff Harwell, Chief Technology Officer Anticipated Date of Completion: 12/31/2023
FAC accepted this audit on October 30, 2022 — management decision was due April 30, 2023.
FAC accepted this audit on January 19, 2022 — management decision was due July 19, 2022.
The Seminary did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) institutional and student portions expended. Criteria: 86 FR 26213 The Seminary was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the Seminary is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that while the Seminary had appropriately disclosed the required CARES Act reporting for HEERF funds and the CRRSAA Institutional Quarterly report and the CRRSAA student emergency grant disbursement report for the quarter ending June 30, 2021, were not completed and disclosed on their website. The Seminary corrected and reports were posted to the website before the audit was finalized. Cause: There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The Seminary was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the Seminary complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund Reporting Other Matter DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Education Stabilization Fund Federal Award Identification #: P425E202245 and P425F204958 Condition: The Seminary did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) institutional and student portions expended. Criteria: 86 FR 26213 The Seminary was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the Seminary is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that while the Seminary had appropriately disclosed the required CARES Act reporting for HEERF funds and the CRRSAA Institutional Quarterly report and the CRRSAA student emergency grant disbursement report for the quarter ending June 30, 2021, were not completed and disclosed on their website. The Seminary corrected and reports were posted to the website before the audit was finalized. Cause: There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The Seminary was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the Seminary complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-001 Higher Education Stabilization Fund Reporting Planned Corrective Action: The Finance department is working closely with Student Financial Services to ensure all reporting is completed and reported on time. Every quarter, the Finance Department will prepare the report. Two weeks prior to due date, Student Financial Services will review and sign off. The Finance Department will then post the report by the designated due date. Person Responsible for Corrective Action Plan: Paula Tkach, Controller and Theresa Cowan, Director of Student Financial Services Anticipated Date of Completion: December 2021
FAC accepted this audit on December 15, 2020 — management decision was due June 15, 2021.
The Organization did not return unearned Title IV funds within the 45 days from the determination of the student?s withdrawal. Criteria: 34 CFR 668.22(j), 34 CFR 668.173(c)(1) Questioned Costs: $0 Context: Out of 13 withdrawals tested (both official and unofficial), 9 students did not have funds returned timely. The financial aid director subsequently did a complete review of all 32 withdrawals (both official and unofficial) and determined that a total of 30 were late (9 of which noted in our sample), ranging from 58 to 218 days. Effect: Title IV funds are not being returned timely in accordance with the regulations to the Department of Education when students withdraw. Cause: There were multiple factors that led to the late returns. The financial aid office experienced a significant amount of turnover, and as a result, there was only one person in the office with the knowledge of the Return of Title IV process. Additionally, on some occasions, the registrar did not notify the financial aid office of a withdrawal in a timely manner. Identification as repeat finding, if applicable: Yes, see 2019-001 and 2018-001. Recommendation: We recommend the Seminary implement a procedure for reviewing all withdrawals at the end of each quarter to ensure unearned funds are returned timely. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Show full finding ▾Hide full finding ▴2020-001 Late Returns of Title IV Funds Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, Federal Direct Loans Federal Award Identification #: 19-20 Award Year Condition: The Organization did not return unearned Title IV funds within the 45 days from the determination of the student?s withdrawal. Criteria: 34 CFR 668.22(j), 34 CFR 668.173(c)(1) Questioned Costs: $0 Context: Out of 13 withdrawals tested (both official and unofficial), 9 students did not have funds returned timely. The financial aid director subsequently did a complete review of all 32 withdrawals (both official and unofficial) and determined that a total of 30 were late (9 of which noted in our sample), ranging from 58 to 218 days. Effect: Title IV funds are not being returned timely in accordance with the regulations to the Department of Education when students withdraw. Cause: There were multiple factors that led to the late returns. The financial aid office experienced a significant amount of turnover, and as a result, there was only one person in the office with the knowledge of the Return of Title IV process. Additionally, on some occasions, the registrar did not notify the financial aid office of a withdrawal in a timely manner. Identification as repeat finding, if applicable: Yes, see 2019-001 and 2018-001. Recommendation: We recommend the Seminary implement a procedure for reviewing all withdrawals at the end of each quarter to ensure unearned funds are returned timely. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Finding Number: 2020-001 Late Returns of Title IV Funds Material Weakness Planned Corrective Action: The student financial services department has undergone significant transition over the past couple of years. The SFS department has been gathering additional guidance and resources in order to train new staff, as well as implementing procedures to be notified at the appropriate times by other departments. Person Responsible for Corrective Action Plan: Theresa Cowan, Student Financial Aid Director Anticipated Date of Completion: Fall 2020
