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entitled 'Capital Financing: Department Management Improvements Could 
Enhance Education's Loan Program for Historically Black Colleges and 
Universities' which was released on November 17, 2006. 

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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

October 2006: 

Capital Financing: 

Department Management Improvements Could Enhance Education's Loan 
Program for Historically Black Colleges and Universities: 

GAO-07-64: 

GAO Highlights: 

Highlights of GAO-07-64, a report to congressional requesters 

Why GAO Did This Study: 

Historically Black Colleges and Universities (HBCU), which number 
around 100, undertake capital projects to provide appropriate settings 
for learning, but many face challenges in doing so. In 1992, Congress 
created the HBCU Capital Financing Program to help HBCUs fund capital 
projects by offering loans with interest rates near the government’s 
cost of borrowing. We reviewed the program by considering (1) HBCU 
capital project needs and program utilization, (2) program advantages 
compared to other sources of funds and schools’ views on loan terms, 
(3) the Department of Education’s (Education) program management, and 
(4) certain schools’ perspectives on and Education’s plan to implement 
loan provisions specifically authorized by Congress in June 2006 to 
assist in hurricane recovery efforts. To conduct our work, we reviewed 
applicable laws and program materials and interviewed officials from 
federal agencies and 34 HBCUs. 

What GAO Found: 

HBCU officials we interviewed reported extensive and diverse capital 
project needs, yet just over half of available loan capital ($375 
million) has ever been borrowed. About 23 HBCUs have taken steps to 
participate in the program, and 14 have become borrowers. Education has 
collected and reported limited data on the program’s utilization and 
has not established performance measures or goals to gauge program 
effectiveness, though Education officials noted they are developing 
measures and goals. 

The HBCU loan program provides access to low-cost capital financing and 
flexibilities not always available elsewhere, but some loan terms and 
conditions discourage participation, though school officials said they 
remain interested in the program. The low interest rate and 30-year 
repayment period were regarded favorably by participants and 
nonparticipants alike, and the program makes funds available for a 
broader range of needs than some federal grant programs. However, the 
requirement to place in a pooled escrow 5 percent of loan proceeds—an 
insurance mechanism that reduces federal program costs due to any 
program borrower’s potential delinquency or default—monthly payments 
versus semiannual ones traditionally available from private sources of 
loans, and the extent to which some loans have been collateralized 
could discourage participation. 

While Education has taken steps to improve the program, significant 
weaknesses in its management control could compromise the program’s 
effectiveness and efficiency. Education has recently provided schools 
with both fixed and variable interest rate options, allowed for larger 
loans, and afforded more opportunities to negotiate loan terms. Also, 
Education has increased its marketing efforts for the program. However, 
Education has not established effective management control to ensure 
that it is (1) communicating with schools in a useful and timely 
manner, (2) complying with statutory requirements to meet twice each 
year with an advisory board composed of HBCU experts and properly 
account for the cost of the program, and (3) monitoring the performance 
of the program’s contractor. 

Officials from 4 HBCUs in Louisiana and Mississippi told us that in 
light of the extensive 2005 hurricane damage to their campuses, they 
were pleased with certain emergency loan provisions but concerned that 
there would not be sufficient time to take advantage of Education’s 
authority to waive or modify the program provisions. School officials 
from the 4 schools noted that their institutions had incurred extensive 
physical damage that was caused by water, wind, and, in one case, fire, 
and that the full financial impact of the hurricanes may remain unknown 
for years. Although Education officials told us that they have not yet 
determined the extent to which the authority under the emergency 
legislation to waive or modify program provisions for hurricane-
affected institutions would be used, the department would be prepared 
to provide loans to hurricane-affected HBCUs. 

What GAO Recommends: 

We recommend that Education 
(1) comply with the law by regularly convening and consulting its 
Advisory Board, (2) improve school communications, (3) allow semiannual 
repayments, (4) properly account for costs in conformance with the law, 
and (5) formally monitor its contractor. Education agreed with our 
findings and four of the five recommendations made in this report. The 
department disagreed with our third recommendation. We continue to 
believe Education should allow semiannual repayments. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-64]. 

To view the full product, click on the link above. For more 
information, contact Cornelia Ashby at (202) 512-7215 or 
ashbyc@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

HBCUs Reported Substantial Capital Project Needs, but Only About Half 
of Available Program Funds Have Been Borrowed: 

The Program Provides Needed Access to Low-Cost Capital Financing, but 
Certain Loan Terms and Conditions Discourage Participation: 

Education Has Taken Some Steps to Improve the Program, but Weaknesses 
in Management Control Exist: 

HBCUs Affected by Hurricanes Expressed Satisfaction with Special Loan 
Provisions and Concerns with Application Deadline, while Education 
Officials Said They Would Evaluate Loan Processes: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: List of Historically Black Colleges and Universities GAO 
Interviewed: 

Appendix II: Number of HBCUs Eligible to Participate in Capital 
Financing Program by State (as of August 31, 2006): 

Appendix III: HBCUs Located in Geographic Area Affected by Hurricane 
Katrina in 2005: 

Appendix IV: Comments from the Department of Education: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Key Terms and Conditions for HBCU Capital Financing Loans: 

Table 2: History of Loan Activity of the HBCU Capital Financing 
Program: 

Table 3: Education's Indicators Measuring Program Utilization: 

Table 4: Designated Bonding Authority's Attendance and Scope of 
Activities at Conferences since 2002: 

Figures: 

Figure 1: The Renovated Kellogg Conference Center at Tuskegee 
University: 

Figure 2: Xavier University Science Building Auditorium Before and 
After Restoration from Flood Damage: 

Figure 3: Exterior of Southern University's Library with Waterline 
Indicating the Extent of Flooding: 

Figure 4: Removed Asbestos from Dillard University Library Awaiting 
Disposal: 

Abbreviations: 

APPA: Association of Higher Education Facilities Officers: 

DBA: designated bonding authority: 

FCRA: Federal Credit Reform Act: 

FEMA: Federal Emergency Management Agency: 

FFB: Federal Financing Bank: 

HBCU: Historically Black Colleges and Universities: 

HEA: Higher Education Act: 

NACUBO: National Association of College and University Business 
Officers: 

NAFEO: National Association for Equal Opportunity in Higher Education: 

NASULGC: National Association of State Universities and Land Grant 
Colleges: 

OMB: Office of Management and Budget: 

SACS: Southern Association of Colleges and Schools: 

SBA: Small Business Administration: 

UNCF: United Negro College Fund: 

United States Government Accountability Office: 
Washington, DC 20548: 

October 18, 2006: 

The Honorable Dale E. Kildee: 
Ranking Minority Member: 
Subcommittee on 21st Century Competitiveness: 
Committee on Education and the Workforce: 
House of Representatives: 

The Honorable Major R. Owens: 
House of Representatives: 

The nation's Historically Black Colleges and Universities (HBCU), like 
many of the approximately 6,500 other institutions of higher education 
in the country,[Footnote 1] undertake capital improvements, including 
renovating existing or constructing new instructional facilities, to 
provide their students appropriate settings for learning and social 
development. Many HBCUs, which number around 100 schools, face numerous 
challenges in funding capital projects because they have relatively 
small enrollments, limited endowments, and face other financial 
constraints. Despite these challenges, HBCUs have distinguished 
themselves by granting a substantial portion of the degrees earned by 
African-Americans. For example, in school year 2003-2004, HBCUs granted 
about 13.5 percent of all degrees earned by African-Americans while 
constituting only 1.5 percent of the nation's postsecondary 
institutions. 

To help these schools fund capital projects, Congress created the HBCU 
Capital Financing Program in 1992 under the Higher Education Act of 
1965 (HEA) to provide eligible HBCUs with access to low-cost financing. 
The Department of Education (Education) is responsible for overall 
program management and is expected to regularly consult with the HBCU 
Capital Financing Advisory Board (Advisory Board). The Advisory Board 
is composed of the Secretary of Education, or the Secretary's designee, 
presidents of private and public HBCUs, and other experts on HBCUs. 
Operation of the program is contracted to a designated bonding 
authority (DBA) that, among other lending functions, raises funds by 
issuing bonds for purchase by the Federal Financing Bank (FFB)--a 
government corporation under the supervision and direction of the 
Department of Treasury (Treasury) that assists federal agencies in 
financing agency-issued or agency-guaranteed securities. Funds raised 
are subsequently lent to eligible HBCUs at an interest rate slightly 
above the government's cost of borrowing to finance qualified capital 
projects. As part of its responsibilities in managing a federal credit 
program subject to the Federal Credit Reform Act of 1990 (FCRA), 
Education is required to determine the net cost to the government of 
extending credit over the life of a loan--the subsidy cost--in the year 
the loan is made. Congress must provide Education with budget authority 
to cover these costs before loans are provided to HBCUs. Since the 
program was first funded, appropriations legislation has, in general, 
limited the subsidy costs of the HBCU capital financing to no greater 
than zero. 

In August of 2005, the campuses of some HBCUs in the Gulf Coast were 
severely damaged by Hurricane Katrina or Rita. To assist these HBCUs in 
their recovery efforts, in June 2006, Congress, in the Emergency 
Supplemental Appropriations Act for Defense, the Global War on Terror, 
and Hurricane Recovery, 2006 (Emergency Act), amended certain statutory 
provisions for institutions affected by the Gulf Coast hurricane 
disasters and granted the Secretary of Education the authority to waive 
or modify any statutory or regulatory provisions of the program in 
connection with a Gulf Coast hurricane disaster. In addition, the 
Emergency Act provides that the authority to enter into, waive, or 
modify the terms of a loan agreement expires 1 year after the 
legislation's enactment. 

In light of the upcoming reauthorization of the Higher Education Act, 
you had questions about the utilization of the program and Education's 
management of the program. To address your interests, we reviewed the 
program by considering (1) the capital project needs of the nation's 
HBCUs and the extent to which HBCUs have used the program; (2) the 
relative advantages of the program, if any, compared with other sources 
of funding, and schools' perspectives on the loan terms and conditions; 
(3) whether Education's administration and management of the program 
ensures program effectiveness; and (4) schools' perspectives on the 
emergency loan provisions of the Emergency Act and Education's plans 
for implementing them. 

To conduct our work, we reviewed and analyzed applicable laws and 
regulations as well as program data and documents pertaining to program 
participation, program policies, and agreements among Education, the 
DBA, the FFB, and participating schools. We also reviewed the methods 
and procedures--management controls--Education had in place or was 
planning to implement to manage the program. To provide some context 
for understanding HBCUs' capital project needs, we analyzed available 
national studies concerning such needs of postsecondary institutions 
and HBCUs in particular. In addition, we reviewed alternative capital 
funding sources, including private sector financing and federal grants 
available to HBCUs and asked schools how these sources or funding 
options compare to the program. We interviewed officials representing 
Education, its DBA, the Advisory Board, the FFB, the Office of 
Management and Budget (OMB), the Small Business Administration (SBA), 
associations knowledgeable about HBCUs, and the Bond Market 
Association. We conducted semistructured interviews with 34 HBCUs. (See 
app. I.) We interviewed all 13 program participants that originated 
loans prior to 2006, and a purposive sample of 21 nonparticipants. We 
selected nonparticipating schools based on (1) location, (2) type (2- 
year and 4-year, public and private), and (3) enrollment size. Our 
selection of nonparticipating schools was made to obtain a variety of 
institutional perspectives and was not intended to be representative. 
During the course of our review, we conducted site visits to 5 
schools,[Footnote 2] 3 of which were institutions affected by the 
hurricanes in 2005,[Footnote 3] and the other 2 institutions were 
program participants. Our interviews with program participants also 
included another institution affected by the 2005 hurricanes. We 
conducted our work from May 2005 to August 2006 in accordance with 
generally accepted government auditing standards. 

