### Compliance Audit Guidelines: Submission Requirements & Deadlines ###

1. Session #57 All About Compliance Audits Katrina Turner

2. Regulatory Citations Guarantor: 34 CFR 682.410(b) Lender: 34 CFR 682.305 (c) School as Lender: 34 CFR 682.601(a) Lender Servicer: 34 CFR 682.416(e) Guarantor Servicer: 34 CFR 682.416(e)

3. Governmental or Nonprofit? • Audits must be conducted annually and in accordance with the OMB Circular A-133, Appendix B, Compliance Supplement and 31 U.S.C. 7501.

4. Governmental or Nonprofit? (cont.) • Audits must be submitted 9 months after the end of the entity’s fiscal year to the Federal Audit Clearinghouse. December 30 30

5. Non Governmental or Nonprofit? • Audits must be conducted annually using the audit guide titled “Compliance Audits for Lenders and Lender Servicers Participating in the Federal Family Education Loan Program” prepared by the Office of Inspector General, December 1996.

6. Non Governmental or Nonprofit? (cont.) • Audits must be submitted 6 months after the end of the entity’s fiscal year to the Audit Compliance Resolution Team. June 30

7. Who Is Required to Submit an Audit? • All Guarantors. • Lenders that originate or hold over $5 million in FFEL loans during the fiscal year.

8. Who Is Required to Submit an Audit? (Cont.) • School Lenders that originate or hold over $5 million in FFEL loans for any period ending prior to July 1, 2006. Regulatory guidelines changed requiring school lenders that originate or hold any amount of FFEL loans for any fiscal year beginning on or after July 1, 2006 to submit an audit.

9. Who Is Required to Submit an Audit? (Cont.) • Servicers that contract with eligible lenders or guarantors to administer any aspect of the FFEL Program. Note: An exemption applies if the servicer contracts with only one lender or guarantor and the lender’s or guarantor’s audit covers every aspect of the servicer’s administration of the FFEL program.

10. What to Submit? Prepared by your organization: • Information Sheet; • Corrective Action Plan if findings were identified;

11. What to Submit? (Cont.) Prepared by an Independent Public Accountant: • Practitioner’s examination report of your organization that includes management’s written assertions; • Schedule of findings and questioned amounts, if applicable;

12. What to Submit? (Cont.) • Comments on prior audit resolution matters; • Communication from the auditor to the lender of any internal control deficiencies noted; and • Separate report on illegal acts that could result in criminal prosecution, if applicable.

13. What to Submit? (Cont.) • Financial Statements (in addition to the items on the previous slides if preparing the audit in accordance to the OMB Circular A-133).

14. Where to Submit? • If filing an OMB Circular A-133 audit, send to: Federal Audit Clearinghouse Bureau of the Census 1201 E. 10th St. Jeffersonville, IN 47132

15. Where to Submit? • If filing an audit using the OIG’s Audit Guide, send to: Audit Compliance Resolution Team U.S. Department of Education Union Center Plaza 830 First St., NE Washington, DC 20202

16. Non Compliance • The Department may exercise its right to impose sanctions against those organizations who do not submit their required compliance audits.

17. Contact Information We appreciate your feedback and comments. We can be reached at: • Financial Partners Eligibility & Oversight: Audit Compliance Resolution Team • Phone: 202-377-3060 • Email: fpe&o.complianceaudits@ed.gov