DALLAS THEOLOGICAL SEMINARY

Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status effective date for some withdrawals was not accurately sent to NSLDS from the system. Criteria: 34 CFR 685.309 Questioned Costs: $0 Context: Out of 29 students tested, 3 students had incorrect effective dates reported for their enrollment status, ranging from two weeks to six weeks different. All of these students were official and unofficial withdrawals. These students were corrected during the audit process. Cause: There was an incorrect date being pulled in the system to send to NSLDS. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure the appropriate fields are captured from the system for NSLDS enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.033, Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has not: - sufficiently documented its security risk assessment and safeguards for systems and programs added during the year - implemented multi-factor authentication on all systems containing personally identifiable information (PII) - implemented a formal employee training program - implemented comprehensive continuous monitoring or annual penetration testing and biannual vulnerability scanning during the audit period - provided a written, annual report to the board Cause: The Seminary underwent a system conversion during the year and was not able to allocate sufficient resources to address and document compliance with the updated requirements of GLBA. Additionally, equipment purchased to address portions of compliance has remained on backorder. Effect: The Seminary has not adequately addressed the requirements of GLBA, which may lead to 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 address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.