Results in Brief: 

HBCU officials we interviewed reported extensive and diverse capital 
project needs, including construction and renovation of facilities and 
addressing deferred maintenance, yet just over half of the available 
HBCU Capital Financing Program loan capital has been borrowed. While 
capital project needs have not been well documented by national 
studies, the schools have individually identified and documented them. 
Despite reported needs, only 14 schools became borrowers--borrowing 
about $200 million, well below the $375 million limit Congress 
established. Education has collected and reported limited information 
on the program's utilization and has not established performance 
measures or goals to gauge program effectiveness, though Education 
officials noted that they are currently working on developing such 
measures and goals. 

The program provides access to low-cost capital financing and 
flexibilities not always available elsewhere, but some loan terms and 
conditions could discourage participation, though school officials said 
they remain interested in the program. Participants and nonparticipants 
alike looked favorably on low interest rates and long repayment periods 
(up to 30 years) offered by the program and noted that these may not be 
available in the private market for some borrowers. Further, while 
HBCUs may qualify for a variety of federal grants for capital projects, 
school officials said that the program makes funds available for a 
broader range of needs. However, school officials found that certain 
provisions of the program have discouraged participation. In 
particular, many officials remarked that the requirement that they 
place in a pooled escrow account 5 percent of loan proceeds was a 
disincentive to participate in the program. The escrow funds, which 
reduce the federal budget cost of the program by offsetting the 
estimated costs of any program borrower's loan delinquency or default, 
are returned to program participants if no such losses occur. The 
recent default of one borrower, however, has heightened awareness among 
participants of the financial risk for them inherent in the pooled 
escrow arrangement. Though not as prevalent a concern, Education's 
requirement for monthly loan repayments was viewed by some as an undue 
burden, given that the DBA remits these payments to the FFB 
semiannually. Although the range of capital projects permissible under 
the program is wider than that offered through some federal grant 
programs we reviewed, many school officials would like to see 
additional projects funded, such as multipurpose community centers and 
campus beautification projects. While concerns were noted, many schools 
expressed an interest in participating again or for the first time, 
provided that certain program improvements were made. 

While Education has taken some steps to improve the program, we found 
significant weaknesses in its management controls that compromise the 
extent to which Education can ensure program objectives are being 
achieved effectively and efficiently. Specifically, with respect to 
program improvements, Education has recently provided schools the 
choice of fixed or variable interest rates, allowed for larger loan 
amounts, and afforded more opportunity for schools to negotiate loan 
terms that appealed to schools. In addition, Education has increased 
marketing of the program. However, Education has not established 
effective management control in several areas, including: 

² Communication with HBCUs: Several HBCU officials reported that they 
lacked clear, timely, and useful information from Education and the 
DBA. For example, several officials said they did not receive updates 
about the status of their loans. For some schools, the process of 
getting the loan took more than a year. As a result of the lengthy 
process, capital project costs for some schools increased. School 
officials told us that the process could have been expedited had 
Education and the DBA made use of previous borrowers' experiences to 
apprise them of problems that could affect their own applications. 

² Compliance with laws and regulations: Despite a statutory requirement 
that the Advisory Board meet with and advise the Secretary of Education 
at least twice each year, the Advisory Board has met only three times 
in the last 12 years. In addition, Education has not complied with 
requirements of the Federal Credit Reform Act of 1990. In particular, 
Education has not properly accounted for the costs of the program 
because it has excluded certain fees paid by borrowers to the 
government from its cost estimates, thereby overestimating program 
costs. Moreover, Education has allowed the DBA to collect and hold in 
trust fees paid, but has not established policies or procedures for the 
DBA concerning how it is to remit these funds to the government. 

² Monitoring the program contractor: Although the DBA has been under 
contract with Education for over 5 years, it has not been formally 
assessed for performance. Also, Education has not monitored the 
marketing activities of its DBA to ensure that loans are being fairly 
allocated among as many eligible institutions as possible. Because the 
DBA's compensation is determined as a percentage of the amount 
borrowed, and the costs it incurs may not vary significantly from loan 
to loan, it is important to monitor its activities to ensure it is not 
making loans exclusively to schools that are likely to borrow larger 
amounts and for which its potential for profit is highest. 
Additionally, we found several instances of poor record keeping by the 
DBA, including missing key loan documentation, and until our review, 
Education was unaware that such documents were missing. 

HBCU officials whose campuses were affected by the hurricanes expressed 
satisfaction with the special loan provisions but had concerns about 
the time allowed to take advantage of them, while Education officials 
told us they are taking steps to evaluate the department's loan 
processes. School officials from the 4 schools we spoke with noted that 
their institutions had incurred extensive physical damages caused by 
water, wind, and, for one school, fire. Many of these officials said 
that they have not been able to fully assess all hurricane-related 
costs, such as replacing property, repairing plumbing systems, 
landscaping, and replacing sidewalks, and that the assessment process 
was lengthy because of the time required to prioritize campus 
restoration needs, undertake complex assessments of historic 
properties, follow state assessment processes, and other factors. They 
noted that the difficulties they face in making their assessments may 
make it challenging for them to apply prior to the expiration of the 
specially authorized provisions. School officials appreciated the 
reduced interest rate and cost of issuance (both set at 1 percent or 
less) and that the Secretary of Education was provided authority to 
waive or modify statutory or regulatory provisions for affected 
institutions to better assist them with their recovery. Although 
Education officials told us that they have not yet determined the 
extent to which the department would make use of its authority to waive 
or modify program provisions, including statutory loan limits, the 
department would be prepared to provide loans to hurricane-affected 
HBCUs. They noted that the department has already notified eligible 
institutions of the availability of funds and would hold additional 
meetings with schools to gain an understanding of their capital 
improvement and restoration needs. 

In this report we are making several recommendations to the Secretary 
of Education to ensure that the department is complying with provisions 
of the Higher Education Act of 1965 and the Federal Credit Reform Act 
of 1990. Furthermore, Education should also implement a number of 
program improvements, such as revising the repayment frequency for 
HBCUs and increasing monitoring of the DBA to ensure program 
effectiveness and efficiency. 

In written comments on a draft of this report, Education agreed with 
our findings and all but one of our recommendations. Education's 
written comments appear in appendix IV. Education also provided 
technical comments, which we incorporated where appropriate. 

Background: 

Congress established the HBCU Capital Financing Program in 1992 under 
Title III, Part D, of the Higher Education Act of 1965, as amended, to 
provide HBCUs[Footnote 4] with access to low-cost capital to help them 
to continue and expand upon their educational missions. (See app. II 
for locations of HBCUs eligible to participate in the program.) Program 
funds, raised through bonds issued by the DBA and purchased by the FFB, 
are lent to eligible schools with qualified capital projects.[Footnote 
5] Loan proceeds may be used for--among other things--repairing, 
renovating, or in exceptional circumstances, constructing and acquiring 
new instructional or residential facilities, equipment, or research 
instrumentation. Additionally, schools are able to refinance prior 
capital loans. Education guarantees loan repayment. 

Program Description: 

Although Education administers the program, the DBA is responsible for 
many of the program's operations and is subject to departmental 
oversight[Footnote 6]. Specifically, the DBA works with prospective 
borrowers to develop loan applications and monitors and enforces loan 
agreements. The loan process consists of multiple steps. HBCUs 
interested in obtaining funds through the program must first complete a 
preliminary application that includes information such as enrollment, 
some financial data--including a description of existing debt--and 
proposed capital projects. On the basis of this information, the DBA 
determines whether the school should formally complete an application, 
which includes more detailed financial information, such as audited 
financial statements and various campus plans and assessments. To be 
approved for the loan, an HBCU must satisfy certain credit criteria and 
have qualified projects. Once the DBA determines a school's eligibility 
status, a memorandum is sent to Education for final approval. When 
approved, the loan goes through a closing process during which certain 
terms and conditions may be negotiated. Table 1 describes key loan 
terms and conditions to which schools are subject. 

Table 1: Key Terms and Conditions for HBCU Capital Financing Loans: 

Loan term: Life of loan; Description: Loan maturity can be for 30 years 
or less. 

Loan term: Interest rates; 
Description: Schools may choose either variable or fixed interest rates 
for loans. Interest rates are generally based on the government's cost 
of borrowing. The FFB adds a surcharge of 1/8[TH] of 1 percent per year 
to cover federal administrative expenses. While the FFB levies the 
surcharge, Education is responsible for collecting it. 

Loan term: Escrow; 
Description: By law, schools are required to place 5 percent of the 
outstanding loan balance in an escrow account to cover risks against 
delinquency and default. Funds held in escrow are pooled and available 
to cover the costs of any program borrower's delinquent or defaulted 
loan. 

Loan term: Other fees; 
Description: By law, the cost of bond issuance is limited to no more 
than 2 percent of the loan (including the DBA's origination fee--
currently set at 1.25 percent). 

Loan term: Collateral; 
Description: Schools must provide collateral to obtain loan funds. 

Loan term: Disbursement; 
Description: Loan disbursements are made incrementally as projects 
progress. 

Loan term: Repayment; 
Description: Borrowers repay their loans monthly to the DBA, which in 
turn remits loan repayments to the FFB semiannually. The law requires 
that borrowers make payments to the DBA at least 60 days prior to the 
date for which payment on the bonds is expected to be needed. 

Loan term: Other; 
Description: Each year, schools are required to submit financial 
statements for the DBA's review. 

Source: GAO analysis. 

[End of table] 

Federal Credit Reform Act of 1990: 

The Federal Credit Reform Act of 1990, along with guidance issued by 
OMB and accounting standards, provides the framework agencies are to 
use in calculating the federal budget costs of federal credit programs, 
such as the HBCU Capital Financing Program. The two principles of 
credit reform are defining subsidy cost and requiring that budget 
authority to cover these costs be provided in advance before new loan 
obligations are incurred. OMB is responsible for coordinating the 
estimation of subsidy costs. Subsidy costs are determined by 
calculating the net present value[Footnote 7] of estimated cash flows 
to and from the government that result from providing loans and loan 
guarantees to borrowers. (Guaranteed loans that are financed by the FFB 
are treated as direct loans for budgetary purposes, in accordance with 
FCRA.) Cash flows for direct loans include, for example, loan 
disbursements to borrowers and borrower repayments of principal and 
payments of interest to the government. Estimated cash flows are 
adjusted to reflect the risks associated with potential borrower 
delinquencies and defaults, and estimates of amounts collected on 
defaulted loans. Subsidy costs can be positive or negative. If the net 
present value of cash outflows exceeds the net present value of cash 
inflows, the government incurs a positive subsidy cost. On the other 
hand, the government realizes a gain in revenue if there is a negative 
subsidy. Since the program was established, appropriations legislation 
has, in general, limited the subsidy costs of the program to be no 
greater than zero. In addition, the legislation authorizing the program 
established a credit authority limit of $375 million; of this amount, 
private HBCUs are collectively limited to borrowing $250 million, and 
public HBCUs are collectively limited to borrowing $125 million. 

