The transferring of funds via online banking services between various accounts and the transfer of funds from District accounts to non-District accounts, and vice versa, for various purposes, are financial transactions to be properly monitored and controlled.
The following are online banking activities the District engages in:
Viewing of bank account information
Interfund transfers
Remittance of employee payroll tax withholdings and other deductions
Paying of the District’s debt obligations
Remittance of employee payroll direct deposits
Transfer of District funds into investments
Receipt of revenues from various sources
Check issue verification
Remote depositing
Update of user information when necessary
Other online banking activities customarily found in commerce
The following individuals are involved in various online banking transactions: District Treasurer, Deputy Treasurer, Accountant, and Payroll Clerk. Each will have separately established usernames and passwords, as well as separate banking security tokens when applicable.
Procedures will be developed and implemented specifying the individuals authorized to initiate, approve, transmit, record, review, and reconcile electronic transactions. At least two individuals will be involved in each transaction where funds are disbursed from a District account to an outside entity. The employee who initiates the process for making the wire transfer or electronic fund transfer will not be the employee who confirms the transfer.
All wire transfers must be confirmed by the District Treasurer or Deputy Treasurer. Dual approval controls will be established for third party wire transfer or ACH orders. The District Treasurer and the Deputy Treasurer will have sole authority to approve and release all online banking transactions.
Each bank transfer will be recorded as a journal entry, cash receipt or cash disbursement showing the amount of funds and the purpose of the transferring of funds. The District Treasurer will be responsible for the proper accounting of the transactions. The District Treasurer will maintain a record of each wire transfer or electronic fund transfer entered into by the District and the recipient and amount of such transfer.
The District Accountant will have authority to utilize the check scanning machine to remotely deposit checks to District bank accounts. The District Accountant will maintain a record of each remote deposit noting the account into which funds were deposited, a detail of the checks deposited noting the check number and amount, and the total amount of the deposit.
Those records will be reviewed and signed by the District Treasurer. The District Treasurer, Deputy Treasurer, Assistant Superintendent for Business, and District Accountant will be established as Security Administrators for online banking. The Security Administrators will have the authority to change entitlements for each employee’s profile within online banking. The Security Administrator who initiates a change to an employee’s online banking profile will not be the same Security Administrator who approves the change to an employee’s online banking profile.
Procedures will be developed to strengthen controls over reducing the risk of fraudulent activities. These may include the use of Payee Check Positive Pay and ACH debit blocks and filters on high volume District accounts.
Ref: General Municipal Law § 5-a
Uniform Commercial Code § 4-A-201
Adoption date: September 12, 2022
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