It is the policy of the Board of Education to develop, maintain and utilize clear, concise and detailed accounting for all financial transactions under its purview in accordance with the School Districts Accounting and Reporting Manual. To assist with this requirement, the District shall direct the Chief School Business Official to establish internal controls and procedures aimed at minimizing the risk for any error and/or misappropriation of funds related to banking services. The transferring of funds via online banking between various accounts and the transfer of funds from District accounts to non-district accounts shall be properly monitored by the Chief School Business Official or designee.
Online Banking: The Board will enter into a written agreement with its designated depository bank(s) for online banking and electronic or wire transfers, which includes the implementation of a security procedure for all transactions. The following individuals are involved in various online banking transactions: the District Treasurer, School Business Administrator, Chief School Business Official and the Deputy Treasurer. Each will have a separately established user name(s) and password(s), along with separate banking security tokens. These passwords will be updated regularly.
Electronic or Wire Transfers and Remote Depositing: Procedures will be developed and implemented specifying who is authorized to initiate, approve, transmit, record, review and reconcile electronic transactions. Limitations on the dollar amount of individual wires as well as limitations on the maximum dollar amount of wires, per day, will be set. At least two individuals will be involved in each transaction where funds are disbursed from a district account to an outside entity. Authorization and transmitting functions will be segregated. The four areas used by the District include:
A. Remote Depositing
B. Transfers between District Bank Accounts
C. Automated Clearing House (ACH) Transactions
D. Wire Transfer to Outside Organizations
Additional Security Measures: 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. Procedures will also include the corrective action plan should fraudulent activity be suspected.
Ref:
Education Law §2116-a
General Municipal Law §5-a
Policy Adopted: April 22, 2014
Reviewed: December 21, 2015