2005 Gulf Coast Hurricanes and Disaster Assistance: 

Over a period of 2 months in 2005, three hurricanes struck the Gulf 
Coast region of the United States, resulting in more than $118 billion 
in estimated property damages.[Footnote 8] Two of these hurricanes, 
Katrina and Rita, struck New Orleans and surrounding areas within a 
month of each other, resulting in significant damages to several 
institutions of higher education in the region and including the 
campuses of several HBCUs,[Footnote 9] including Dillard University, 
Southern University at New Orleans, and Xavier University, in 
Louisiana, and Tougaloo College, in Mississippi. (See app. III for 
locations of the 8 hurricane affected HBCUs.) 

In June 2006, Congress passed the Emergency Act which, among other 
things, amends the HBCU Capital Financing Program to assist hurricane- 
affected HBCUs in their recovery efforts. To be eligible, a school must 
be located in an area affected by a Gulf Coast hurricane disaster and 
demonstrate that it (1) incurred physical damage resulting from 
Hurricane Katrina or Rita; (2) has pursued other sources of 
compensation from insurance, Federal Emergency Management Agency 
(FEMA), or the Small Business Administration, as appropriate; and (3) 
has not been able to fully reopen in existing facilities or to the 
levels that existed before the hurricanes because of physical damage to 
the institution. Key provisions include a lowered interest rate and 
cost of issuance (both set at 1 percent or less), elimination of the 
escrow, and deferment of principal and interest payments from program 
participants for a 3-year period. The Emergency Act also provides the 
Secretary of Education with authority to waive or modify any statutory 
or regulatory provisions related to the program in connection with a 
Gulf Coast hurricane disaster. 

Disaster Assistance Agencies: 

FEMA assists states and local governments with the costs associated 
with disaster response and recovery efforts that exceed a state or 
locale's capabilities. Grants are also provided to eligible 
postsecondary educational institutions to help them recover from the 
disaster. Some institutions of higher education are subsequently 
provided with referrals to SBA when seeking assistance from FEMA. For 
private, nonprofit institutions, SBA's disaster loans are designed to 
be a primary form of federal assistance. Unlike their public 
counterparts, private colleges must apply for low-interest, long-term 
disaster loans prior to seeking assistance from FEMA. Schools may apply 
for SBA loans, and the aggregate loan amount cannot exceed $1.5 
million. In general, the loan terms for each loan include a maximum of 
30 years for repayment with interest rates of at least 4 percent. 

HBCUs Reported Substantial Capital Project Needs, but Only About Half 
of Available Program Funds Have Been Borrowed: 

HBCU officials we interviewed reported extensive and diverse capital 
project needs, including construction and renovation of facilities and 
addressing deferred maintenance, yet just over half of the available 
program loan capital has been borrowed. While HBCU capital project 
needs are not well documented by national studies, the schools 
themselves have individually identified and documented them. Despite 
reported needs, only about a quarter of HBCUs have taken steps to 
participate in the program, and about half of these HBCUs became 
borrowers. Education has collected and reported limited information on 
the program's utilization and has not established performance measures 
or goals to gauge program effectiveness, though Education officials 
noted that they are currently working on developing such measures and 
goals. 

HBCUs Reported Having Substantial Capital Project Needs, although Such 
Needs Are Not Well Documented in National Studies: 

There are few national studies that document the capital project needs 
of HBCUs, and they do not provide a current and comprehensive national 
picture. The four that we identified and reviewed are more than several 
years old, narrowly scoped, or had limited participation.[Footnote 10] 
Specifically, the studies are between 6 and 17 years old, and two 
studies focused only on specific types of need--renovation of historic 
properties and campus wiring for computer networks.[Footnote 11] One 
study that addressed a broader range of needs and was among the most 
recent had a low response rate--37 percent. 

Despite the lack of national studies, schools that we interviewed 
reported extensive, diverse, and ongoing capital project needs. School 
officials reported that they routinely conduct facility 
assessments[Footnote 12] as part of their ongoing strategic planning 
and that these assessments help determine the institutions' short-and 
long-term capital needs. They said that capital projects, including the 
construction of new dormitories, renovation of aging or historic 
facilities, repair of infrastructure, and addressing long-standing 
deferred maintenance are needed for a variety of reasons. New 
facilities such as dormitories and student centers are often needed as 
a result of enrollment growth, for example, while modernization of 
existing facilities is needed to accommodate technological advances. 
For example, Tuskegee University renovated an existing facility to 
house its hospitality management program, creating modern meeting 
facilities along with a full-service hotel, which provides students 
with a real-world laboratory in which they gain immediate hands-on 
experiences (see fig. 1). In addition, many of the school officials who 
we interviewed reported that their schools had particularly old 
facilities, many of which are listed in the National Register of 
Historic Places.[Footnote 13] Some school officials cited their need to 
repair or replace campus infrastructure. For example, some schools 
reported needing to replace leaking underground water pipes, while 
others reported the need to replace 100-year-old water and gas pipes. 
Many of the school officials we interviewed reported having deferred 
maintenance projects, some for over 15 years, and officials from 3 
schools estimated their schools' deferred maintenance to be over $50 
million. For some schools, the deferred maintenance is substantial in 
light of existing resources, according to HBCU officials. These types 
of capital projects are essential to ensuring student safety and 
preserving assets that directly affect their ability to attract, 
educate, and retain students. 

Figure 1: The Renovated Kellogg Conference Center at Tuskegee 
University: 

[See PDF for image] 

Source: Tuskegee University. 

Note: The University relied in part on the HBCU Capital Financing 
Program to renovate and expand this facility. In particular, a program 
loan was used to finance the upgrades of the heating and ventilation 
system. 

[End of figure] 

Approximately 14 Percent of HBCUs Have Borrowed Just Over Half of the 
Available Program Funds: 

Over the life of the program, approximately 14 percent of HBCUs have 
borrowed just over half of the available funds despite the substantial 
needs reported by schools. Specifically, 23 HBCUs, according to 
Education, have taken steps to participate in the program, and 14 
became borrowers, with loans totaling just over $200 million--below the 
program's $375 million total limit. About 20 percent of the eligible 
private institutions have borrowed a little more than half of the $250 
million allotted for private schools, and less than 8 percent of public 
institutions have borrowed less than two-thirds of the $125 million 
allotted for public schools. To date, loan participants have all been 4-
year institutions. Taking into account loan repayments, the total 
amount of outstanding loans was about $168 million as of August 2006, 
leaving about $207 million available for loans (about $66 million for 
public schools and about $141 million for private schools). Table 2 
shows the participants and the amounts of their loans. Regarding other 
schools that took steps to participate in the program but did not 
become borrowers, 6 schools were reported to have withdrawn their 
applications, and 6 others had applications pending. To date, only one 
school has been denied a loan. 

Table 2: History of Loan Activity of the HBCU Capital Financing 
Program: 

Institution: Barber-Scotia College; 
Institution type: Private, 4-year; 
Amount borrowed: $7,000,000. 

Institution: Miles College; 
Institution type: Private, 4-year; 
Amount borrowed: $7,835,000. 

Institution: Tougaloo College; 
Institution type: Private, 4-year; 
Amount borrowed: $8,200,000. 

Institution: Virginia Union University; 
Institution type: Private, 4- year; 
Amount borrowed: $8,218,000. 

Institution: Bennett College; 
Institution type: Private, 4-year; 
Amount borrowed: $8,700,000. 

Institution: Livingstone College; 
Institution type: Private, 4-year;
Amount borrowed: $13,000,000. 

Institution: Shaw University; 
Institution type: Private, 4-year; 
Amount borrowed: $10,015,000. 

Institution: Bethune-Cookman College; 
Institution type: Private, 4- year; 
Amount borrowed: $20,295,000. 

Institution: Clark Atlanta University; 
Institution type: Private, 4- year; 
Amount borrowed: $23,905,000. 

Institution: Tuskegee University; 
Institution type: Private, 4-year; 
Amount borrowed: $35,931,000. 

Institution: Subtotal for private institutions; 
Institution type: [Empty]; 
Amount borrowed: $143,099,000. 

Institution: West Virginia State University; 
Institution type: Public, 4-year; 
Amount borrowed: $3,500,000. 

Institution: Lincoln University; 
Institution type: Public, 4-year; 
Amount borrowed: $13,850,000. 

Institution: Harris Stowe State University; 
Institution type: Public, 4-year; 
Amount borrowed: $15,264,000. 

Institution: South Carolina State University; 
Institution type: Public, 4-year; 
Amount borrowed: $42,000,000. 

Institution: Subtotal for public institutions; 
Institution type: [Empty]; 
Amount borrowed: $74,614,000. 

Institution: Total; 
Institution type: [Empty]; 
Amount borrowed: $217,713,000. 

Source: GAO analysis of Education data. 

Note: Some schools have more than one loan; amount borrowed reflects 
total for all loans. 

[End of table] 

Education Has Taken Limited Steps to Determine Schools' Financing Needs 
and Collect Information and Report on Program Utilization and 
Effectiveness: 

Education has collected and reported limited information concerning 
HBCUs' capital financing needs and the schools' utilization of the 
program. Education officials said that, beginning in 2005, to 
understand schools' financing needs and whether the program could 
assist schools, the DBA engaged in an outreach effort through which it 
identified 15 schools that might be candidates for the program. Over 
the history of the program, Education has collected some information to 
track program utilization, including the number of inquiries and 
applications received and the loan volume requested, approved, and 
awarded. However, Education has not widely reported such data. 
Education has provided certain elements of its program utilization data 
to Congress' appropriations committees via its annual justifications of 
budget estimates documents. Table 3 shows the data collected by 
Education to track program utilization. 

Table 3: Education's Indicators Measuring Program Utilization: 

Dollars in millions. 

Inquiries; 
1996: --; 
1997: --; 
1998: 25; 
1999: 30; 
2000: --; 
2001: --; 
2002: 11; 
2003: 22; 
2004: 36; 
2005: 23; 
2006: 8; 
Total: 155. 

Pre-applications received; 
1996: --; 
1997: --; 
1998: --; 
1999: --; 
2000: 1; 
2001: 2; 
2002: 2; 
2003: 8; 
2004: 7; 
2005: 5; 
2006: 1; 
Total: 26. 

Applications received; 
1996: 4; 
1997: 4; 
1998: 3; 
1999: 3; 
2000: 1; 
2001: 2; 
2002: 2; 
2003: 3; 
2004: 2; 
2005: 1; 
2006: 1; 
Total: 26. 