2019-001
The Organization did not always report enrollment status to NSLDS accurately for withdrawn students. Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: Out of 13 withdrawals tested (both official and unofficial), 1 was reported as half time instead of withdrawn, and one was reported as withdrawn at the end of the semester instead of the date of their withdrawal, which was approximately two months different. This results in extra deferment for these students. Effect: Inaccurate reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. The one student noted in the audit process was corrected by the Seminary. Cause: NSLDS was not properly updated for students who withdrew. Identification as repeat finding, if applicable: Yes, see 2019-002, 2018-002 and 2017-001. Recommendation: We recommend the registrar work with student financial aid personnel to update NSLDS to show accurate reporting of the student?s withdrawn status. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Show full finding ▾Hide full finding ▴2020-002 NSLDS Enrollment Reporting Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, Federal Direct Loans Federal Award Identification #: 19-20 Award Year Condition: The Organization did not always report enrollment status to NSLDS accurately for withdrawn students. Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: Out of 13 withdrawals tested (both official and unofficial), 1 was reported as half time instead of withdrawn, and one was reported as withdrawn at the end of the semester instead of the date of their withdrawal, which was approximately two months different. This results in extra deferment for these students. Effect: Inaccurate reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. The one student noted in the audit process was corrected by the Seminary. Cause: NSLDS was not properly updated for students who withdrew. Identification as repeat finding, if applicable: Yes, see 2019-002, 2018-002 and 2017-001. Recommendation: We recommend the registrar work with student financial aid personnel to update NSLDS to show accurate reporting of the student?s withdrawn status. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Finding Number: 2020-002 NSLDS Enrollment Reporting Significant Deficiency Planned Corrective Action: As there has been significant transition in the student financial services department, the plan for collaboration was not able to be implemented as intended in January 2020. The registrar will collaborate with student financial services to identify the root cause related to enrollment reporting for withdrawn students. A process will then be developed to ensure the appropriate enrollment reporting for withdrawn students is done accurately and timely. Person Responsible for Corrective Action Plan: Stephen Rometti, Registrar Anticipated Date of Completion: Fall 2020
2019-002
FAC accepted this audit on January 19, 2020 — management decision was due July 19, 2020.
The Organization did not return unearned Title IV funds within the 45 days from the determination of the student?s withdrawal. Criteria: 34 CFR 668.22(j), 34 CFR 668.173(c)(1) Questioned Costs: $0 Context: Out of 11 withdrawals tested (both official and unofficial), 7 students did not have funds returned timely. The financial aid director subsequently did a complete review of all 26 withdrawals (both official and unofficial) and determined that a total of 7 were late (the same 7 as noted in our sample), ranging from 55 to 216 days. Effect: Title IV funds are not being returned timely in accordance with the regulations to the Department of Education when students withdraw. Cause: There were multiple factors that led to the late returns. The financial aid office experienced a significant amount of turnover, and as a result, there was only one person in the office with the knowledge of the Return of Title IV process. Additionally, on some occasions, the registrar did not notify the financial aid office of a withdrawal in a timely manner. Identification as repeat finding, if applicable: Yes, see 2018-001. Recommendation: We recommend the Organization implement a procedure for reviewing all withdrawals at the end of each quarter to ensure unearned funds are returned timely. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Show full finding ▾Hide full finding ▴2019-001 Late Returns of Title IV Funds Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.033, and 84.038 (Student Financial Assistance Cluster) Federal Award Identification #: 18-19 Award Year Condition: The Organization did not return unearned Title IV funds within the 45 days from the determination of the student?s withdrawal. Criteria: 34 CFR 668.22(j), 34 CFR 668.173(c)(1) Questioned Costs: $0 Context: Out of 11 withdrawals tested (both official and unofficial), 7 students did not have funds returned timely. The financial aid director subsequently did a complete review of all 26 withdrawals (both official and unofficial) and determined that a total of 7 were late (the same 7 as noted in our sample), ranging from 55 to 216 days. Effect: Title IV funds are not being returned timely in accordance with the regulations to the Department of Education when students withdraw. Cause: There were multiple factors that led to the late returns. The financial aid office experienced a significant amount of turnover, and as a result, there was only one person in the office with the knowledge of the Return of Title IV process. Additionally, on some occasions, the registrar did not notify the financial aid office of a withdrawal in a timely manner. Identification as repeat finding, if applicable: Yes, see 2018-001. Recommendation: We recommend the Organization implement a procedure for reviewing all withdrawals at the end of each quarter to ensure unearned funds are returned timely. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Finding Number: 2019-001 Late Returns of Title IV Funds Reason for Finding and Planned Corrective Action: As of August 5, 2019, Fuller Theological Seminary?s Student Financial Services Department is under new leadership. From our understanding, there were significant reasons for late returns. These include: - Lack of trained permanent staff - Communication breakdown between the new Registrar and SFS in regards to withdrawal dates - Outdated financial aid reports in Banner to track enrollment changes - Lack of oversight/management The new leadership model was designed to include a robust organizational analysis of current financial aid policies and procedures, as the institution was under the same director for over 20 years. This analysis is being conducted by the interim operations manager and is under the supervision of the new acting director. SFS will gather additional guidance/resources from the Department of Education and hire additional support, if required. The seminary is committed to correcting this finding and is working diligently to execute necessary operational changes for the timely return of Title IV funds. This will require collaboration with other departments, creating new policies and procedures, and training financial aid staff. Until new policies and procedures are vetted and established, returns will be assessed on a weekly basis by the acting director and interim operations manager, to ensure timeliness and accuracy. Person Responsible for Corrective Action Plan: Shannon Lewis, Acting Director of Student Financial Services Jennyth Green, Interim Operations Manager of Student Financial Services Anticipated Date of Completion: January 2020
2018-001
The Organization did not always report enrollment status to NSLDS accurately for withdrawn students. Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: Out of 11 withdrawals testing (both official and unofficial), 3 were reported as full time instead of withdrawn. This results in extra deferment for these students. Effect: Inaccurate reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. All 3 students noted in the audit process were corrected by the Organization. Cause: NSLDS was not properly updated for students who withdrew. Identification as repeat finding, if applicable: Yes, see 2018-002 and 2017-001. Recommendation: We recommend the registrar work with student financial aid personnel to update NSLDS to show accurate reporting of the student?s withdrawn status. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Show full finding ▾Hide full finding ▴2019-002 NSLDS Enrollment Reporting Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, Federal Direct Loans Federal Award Identification #: 18-19 Award Year Condition: The Organization did not always report enrollment status to NSLDS accurately for withdrawn students. Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: Out of 11 withdrawals testing (both official and unofficial), 3 were reported as full time instead of withdrawn. This results in extra deferment for these students. Effect: Inaccurate reporting can impact a student?s loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. All 3 students noted in the audit process were corrected by the Organization. Cause: NSLDS was not properly updated for students who withdrew. Identification as repeat finding, if applicable: Yes, see 2018-002 and 2017-001. Recommendation: We recommend the registrar work with student financial aid personnel to update NSLDS to show accurate reporting of the student?s withdrawn status. Views of Responsible Officials: Management is in agreement with the findings and is in the process of correcting the issue.
Finding Number: 2019-002 NSLDS Enrollment Reporting Reason for Finding and Planned Corrective Action: Since 2018, the NSLDS reporting process has undergone significant changes and improvements under the leadership of the new registrar and IT department. The registrar will collaborate with the new student financial services leadership team to identify the source of the enrollment reporting mistakes for withdrawn students. Once the issue is defined, a workflow for reporting students who have withdrawn to NSLDS will be established. The IT registrar advocate for NSLDS reporting is now conducting a remediation process and creating custom scripts to address the issue at hand. Person Responsible for Corrective Action Plan: Registrar, Stephen Rometti Anticipated Date of Completion: January 2020
2018-002
FAC accepted this audit on October 28, 2018 — management decision was due April 28, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-001
FAC accepted this audit on October 29, 2017 — management decision was due April 29, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-001
FAC accepted this audit on November 7, 2016 — management decision was due May 7, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-003
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