Loan volume requested; 
1996: $20.5; 
1997: $21.8; 
1998: $12.3; 
1999: $37.6; 
2000: $100; 
2001: $20.7; 
2002: $32.1; 
2003: $34.9; 
2004: $29.5; 
2005: $57.5; 
2006: $18; 
Total: $384.90. 

Loans approved; 
1996: 4; 
1997: 1; 
1998: 2; 
1999: 3; 
2000: 1; 
2001: 2; 
2002: 2; 
2003: 3; 
2004: 4; 
2005: 1; 
2006: 1; 
Total: 24. 

Loan volume approved; 
1996: $20.5; 
1997: --; 
1998: $8.3; 
1999: $37.6; 
2000: $13.85; 
2001: $20.7; 
2002: $32.1; 
2003: $24.9; 
2004: $51.8; 
2005: $42; 
2006: $15.5; 
Total: $267.25. 

Loans awarded; 
1996: 1; 
1997: 1; 
1998: 0; 
1999: 3; 
2000: 1; 
2001: 2; 
2002: 2; 
2003: 2; 
2004: 3; 
2005: 1; 
2006: 1; 
Total: 17. 

Volume awarded; 
1996: $3.5; 
1997: $4.8; 
1998: $0; 
1999: $37.6; 
2000: $7; 
2001: $20.7; 
2002: $32.1; 
2003: $24.9; 
2004: $29.8; 
2005: $42; 
2006: $15.3; 
Total: $217.70. 

Source: Education and GAO analysis of budget justification documents. 

Note: (--) indicates that Education was unable to provide information 
for the indicator in that particular year. 

[End of table] 

Education officials noted that while the data they collect are useful 
to indicate the extent to which the schools have used or accessed the 
program, they are inadequate to address questions concerning whether 
the program is under-or overutilized or to demonstrate program 
effectiveness. These officials noted that they believe program 
performance measures would be useful but that developing such measures 
is particularly challenging for a credit program like the HBCU Capital 
Financing Program. This is so in part because participation in a loan 
program is dependent on complex factors, such as schools' funding 
needs, the availability of other sources of financing, and schools' 
desire and capacity to assume debt. Program officials cautioned against 
setting firm program participation goals, for example, because they 
would not want Education to be perceived as "pushing" debt onto schools 
that either do not want to, or should not, assume loan obligations 
before their circumstances warrant doing so. Another complicating 
factor program officials cited was the small number of potential 
program beneficiaries. One Education official noted that Education has 
established performance goals and measures for its student grant and 
loan aid programs, which are based on sophisticated survey mechanisms 
designed to measure customer (students, parents, and schools) 
satisfaction with the department's aid application, receipt, and 
accounting processes. Because the scope of the student aid programs is 
large, encompassing millions of students and parents and thousands of 
schools, it is reasonable to develop and use such measures, the 
official noted. In contrast, such measures may not be meaningful given 
the small number of HBCUs and the frequency with which loans are made 
under the Capital Financing Program. Nevertheless, these officials told 
us that they believe program performance measures would be useful to 
gauge program effectiveness. They have established a working group to 
develop performance measures for the program and were consulting with 
OMB and other federal officials with expertise on federal credit 
programs to guide their efforts. The officials noted that they do not 
have any firm schedule with respect to completing their development of 
program performance measures. 

The Program Provides Needed Access to Low-Cost Capital Financing, but 
Certain Loan Terms and Conditions Discourage Participation: 

The HBCU loan program provides access to low-cost capital financing and 
flexibilities not always available elsewhere, but some loan terms and 
conditions discourage participation, though school officials said they 
remain interested in the program. The low interest rate and long 
repayment period were regarded favorably by participants and 
nonparticipants alike, and the program makes funds available for a 
broader range of needs than some federal grant programs. However, the 
pooled escrow arrangement, monthly repayment terms, and the extent to 
which some loans have been collateralized could discourage 
participation. 

The Program Provides Low-Cost Financing and Certain Flexibilities in 
Comparison to Other Capital Funding Sources: 

The HBCU Capital Financing Program provides lower-cost financing and 
longer loan maturities and may be used for a broader range of capital 
projects by a greater number of schools than other funding sources, 
according to HBCU officials. Some officials noted that the program 
offers loans with lower interest rates than traditional bank loans. 
Moreover, the program's interest rates are typically less than the 
interest rates schools would be required to pay investors if they 
issued their own bonds to raise funds. According to school officials 
and bond industry experts, some HBCUs could obtain, and some have 
obtained, lower interest rates than those offered under the program by 
issuing their own tax-exempt bonds.[Footnote 14] However, this is 
predicated on a school's ability to obtain a strong credit rating from 
a credit rating agency.[Footnote 15] Schools with weaker or 
noninvestment grade credit ratings would likely have to pay investors 
higher interest rates. In addition, schools issuing taxable bonds would 
likely pay higher interest rates to investors, compared to the 
program's interest rates, regardless of the schools' credit ratings. 
While schools can lower interest rates paid to bond investors by 
purchasing bond insurance, the cost to do so may be 
prohibitive.[Footnote 16] For these reasons, officials at Education and 
HBCUs, as well as bond industry experts, told us that the HBCU Capital 
Financing Program may be ideally suited for schools that have or would 
receive a noninvestment grade rating. Participation in the program may 
also benefit schools by enhancing their ability to issue their own 
bonds in the future. An official at one HBCU, for example, told us that 
obtaining and repaying a loan under the program had allowed the school 
to demonstrate its fiscal stability and to subsequently issue its own 
bond with a lower interest rate than was then being offered under the 
program. 

In addition to citing lower interest rates, a large majority of the 
HBCU officials we spoke to said that the program's 30-year loan 
repayment period was attractive, and some noted that private funding 
sources would likely offer 20 years or less. Some school officials 
noted that the longer repayment period allowed schools to borrow more 
or reduce the amount of monthly payments. Borrowing larger amounts, 
officials reported, allowed them to finance larger or more capital 
projects. Another school we spoke with that once considered using the 
program said that even though it was able to issue a tax-exempt bond 
and obtain a more favorable interest rate, it could only obtain a 20- 
year maturity period for the bond. 

Some HBCU officials told us they preferred grants to loans but noted 
that, in general, compared to other federal grant programs, more HBCUs 
are eligible for the HBCU loan program, and that it also funds a wider 
variety of projects. Grants are available for most HBCUs under the 
Higher Education Act's strengthening institutions programs, also 
administered by Education, which fund capital projects as well as other 
activities, such as faculty and academic program development. However, 
fewer HBCUs are eligible for other federal grant programs that provide 
funding for capital projects. For example, the Department of 
Agriculture's 1890 Facilities Grant Program is only for those 18 HBCUs 
that are land grant institutions. Similarly, the Department of Health 
and Human Services' facilities improvement program provides only for 
those HBCUs with a biomedical and behavioral research program. While 
there are a variety of other assistance programs offered by charitable 
foundations, and state and local governments, available funding is 
limited. 

The Escrow Arrangement, among Other Terms and Conditions, Was Cited as 
a Disincentive to Participating in the Program: 

HBCU officials we spoke with--participants and nonparticipants alike-- 
reported that a disincentive to participation in the program was the 
pooled escrow; additionally, other terms and conditions, such as the 
monthly repayment schedule and the extent to which loans are 
collateralized, were also viewed by some as deterrents. Over half of 
HBCU respondents we spoke with--both participants and nonparticipants-
-agreed that the pooled escrow was a drawback, and over one-fifth said 
that it actually deters participation. The escrow funds, which reduce 
the federal budget cost of the program by offsetting the estimated 
costs associated with delinquent loan repayments and borrower defaults, 
net of collections, are returned to program participants if no such 
losses occur. However, a recent default by one borrower--the first to 
occur in the program's history--has heightened awareness among program 
participants of the financial risk for them inherent in the pooled 
escrow arrangement.[Footnote 17] Since the default, Education has 
withdrawn funds from participating schools' escrow accounts twice and 
will continue doing so until the default is resolved, leaving other 
schools uncertain as to how much of their own escrow accounts will 
remain or be replenished.[Footnote 18] The pooled escrow feature also 
presents a problem for state institutions because they are prohibited 
from assuming the liability of another institution. One program 
official said that this issue was common for state schools because 
state law prohibits the lending of public funds to nonstate entities-- 
considered to be the case when state funds in escrow are used to hedge 
against the delinquency of another institution. One participating 
public HBCU reported that it had to resolve this problem by accounting 
for its escrow payments as a fee that would not be returned to the 
school rather than a sum that could be recovered, as the program 
intends. Because the escrow feature is mandated by law, any changes to 
this arrangement would require congressional authorization. 
Additionally, in order to maintain the federal subsidy cost of the 
program at or below zero, other alternatives--such as assessing 
additional fees on borrowers, or requiring contributions to an 
alternative form of a contingency reserve--would be necessary in the 
absence of the pooled escrow arrangement. 

While frequency of payments is not as prevalent a concern as the pooled 
escrow, some schools objected to the program's requirement that 
repayments be made monthly as opposed to semiannually, as is common in 
the private market. Schools participating in the HBCU Program have been 
required by the DBA to make payments monthly, although FFB lending 
policy is to require repayments only on a semiannual basis. Despite the 
fact that participants have met the terms of an extensive credit 
evaluation process, DBA officials expressed the view that the monthly 
repayment requirement promotes good financial stewardship on the part 
of the schools. However, some HBCU officials said that they incur 
opportunity costs in making payments on a monthly versus a semiannual 
basis. They also noted that it would be more practical if payments were 
to coincide with the beginning of their semesters, when their cash 
flows are typically more robust. 

Additionally, almost half of the participating schools expressed 
concern about the amount of collateral they had to pledge in order to 
obtain a loan. In most cases, program participants have pledged certain 
real property as collateral, though endowment funds and anticipated 
tuition revenue are also allowed as collateral. Some HBCU officials 
said their loans were overcollateralized in that the value of the real 
estate pledged as security exceeded the value of the loan. They noted 
that such circumstances can present a problem for those schools trying 
to obtain additional capital financing without sufficient assets 
remaining available as collateral. One nonparticipant cited the 
collateral required of other institutions as a reason for its decision 
not to participate. When asked about the amount of collateral required, 
Education and DBA officials reported that the extent and amount of 
collateral required to obtain a loan under the program varies depending 
on the individual circumstances of an institution. The amount of 
collateral required may be less for institutions that have maintained 
relatively large endowments and stable tuition revenue and more for 
institutions that have few or no physical properties to use as 
collateral, for example. Education officials further noted that 
requiring the value of collateral to be greater than the value of the 
loan was not an uncommon business practice. 

Overall, more than two-thirds of the participant schools and more than 
a third of the nonparticipants said they are interested in using the 
program but some said that their continued or future interest in the 
program would depend on its being modified. Several schools suggested 
the types of projects eligible for funding could be broadened, which 
might allow them to undertake capital projects that would, in turn, 
assist them in attracting and retaining additional students. Campus 
beautification projects and multipurpose community centers were cited 
as examples. In addition, they regarded new construction--for which 
program loans are available only under exceptional circumstances--as 
particularly important because new construction attracts more students 
and because renovations often incur unexpected costs. Nevertheless, 
many public HBCU school officials we spoke with said that in view of 
their states' continuing fiscal constraints, they expect to consider 
the loan program as a future funding resource. 

Education Has Taken Some Steps to Improve the Program, but Weaknesses 
in Management Control Exist: 

While Education has taken limited steps to improve the program, we 
found significant weaknesses in management controls that compromise the 
extent to which Education can ensure program objectives are being 
achieved effectively and efficiently. Education has recently provided 
schools the choice of fixed or variable interest rates, allowed for 
larger loan amounts, and afforded more opportunity for schools to 
negotiate loan terms, which appealed to schools. In addition, Education 
has attempted to increase awareness of the program among HBCU officials 
through increased marketing of the program by the DBA. While Education 
has taken steps to improve the program, we found significant weaknesses 
in its management control with respect to its communications with 
HBCUs, compliance with program and financial reporting laws and 
guidance, and monitoring of its DBA. 

Education Has Recently Introduced Some Program Improvements, Including 
Flexible Loan Terms: 

Since 2001, Education has taken some steps to improve the program--in 
some cases by allowing greater negotiation of certain loan terms and 
conditions. Department officials said that changes to the program were 
necessary to remain competitive with other programs and the private 
market. These flexible terms included a variable interest rate option 
and the opportunity to negotiate the amount of additional debt that a 
school can subsequently assume through other financing arrangements. In 
fact, since 2003, 4 of the 7 schools that have received loans have 
taken advantage of the variable interest rate. Regarding the 
department's monitoring of their debt, officials at another school said 
that they were able to negotiate with the DBA the amount of additional 
debt they could assume--from $500,000 to $1 million--before they would 
have to notify the department. School officials said this change was 
important because it not only reduced their administrative burden but 
it also gave them additional leeway to pursue other capital financing. 
The program made greater use of loans for the sole purpose of 
refinancing existing debt since 2003[Footnote 19]. Two participants 
reported an estimated savings of at least $3.7 million by refinancing 
under the program. According to department officials, Education has 
also made greater use of the Secretary's authority to originate loans 
exceeding $10 million and to make multiple loans to an institution, 
providing schools with more purchasing power. Program officials said 
that while the limit on the amount and number of loans that could be 
made was to prevent disproportionate use of the loan fund by larger and 
more affluent schools, it no longer reflected the reality of current 
costs for construction and renovation or the budgetary constraints 
facing many states. 

Additionally, program officials we spoke with said they had enhanced 
program marketing. For example, the DBA has developed a Web site 
describing the program and offering answers to frequently asked 
questions. In addition, officials reported attending the national and 
regional conferences for college executives shown in table 4, 
completing over 60 campus site visits and contacting other school 
officials by telephone. Program officials also reported that most 
schools received written correspondence or an e-mail to inform them of 
the program. By these efforts, all HBCUs have been contacted in 2005, 
according to DBA officials. They also said they timed these outreach 
efforts to correspond with schools' annual budgetary and enrollment 
processes in order to prompt schools to think about potential capital 
projects that could fit the program. DBA officials said that their 
marketing approach for fiscal year 2006 would be the same as in the 
previous year. 

Table 4: Designated Bonding Authority's Attendance and Scope of 
Activities at Conferences since 2002: 

Conference name: Southern Association of Colleges and Schools (SACS) 
regional meetings; 
Years attended[A]: 2002: ­; 
Years attended[A]: 2003: ­; 
Years attended[A]: 2004: ­; 
Years attended[A]: 2005: ­; 
HBCUs in membership[B]: 77 HBCUs in 11 states; 
DBA's activity: Breakfast and luncheon sponsorships, exhibit space, 
receptions, and dinners. 

Conference name: National Association of College and University 
Business Officers (NACUBO) national or regional conferences; 
Years attended[A]: 2002: [Empty]; 
Years attended[A]: 2003: ­; 
Years attended[A]: 2004: ­; 
Years attended[A]: 2005: ­; 
HBCUs in membership[B]: c; 
DBA's activity: Exhibit space, client dinners. 

Conference name: United Negro College Fund's annual events; 
Years attended[A]: 2002: [Empty]; 
Years attended[A]: 2003: ­; 
Years attended[A]: 2004: ­; 
Years attended[A]: 2005: ­; 
HBCUs in membership[B]: 39 private 4-year colleges; 
DBA's activity: Event sponsorships, contact with meeting participants. 

Conference name: National Association of State Universities and Land 
Grant Colleges (NASULGC) Annual Meeting; 
Years attended[A]: 2002: ­; 
Years attended[A]: 2003: [Empty]; 
Years attended[A]: 2004: [Empty]; 
Years attended[A]: 2005: [Empty]; 
HBCUs in membership[B]: 18 land grant HBCUs/other members; 
DBA's activity: Contact with meeting participants. 

Conference name: Thurgood Marshall President's and Member Schools' 
Professional Conference; 
Years attended[A]: 2002: [Empty]; 
Years attended[A]: 2003: ­; 
Years attended[A]: 2004: [Empty]; 
Years attended[A]: 2005: [Empty]; 
HBCUs in membership[B]: School executives at 47 HBCUs; 
DBA's activity: Contact with meeting participants. 

Conference name: National Association for Equal Opportunity in Higher 
Education's annual conference; 
Years attended[A]: 2002: ­; 
Years attended[A]: 2003: ­; 
Years attended[A]: 2004: ­; 
Years attended[A]: 2005: ­; 
HBCUs in membership[B]: All HBCU executives/other members; 
DBA's activity: Exhibit space, evening receptions. 

Conference name: White House Initiative on HBCUs National HBCU Week 
Conference; 
Years attended[A]: 2002: ­; 
Years attended[A]: 2003: ­; 
Years attended[A]: 2004: ­; 
Years attended[A]: 2005: ­; 
HBCUs in membership[B]: All HBCU executives; 
DBA's activity: Direct contact with meeting participants, client 
dinners. 

Source: GAO analysis. 

[A] GAO did not confirm conference attendance with host association/ 
organization: 

[B] Information on HBCUs included in membership based on most recent 
data available. 

[C] No description of HBCU membership was available. 

[End of table] 

Weaknesses in Management Control Exist: 

While Education has taken some steps to improve the HBCU loan program, 
we found significant weaknesses in its management control of the 
program with respect to its (1) communications with HBCUs, (2) 
compliance with program and financial reporting laws and guidance, and 
(3) monitoring of its DBA, as described below. 

Communication with HBCUs: 

Many HBCU officials we interviewed reported a lack of clear, timely, 
and useful information from Education and the DBA at various stages of 
the loan process, and said the need to pursue such information 
themselves had sometimes led to delays. While program materials 
represent the loan application as a 2-to 3-month process, about two- 
thirds of the loans made since January 2001 were not closed until 7 to 
18 months after application. Officials from one school said that it had 
taken 6 to 7 months for the DBA to relay from Education a clarification 
as to whether its proposed project was eligible. Other schools reported 
that Education had not provided timely or clear information about the 
status of their loans. In some cases, schools reported that the lengthy 
loan process resulted in project delays and cost increases over the 
intervening time period. An official from one school told us that it 
remained unclear to him why his school was denied a loan. 

Education officials acknowledged that the loan process was lengthy for 
some borrowers and said its DBA had attempted to work with these 
borrowers to address problems with applications. School officials told 
us that in some cases the loan process could have been expedited had 
Education and the DBA made use of previous borrowers' experiences to 
apprise them of problems that could affect their own applications--such 
as the fact that title searches can be especially time consuming and 
problematic for private HBCUs, some of which did not receive all 
property deeds from their founders when they were established in the 
1800s. With regard to making loan payments, several officials we 
interviewed said that DBA officials had not provided information that 
was in sufficient detail. In one situation, officials from one school 
reported that school auditors had questioned the accuracy of the loan 
payment amount for which the school was billed by the DBA because the 
billing statements omitted information concerning the extent to which 
the amount billed included escrow payments. Other officials noted that 
they had not received written notification from the DBA concerning the 
full amount of their potential liability after funds had been withdrawn 
from the schools' escrow accounts to cover payments on behalf of 
another borrower that had recently defaulted on a loan. 

Compliance with Program and Budget Laws and Federal Financial 
Accounting Standards: 

Education has not complied with certain statutory requirements relating 
to the program's operations and how federal agencies are to account for 
the government's cost of federal loan programs. In creating the 
program, Congress established within the Department of Education an 
HBCU Capital Financing Advisory Board composed of the (1) Secretary of 
Education or the Secretary's designee, (2) three members who are 
presidents of private HBCUs, (3) two members who are presidents of 
public HBCUs, (4) the President of the United Negro College Fund or 
his/her designee, (5) the President of the National Association for 
Equal Opportunity in Higher Education or his/her designee, and (6) the 
Executive Director of the White House Initiative on HBCUs. By law, the 
Advisory Board is to provide advice and counsel to the Secretary of 
Education and the DBA concerning the capital financing needs of HBCUs, 
how these needs can be met through the program, and what additional 
steps might be taken to improve the program. To carry out its mission, 
the law requires that the board meet with the Secretary of Education at 
least twice each year. Despite this requirement, the board has met only 
three times in the past 12 years, the most recent meeting occurring in 
May 2005. According to Education officials, the Advisory Board did not 
routinely meet because of turnover among Education staff as well as 
HBCU presidents designated to serve on the board. Education officials 
told us that there could have been other reasons why the Advisory Board 
did not meet in earlier years, but none that they had knowledge of. 
Although Education officials told us that they had believed another 
Advisory Board meeting would be convened soon after the May 2005 
meeting, no such meeting has yet been scheduled. 

We also found that Education has not fully complied with requirements 
of the Federal Credit Reform Act of 1990, which, along with guidance 
issued by OMB and accounting standards, provide the framework that 
Education is to use in calculating the federal budget costs of the 
program. In particular, Education has excluded certain fees paid by 
HBCUs from its calculations of program costs. The interest payments 
made by HBCUs on program loans includes a surcharge of 1/8TH of 1 
percent assessed by FFB in accordance with its policy and as permitted 
by statutory provisions governing its transactions.[Footnote 20] Under 
the Federal Credit Reform Act of 1990, these fees--i.e., the surcharge-
-are to be recognized as cash flows to the government and included in 
agencies' estimated costs of the credit programs they 
administer.[Footnote 21] In addition, these fees are to be credited to 
the program's financing account.[Footnote 22] OMB officials responsible 
for coordinating agencies' subsidy cost estimates acknowledged that 
Education should include the fees in its budgetary cost estimates and 
noted that other agencies with similar programs do so. Further, the 
written agreement among Education, the FFB, and the DBA that governs 
the issuance of bonds by the DBA for purchase by the FFB for the 
purpose of funding loans under the program also stipulates that these 
fees are to be credited to Education. Despite these provisions, 
Education has not included the fees in its calculations of the federal 
cost of the program, thereby overestimating the program's costs; nor 
has Education accounted for the fees on its financial 
statements.[Footnote 23] Instead, the DBA has collected and held these 
fees in trust.[Footnote 24] Although the contract between Education and 
the DBA generally describes how the DBA is to manage the proceeds from 
and the payment of bonds issued to fund loans made to HBCUs, it does 
not specifically address how the DBA is to manage the payments that 
reflect the 1/8th of 1 percent paid by borrowers. In general, the DBA 
collects borrower repayments and remits the proceeds to the FFB to pay 
amounts due on the program's outstanding bonds. However, the amounts 
paid to the FFB do not include the fees paid by borrowers. As a result, 
it is unclear how these funds, retained by the DBA, are to be 
eventually returned to the federal government. Moreover, Education has 
not monitored the DBA's handling of these funds and is unaware of the 
accumulated balance. 

Monitoring the Performance of the DBA: 

Although the current DBA has been under contract with Education for 
over 5 years, Education has not yet assessed its performance with 
respect to key program activities and contractual obligations, although 
Education officials said that they have been pleased with the DBA's 
performance. One of these major activities is "marketing" the capital 
financing program among HBCUs in order to raise awareness and help 
ensure that the program is fully utilized. Although the DBA is required 
by its contract with Education to submit annual reports and audited 
financial statements to Education, it has not done so. While DBA 
officials told us the department has offered some informal assessments, 
Education officials have not guided their marketing efforts. Still, we 
found indications that the DBA's marketing strategy has likely suffered 
from a lack of guidance and monitoring by Education. Officials we spoke 
with at 4 schools did not know of the program, and another eight told 
us they had learned about it from peers or advocacy organizations. 
Others were aware of the DBA's marketing activities, but offered a 
number of suggestions for improvement, citing a need for more specific 
information as to the extent to which collateral would be needed, how 
the program meets the needs of both private and public schools, or 
examples and testimonials about funded projects. Several school 
officials said DBA outreach through conferences was not necessarily 
well targeted--either because the selected conferences covered a full 
range of topics for a variety of schools and not only HBCUs, or because 
they focused on issues relating to either public or private HBCUs, or 
because they drew school officials not involved in facilities planning. 
Additionally, the DBA has reserved its direct contact marketing largely 
for 4-year schools. DBA officials justified this decision on grounds 
that smaller schools tended to have more difficulty borrowing and that 
they had targeted larger schools that they believed would be most 
likely to benefit from the program. However, as prescribed by law, 
loans are to be fairly allocated among as many eligible institutions as 
possible. Because the DBA's compensation is determined as a percentage 
of the amount borrowed, and the costs it incurs may not vary 
significantly from loan to loan, it is important to monitor its 
activities to ensure it is not making loans exclusively to schools that 
are likely to borrow larger amounts and for which its potential for 
profit is highest. 

With regard to the DBA's basic responsibility for keeping records, we 
found several cases in which critical documents were missing from loan 
agreement files. Moreover, the DBA was unable to provide us with 
entirely complete files for any of the 14 institutions that had 
participated or were participating in the program. For example, 
documents that included loan applications, decision memoranda, 
financial statements, and real property titles were missing for several 
schools. In our file review, we found that files for 9 schools did not 
include the original application. Files for 8 schools did not include 
the required financial statements for demonstrating long-term financial 
stability, and 5 lacked DBA memoranda pertaining to the decision to 
make the loan. Moreover, until our review, key Education officials were 
unaware that such documents were missing.[Footnote 25] 

HBCUs Affected by Hurricanes Expressed Satisfaction with Special Loan 
Provisions and Concerns with Application Deadline, while Education 
Officials Said They Would Evaluate Loan Processes: 

Officials from four HBCUs in the Gulf Region we spoke with (Dillard 
University, Southern University at New Orleans, Xavier University, and 
Tougaloo College) told us that, in light of the extensive hurricane 
damage to their campuses, they were pleased with the emergency loan 
provisions but concerned that the 1-year authorization would not 
provide sufficient time for them to take advantage of the special 
program features. School officials from each of the four schools noted 
that their institutions had incurred physical damages caused by water, 
wind, and, in the case of one institution, fire, and that the actual 
financial impact of the hurricanes may remain unknown for years. 
Although Education officials told us that they have not yet determined 
the extent to which the department would make use of its authority to 
waive or modify program provisions for hurricane-affected institutions, 
the department would be prepared to provide loans to hurricane-affected 
HBCUs. 

Gulf Area HBCUs Experienced Significant Hurricane Damage, and the Full 
Financial Impact May Remain Unknown for Years: 

Officials from the three HBCUs we visited reported extensive damage to 
their campuses as a result of the 2005 hurricanes and noted that it may 
take another few years to determine the full financial impact. School 
officials told us that they have not been able to fully assess all 
hurricane-related costs, such as replacing property, repairing plumbing 
systems, landscaping, and replacing sidewalks, and as result, current 
estimates are only preliminary. School officials noted that the 
assessment process was lengthy because of, among other things, the time 
required to prioritize campus restoration needs, undertake complex 
assessments of historic properties, follow state assessment processes, 
and negotiate insurance settlements. Each of the four schools we 
contacted incurred physical damages caused by water and wind; one 
school also incurred damage by fire. For example, the campuses of all 
three schools in New Orleans were submerged in 2 to 11 feet of water 
for about a month after the hurricanes, damaging the first floors of 
many buildings as well as their contents. As a result, schools required 
removal of debris and hazardous waste (e.g., mold and asbestos), repair 
and renovation, and the taking of actions recommended by FEMA to 
mitigate future risks. Xavier University officials, who preliminarily 
estimated $40 million to $50 million in damage to their school, said 
that they faced the need to undertake several capital projects, 
including replacing elevators, repairing roofs, and rehabilitating the 
campus auditorium and replacing its contents. According to officials 
from Southern University at New Orleans, state officials have estimated 
damages at about $17 million; at the time of our visit 10 months after 
the hurricanes, state insurance assessors were beginning their work on 
the campus library, where mold reached all three floors, covering 
books, art collections, card catalogues, and computers. Officials at 
Dillard University also reported extensive damage, preliminarily 
estimated as high as $207 million[Footnote 26]. According to officials, 
five buildings--which were used for academic support services and 
residential facilities--had to be demolished because of extensive 
damage; three of these buildings were destroyed by fire. Further, they 
also reported that the international studies building, built adjacent 
to a canal levee in 2003, will have to be raised at least 18 feet to 
make it insurable. Officials at Tougaloo College, in Mississippi, 
reported wind and water damage to the roofs of some historic 
properties, which along with other damages, they preliminarily 
estimated at $2 million. Figures 2-4 show some of the damages and 
restoration under way at the three schools we visited. 

Figure 2: Xavier University Science Building Auditorium Before and 
After Restoration from Flood Damage: 

[See PDF for image] 

Sources: Xavier University. 

[End of figure] 

Figure 3: Exterior of Southern University's Library with Waterline 
Indicating the Extent of Flooding: 

[See PDF for image] 

Source: GAO. 

[End of figure] 

Figure 4: Removed Asbestos from Dillard University Library Awaiting 
Disposal: 

[See PDF for image] 

Source: GAO. 

Note: All of the affected HBCUs have resumed operations but are still 
in the process of restoring their campuses to varying degrees. In the 
case of Southern University, it has created a new campus nearby 
consisting of more than 400 trailers constructed by the U.S. Army Corps 
of Engineers while damage assessments are being made. By contrast, 
Dillard University had moved its operations--classes, student services, 
administration--and students to a local hotel and other buildings as it 
undertook the restoration of its campus. Officials were scheduled to 
reopen that campus in September 2006. Xavier University had resumed 
operations on its campus in January 2006 while it continued to restore 
its facilities. 

[End of figure] 

Schools Found Select Terms for Emergency Loans Favorable, but Said They 
Would Be Challenged to Make Application in the Time Allotted: 

The school officials we spoke with found certain emergency provisions 
of the loan program favorable, but they expressed reservations about 
the time frame within which they are required to make application for 
the special loans. Most school officials appreciated the reduced 
interest rate and cost of issuance (both set at 1 percent or less) and 
that the Secretary of Education was provided discretion to waive or 
modify statutory or regulatory provisions, such as credit criteria, to 
better assist them with their recovery. They said the normal sources of 
information for credit evaluation--such as audited financial records 
from the last 5 years--would be difficult to produce. Other conditions 
of the emergency loan provisions some officials found favorable were 
the likelihood that loans would be awarded sooner--providing a timely 
infusion of funds--with more flexibility compared to other programs. 
Officials at both Dillard and Xavier Universities said that because 
their institutions had already spent a significant amount of their 
available resources, the emergency loans could be used to bridge any 
emerging financial difficulties they experience as they continue to 
pursue insurance settlements and assistance from other federal 
agencies, including FEMA and SBA. Additionally, some school officials 
said that the program may allow for greater flexibility compared to 
FEMA and SBA aid. For example, some officials told us that in 
addressing damages caused by the hurricanes they would like to improve 
upon their facilities to mitigate potential environmental damages in 
the future and, at one school, upgrade an obsolete science laboratory 
with state-of-the-art equipment. They said, however, that in some cases 
FEMA aid is limited to restoring campus facilities to their prestorm 
conditions and in other cases desired improvements might not be 
consistent with requirements for historic preservation. 

While most school officials we spoke with found select provisions 
favorable, they expressed concerns with stipulations that limit the 
extension of the special provisions to 1 year, primarily because all of 
the costs associated with damage from the hurricanes have not been 
fully identified. Further, officials at Southern University at New 
Orleans--a public institution--said that they are subject to an 
established capital improvement approval process involving both its 
board of directors and state government officials that alone normally 
requires a year to complete. Additionally, some of the schools are 
concerned that they may not be able to restore damaged and lost records 
needed to apply to the program. Officials reported that a time frame of 
at least 2 to 3 years would allow them to better assess the costs of 
the damages. Other concerns cited included eligibility requirements for 
the deferment provision, and officials from one institution expressed 
disappointment that the emergency provisions did not include some form 
of loan forgiveness. 

Education Is Preparing to Take Steps to Ensure It Can Provide Loans 
from Available Funds to Help Hurricane-Affected HBCUs Restore Their 
Campuses: 

According to Education officials, they are preparing to take the steps 
necessary to ensure that the department is prepared to provide loans to 
hurricane-affected HBCUs. Education officials noted that in light of 
the statutory limit on the total amount of loans it can make under the 
program and the balance of loans outstanding as of August 2006, about 
$141 million in funding is available for private, and $66 million for 
public, HBCUs--both those affected by the hurricanes and others. The 
officials noted that the department had not yet determined to what 
extent the Secretary would use her discretion to waive or modify 
program requirements, including the statutory loan limits. They told us 
that some of their next steps included determining how the program's 
application processes could be changed to ensure that funds can be 
provided to hurricane-affected schools in a timely manner. They said 
the department would need to consider to what extent it would apply 
credit criteria to hurricane-affected institutions in light of the fact 
that these institutions would likely be experiencing fiscal stresses as 
they seek to rebuild their campuses and attempt to return to their 
prior levels of enrollment. They noted that they would talk with school 
officials to gain a better understanding of which program criteria 
remain applicable, but anticipate using fewer credit criteria in their 
determinations. Education officials also noted that they will likely 
have to decide on the appropriate level of flexibility to exercise with 
respect to collateralizing loans for hurricane-affected HBCUs because 
some institutions may lack the collateral they had prior to the 
hurricanes. Moreover, these officials stated that the department would 
need to consider establishing limits on the types of projects for which 
it would provide funding to ensure that loans are not provided for 
capital projects for which other federal aid is available, such as that 
provided by FEMA. For example, program officials recognized that a 
significant cost of recovery for the schools in the Gulf Coast region 
is debris removal, but believe FEMA is likely to provide funding for 
such costs. Even with these challenges and outstanding questions, 
program officials said that they are confident the department will be 
able to lend funds to hurricane-affected institutions prior to 
expiration of the special legislative provisions applicable to 
hurricane-affected HBCUs. They noted that the department has already 
notified eligible institutions of the availability of funds and would 
hold additional meetings with schools to gain an understanding of their 
capital improvement and restoration needs. 

Conclusions: 

HBCUs play an important role in fulfilling the educational aspirations 
of African-Americans and others and in helping the nation attain equal 
opportunity in higher education. In establishing the Capital Financing 
Program, Congress sought to help HBCUs continue and expand their 
educational mission. The program has in fact assisted some HBCUs in 
financing their capital projects. Factors, however, including awareness 
of the program; clear, timely, and useful information concerning the 
status of loan applications and approvals; and certain loan terms and 
conditions, may be discouraging other schools from participating in the 
program. Some HBCUs have accessed even more attractive financing 
outside of the program, while yet others may face financial challenges 
that make it unwise to borrow through the program--factors that affect 
program utilization and make the development of program performance 
goals and measures challenging. Despite the challenge, Education is 
attempting to design performance goals and measures--a positive step 
that if successfully completed could be useful in informing Congress 
and others about the extent to which the program is meeting Congress' 
vision in establishing it. 

HBCU officials had a number of suggestions, such as changing the 
frequency of schools' loan repayments from a monthly to a semiannual 
basis, that they believed could improve the program and positively 
influence program utilization. By soliciting and considering such 
feedback from HBCU officials, Education could ensure that the program 
is optimally designed to achieve its objectives effectively and 
efficiently. However, Education has not made consistent use of the 
mechanism--the HBCU Capital Financing Advisory Board--Congress provided 
to help ensure Education received input from critical program 
stakeholders. Receiving feedback from schools would also allow the 
department to better inform Congress about the progress made under the 
program. 

Effective management control is essential to ensuring that programs 
achieve results and depends on, among other things, effective 
communication. Agencies must promote relevant, reliable, and timely 
communication to achieve their objectives and for program managers to 
ensure the effective and efficient use of resources. Effective 
management control also entails ensuring that an agency complies with 
applicable laws and regulations and that ongoing monitoring occurs 
during the normal course of an agency's operations. In failing to 
follow the requirements of the Federal Credit Reform Act, Education has 
overstated the budgetary cost of the program. Accurately accounting for 
the cost of federal programs is all the more important in light of the 
fiscal challenges facing the nation. Moreover, failing to adequately 
monitor the DBA's performance with respect to critical program 
responsibilities--record keeping, marketing, accounting, and 
safeguarding the federal funds it has been collecting from program 
borrowers--increases the program's exposure to potential fraud, waste, 
abuse, and mismanagement. 

Recommendations for Executive Action: 

To better ensure that the HBCU Capital Financing Program can assist 
these schools to continue and expand their educational missions, GAO is 
making the following five recommendations for Executive Action. To 
ensure that it obtains the relevant, reliable, and timely communication 
that could help ensure that program objectives are being met 
efficiently and effectively, and to meet statutory requirements, we 
recommend that the Secretary of Education regularly convene and consult 
with the HBCU Advisory Board. Among other things, the Advisory Board 
could assist Education in its efforts to develop program performance 
goals and measures, thereby enabling the department and the board to 
advise Congress on the program's progress. Additionally, Education and 
the Advisory Board could consider whether alternatives to the escrow 
arrangement are feasible that both address schools' concerns and the 
need to keep federal costs at a minimum. If Education determines that 
statutory changes are needed to implement more effective alternatives, 
it should seek such changes from Congress. 

To ensure program effectiveness and efficiency, we recommend that the 
Secretary of Education enhance communication with HBCU program 
participants by (1) developing guidance for HBCUs, based on other 
schools' experiences with the program, on steps that applicants can 
take to expedite loan processing and receipt of loan proceeds, and (2) 
regularly informing program applicants of the status of their loan 
applications and department decisions. 

In light of the program's existing credit requirements for borrowers 
and the funds placed in escrow by borrowers to protect against loan 
delinquency and default, we recommend that the Secretary of Education 
change its requirement that borrowers make monthly payments to a 
semiannual payment requirement consistent with the DBA's requirement to 
make semiannual payments to the FFB. 

To improve its estimates of the budgetary costs of the program, and to 
comply with the requirements of the Federal Credit Reform Act, we 
recommend that the Secretary of Education ensure that the program 
subsidy cost estimation process include as a cash flow to the 
government the surcharge assessed by the FFB and paid by HBCU borrowers 
and pay such amount to the program's financing account. Additionally, 
we recommend that the Secretary of Education audit the funds held by 
the DBA generated by this surcharge and ensure the funds are returned 
to the Department of the Treasury and paid to the program's financing 
account. 

To ensure adequate management control and efficient program operations, 
we recommend that the Secretary of Education increase its monitoring of 
the DBA to ensure its compliance with contractual requirements, 
including record keeping, and that the DBA is properly marketing the 
program to all potentially eligible HBCUs. 

Agency Comments: 

In written comments on a draft of this report, Education agreed with 
our findings and all but one of our recommendations and noted that our 
report would help it enhance the program and better serve the nation's 
HBCUs. Education agreed with our recommendation to regularly convene 
and consult with the HBCU Advisory Board and noted that the department 
would leverage the board's knowledge and expertise to improve program 
operations and that the department had scheduled a board meeting for 
October 27, 2006. Education also agreed with our recommendation to 
improve communications with HBCUs, noting that it would take steps 
including developing guidance based on lessons learned to expedite loan 
processing and receipt of proceeds, and regularly informing applicants 
of their loan status and department decisions. Moreover, Education 
agreed with our recommendation to improve its budget estimates for the 
program, indicating that it would work with OMB and Treasury to do so. 
Further, with regard to our recommendation that the department increase 
its monitoring of its DBA, the department stated that it would require 
the DBA to submit quarterly reports on program participation and 
financing, identify and locate missing loan documentation, and maintain 
these efforts for each subsequent loan disbursal. Additionally, the 
department said that it was planning to conduct an audit of the DBA's 
handling of loan funds and associated fees, as we recommended. 

With respect to our recommendation that would allow participating 
schools to make semiannual payments, Education said it would be 
imprudent to implement the recommendation at this time because of the 
potential for default as well as the exposure from a default by a 
current program participant. We considered these issues in the 
development of our recommendation and continue to believe that the 
credit evaluation performed by the DBA, the funds set aside by 
borrowers held in escrow, and the security pledged by borrowers provide 
important and sufficient measures to safeguard taxpayers against 
potential delinquencies and default. Further, while not noted in our 
draft report reviewed by the department, the law requires that 
borrowers make payments to the DBA at least 60 days prior to the date 
for which payment on the bonds is expected to be needed. In addition, 
borrowers have been required to submit, on an annual basis, audited 
financial reports and 3-year projections of income and expenses to the 
DBA. These measures provide additional safeguards as well as a 
mechanism to alert the department of potential problems. We added this 
information to our description of program terms and conditions in table 
1. 

Education also provided technical comments that we incorporated into 
this report where appropriate. 

As agreed with your offices, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from its issue date. At that time, we will send copies to the Secretary 
of Education appropriate congressional committees, the Director of OMB, 
and other interested parties. We will also make copies available to 
others upon request. In addition, the report will be available at no 
charge on GAO's Web site at [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7215 or AshbyC@gao.gov. Contact points for our 
Office of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff that made major contributions 
to this report are listed in appendix IV. 

Signed by: 

Cornelia M. Ashby: 
Director, Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: List of Historically Black Colleges and Universities GAO 
Interviewed: 

1. 
Alabama Agricultural and Mechanical University; 
Ala. 

2.  
Albany State University; 
Ga. 

3. 
Allen University; 
S.C. 

4. 
Barber-Scotia College; 
N.C. 

5.  
Bennett College; 
N.C. 

6. 
Bethune-Cookman College; 
Fla. 

7. 
Bowie State University; 
Md. 

8. 
Central State University; 
Ohio. 

9. 
Cheney University of Pennsylvania; 
Pa. 

10. 
Clark Atlanta University; 
Ga. 

11.  
Dillard University; 
La. 

12; 
Fisk University; 
Tenn. 

13; 
Florida Memorial College; 
Fla. 

14; 
Jarvis Christian College; 
Tex. 

15; 
Kentucky State University; 
Ky. 

16; 
Lincoln University; 
Pa. 

17; 
Livingstone College; 
N.C. 

18; 
Miles College; 
Ala. 

19; 
Norfolk State University; 
Va. 

20; 
North Carolina Agriculture and Technical State University; 
N.C. 

21; 
Saint Philip's College; 
Tex. 

22; 
Shaw University; 
N.C. 

23; 
South Carolina State University; 
S.C. 

24; 
Southern University at New Orleans; 
La. 

25; 
Tennessee State University; 
Tenn. 

26; 
Texas College; 
Tex. 

27; 
Tougaloo College; 
Miss. 

28; 
Tuskegee University; 
Ala. 

29; 
Philander Smith College; 
Ark. 

30; 
University of the District of Columbia; 
D.C. 

31; 
University of Maryland Eastern Shore; 
Md. 

32; 
Virginia Union University; 
Va. 

33; 
West Virginia State University; 
W.Va. 

34; 
Xavier University; 
La. 

Source: GAO. 

[End of table] 

[End of section] 

Appendix II: Number of HBCUs Eligible to Participate in Capital 
Financing Program by State (as of August 31, 2006): 

[See PDF for Image] 

Source: GAO data; Map Resources. 

[End of section] 

Appendix III: HBCUs Located in Geographic Area Affected by Hurricane 
Katrina in 2005: 

[See PDF for Image] 

Source: GAO data; map, U.S. Department of Commerce, Economics and 
Statistics Administration, U.S. Census Bureau. 

[End of section] 

Appendix IV: Comments from the Department of Education: 

United States Department Of Education: 
Office Of Postsecondary Education: 
The Assistant Secretary: 

OCT 2 2006: 

Ms. Cornelia M. Ashby: 
Director, Education, Workforce, and Income Security Issues: 
United States Government Accountability Office: 
Washington, DC 20548: 

Dear Ms. Ashby: 

Thank you for the opportunity to review and comment on the U.S. 
Government Accountability Office's (GAO) draft report entitled "Capital 
Financing: Department Management Improvements Could Enhance Education's 
Loan Program for Historically Black Colleges and Universities" (GAO-07-
64). We appreciate GAO's examination of this important program, and, in 
accordance with the draft report's recommendations, the Department of 
Education (Department) intends to take numerous steps towards 
strengthening the program's ability to serve the nation's Historically 
Black Colleges and Universities (HBCUs). 

The Department's increased leadership and oversight of program 
activities, including those of the Designated Bonding Authority (DBA), 
will ensure that the statutory requirements discussed in your report 
are met and enable us to better address the needs of prospective and 
current participants as they arise. As part of our effort to more 
closely monitor the DBA, the Department will require quarterly reports 
on the status of program participation and financing. 

In addition, plans are underway to retain an independent firm to audit 
the DBA during fiscal year (FY) 2007, at which time the handling of 
loan funds and associated fees will be assessed. 

The Department will leverage the knowledge and expertise of the HBCU 
Capital Financing Advisory Board (Board) by consulting the Board 
regarding how to maximize the value of marketing and outreach to the 
HBCU community. In addition, as required by the statute, we will 
convene Board meetings on a more regular basis. The next meeting has 
been scheduled for October 27, 2006. 

In order to increase program awareness among HBCU administrators, the 
Department will review and adjust promotion strategies to ensure that 
the program targets relevant administrators (i.e. facilities officers) 
at a diverse range of institutions (2-and 4-year, public and private). 
We must also identify the most effective means and sites of outreach, 
such as conference participation and school visits, and track the 
outcomes of these efforts. To support schools that have expressed 
interest or that appear to be strong candidates for the program, the 
Department will place greater emphasis on technical assistance in 
preparing and applying for program loans. 

Efforts will be made to simplify each stage of the loan process - 
including pre-application activities (e.g. obtaining property titles 
and financial statements), formal initiation of the process, and 
subsequent evaluation, decision, and negotiations - and to clearly 
convey this process in marketing materials and conversations with 
school administrators. Experiences of past borrowers will be studied to 
determine realistic time projections for each phase and to identify 
lessons that can be shared with new applicants. Throughout the process, 
the Department and the DBA will provide schools with clear and timely 
information regarding the status of their inquiries. Anticipated delays 
will be discussed with applicants as early as possible and monitored 
closely to minimize project delays and related cost increases. 

We recognize schools' frustration with the pooled escrow requirement 
described in your report; however, modifying this requirement would 
require legislative action. Given Congress' historical desire to limit 
program costs, it is unlikely that such a change will occur in the 
foreseeable future. Furthermore, while the Department understands 
institutions' preference for semi-annual rather than monthly payments, 
the potential for default, as well as exposure from the default of a 
current program participant, leads us to believe that it would be 
imprudent to implement a less frequent payment schedule at this time. 

As suggested in your report, the Department is in the process of 
revising its fiscal procedures to ensure that fees are accurately 
collected and recorded. The Federal Financing Bank fee should be held 
in the program's financing account, and we are currently working with 
the Treasury Department and the Office of Management and Budget (OMB) 
to incorporate the fee into the Department's cash flow model as part of 
our ongoing efforts to improve the estimates of the budgetary costs of 
the program. These changes should take effect early in FY 2007. 

In order to ensure the completeness of program files, the Department is 
working with the DBA to identify and locate any documents that are 
currently missing from program records, including property titles, loan 
applications, and decision memoranda. Future loans will be issued only 
when an applicant's file is complete, and a more diligent effort will 
be made to maintain those files following disbursement of a loan. 

To determine the program's effectiveness, the Department has begun to 
develop performance measures that will be implemented in FY 2007. Key 
stakeholders, including the Board, will be consulted during the 
development stage of this process. Looking forward, the Department will 
make certain that rigorous standards are used to measure the 
performance of both program staff and the DBA. 

Special attention will continue to be given to the implementation of 
emergency provisions related to the Gulf Coast hurricanes, as the 
Department works closely with affected HBCUs to support their recovery 
and rebuilding efforts. On September 27, 2006,1 visited New Orleans to 
discuss these provisions with HBCU administrators and to offer the 
Department's assistance in helping them access these funds in a timely 
manner. We are committed to working with these institutions to ensure 
that available resources are used to meet their critical needs, but we 
will remain vigilant about properly segregating and accounting for the 
various streams of funding that have been awarded to hurricane-affected 
schools to avoid duplication or misuse of funds. 

Once again, I would like to thank you for taking the time to research 
and report on the HBCU Capital Financing Program. Your findings and 
recommendations will be most helpful as we strive to enhance this 
valuable program. 

Sincerely, 

Signed by: 

James Manning: 
Acting Assistant Secretary: 

Enclosure: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contacts: Cornelia M. Ashby, Director, (202) 512-7215: 

Staff Acknowledgments: 

In addition to those named above the following individuals made 
important contributions to the report: Jeff Appel, Assistant Director; 
Tranchau Nguyen, Analyst-in-Charge; Carla Craddock; Holly Gerhart; 
Lauren Kennedy; Sue Bernstein; Margie Armen; Christine Bonham; Jessica 
Botsford; Michaela Brown; Richard Burkard; Carlos Diz; Kevin Jackson; 
Tom McCool. 

[End of section] 

(130466): 

FOOTNOTES 

[1] These are institutions recognized by the Department of Education as 
accredited institutions eligible for participation in federal student 
financial aid programs. 

[2] Schools we visited included Barber-Scotia College, Dillard 
University, Southern University at New Orleans, Tuskegee University, 
and Xavier University. 

[3] A total of 8 HBCUs were affected by the 2005 hurricanes. 

[4] For purposes of this program, the Higher Education Act of 1965, as 
amended, generally defines an HBCU as a college or university that was 
established before 1964, whose principal mission was and is the 
education of Black Americans, and is accredited or making reasonable 
progress toward accreditation by an accrediting agency or association 
recognized by Education. 

[5] Funds can also be raised through the private market. However, to 
date, Education has used only the FFB to finance the loans. 

[6] Education has had two DBAs. The current DBA, Commerce Capital 
Access Program Corporation, was selected by Education in 2001. The 
first DBA, selected in 1994 and terminated in 2000, was Educational 
Direct Loan Mortgage Company and Pryor, McClendon, Counts and Company. 

[7] "Present value" is the worth of future streams of returns or costs 
for a program in terms of money paid immediately. In calculating 
present value, future amounts are converted into their "money now" 
equivalents using a discount rate. The discount rate is determined by 
OMB and is generally the average annual interest rate for marketable 
zero-coupon U.S. Treasury securities with the same maturity from the 
date of disbursement as the cash flow being discounted. 

[8] That is, Hurricanes Katrina, Rita, and Wilma, which have been 
collectively referred to as the Gulf Coast hurricanes. 

[9] Four HBCUs in Mississippi and Alabama (Jackson State University, 
Alcorn State University, Bishop State Community College, and Hinds 
Community College-Utica Campus) also reported damages to property 
totaling $4.5 million. 

[10] (1) The Association of Higher Education Facilities Officers 
(APPA)/National Association of College and University Business Officers 
(NACUBO), The Decaying American Campus: A Ticking Time Bomb 1989, (2) 
APPA/NACUBO and Sallie Mae, A Foundation to Uphold, 1996, (3) U.S. 
Department of Commerce/National Association For Equal Opportunity In 
Higher Education (NAFEO), Historically Black Colleges and Universities: 
An Assessment of Networking and Connectivity, 2000, and (4) GAO, 
Historic Preservation: Cost to Restore Historic Properties at 
Historically Black Colleges and Universities, GAO/RCED-98-51, 
(Washington, D.C.: Feb. 6, 1998). 

[11] In 1998, HBCUs reported that an estimated $755 million was needed 
to restore 712 historic properties. See GAO/RCED-98-51. 

[12] About 29 percent of HBCUs we contacted reported that their own 
staff conducted their needs assessment, and the remaining schools 
reported that they relied on either an architectural or an engineering 
firm to perform such assessments. 

[13] Authorized under the National Historic Preservation Act of 1966, 
the National Register is part of a national program to coordinate and 
support public and private efforts to identify, evaluate, and protect 
our historic and archeological resources. Properties listed in the 
register are significant to American history, architecture, archeology, 
engineering, and culture. 

[14] Under the Internal Revenue Code, qualified education facilities, 
such as HBCUs, are permitted to issue tax-exempt bonds. In contrast to 
taxable bonds, tax-exempt bonds produce interest income that is exempt 
from federal taxation and may also be exempt from state and local 
taxation, especially if the owners live in the state in which the bond 
is issued. Because these investors do not pay taxes on their interest 
earnings, they are willing to accept a lower pretax rate of return on 
their investment, which lowers the financing costs for schools that 
issue such bonds. 

[15] Schools that issue bonds pay credit agencies, such as Standard & 
Poor's, or Moody's Investors' Service, to assess their potential risk 
of default. Credit agencies assign ratings for bonds reflecting a 
spectrum of highest to lowest credit quality to help investors 
determine the risk associated with investments. Ratings can generally 
be grouped into two larger categories--investment and noninvestment 
grades. 

[16] Bond insurance guarantees the payment of principal and interest on 
a bond issue if the issuer defaults. Credit rating agencies assign a 
bond rating based on the insurer's ability to pay claims against 
defaults, rather than on the underlying credit of the issuer. 

[17] Barber-Scotia College defaulted on its loan payments in September 
2005. The outstanding balance of the defaulted loan is about $7 
million. Funds to cover the school's delinquent payments were withdrawn 
from the school's escrow account. When the school's escrow account was 
depleted, the funds required to cover the school's subsequent payments 
were drawn upon a pro rata basis from each program participant's escrow 
account--schools with larger outstanding loan balances will have more 
money withdrawn from their escrow accounts than schools with smaller 
outstanding loan balances. 

[18] According to Education, escrow account funds are sufficient to 
make loan repayments on behalf of the defaulted borrower for up to 12 
years, provided no additional borrowers default on their loans. 
Education officials said they are attempting to maintain close contact 
with the defaulting school and offering to work with it to resolve the 
default. Since the school pledged its entire campus as collateral for 
the loan, Education could ultimately foreclose and sell it to recover 
loan proceeds. 

[19] Previously, refinancing was always coupled with a requirement that 
most proceeds be used for construction or renovation purposes, 
according to department officials. 

[20] 12 U.S.C. § 2285(c). 

[21] 2 U.S.C. § 661d(c). 

[22] A financing account records all of the cash flows resulting from 
direct loans or loan guarantees. It disburses loans, collects 
repayments and fees, makes claim payments, holds balances, borrows from 
the Department of the Treasury, earns or pays interest, and receives 
the subsidy cost payment from the credit program account. The credit 
program account receives and obligates appropriations to cover the 
subsidy cost of a direct loan or loan guarantee and disburses the 
subsidy cost to the financing account. 

[23] According to 31 U.S.C. § 3515, federal agencies are required to 
prepare and submit to OMB audited financial statements covering their 
operations. 

[24] The DBA has collected this fee from all but one borrower--West 
Virginia State University, which received a loan in 1996 prior to the 
requirement that Education collect the fee. 

[25] Several of the files had been compiled by a prior bonding 
authority. Nevertheless, the DBA is required under its contract with 
Education to maintain files on participants for the life of the program 
and a minimum of 6 years thereafter. 

[26] Officials also noted that the school had incurred additional 
costs, such as renting temporary space, architectural and legal 
services, and lost revenues, which collectively amounted to about $130 
million. 

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