I. OBJECTIVE & PURPOSE
This policy sets forth the University's written policies prescribing the accounting and control procedures under which any funds under its control are allowed to be moved by electronic funds transfer for any purpose, including direct deposit, wire transfer, withdrawal, or investment.
Electronic Funds Transfer ("EFT") is defined as the transmission of an electronic message to a financial institution instructing it to make an electronic entry reflecting the transfer of ownership of funds from one depositor to another.
III. STATEMENT OF POLICY
The University of North Florida, Board of Trustees (the "Board") has delegated to the President of the University the authority to operate and administer the University in accordance with applicable law, and with the resolutions, regulations and policies of the Board and of the Board of Governors of the State University System and has also delegated to the President, the Vice President and Associate Vice President for Administration and Finance, the University Controller and Assistant Controller, and the University Treasurer the specific authority to perform banking transactions.
The Office of Treasury is responsible for the daily management of University bank balances and the general oversight of EFT activity and ensuring appropriate accounting and control procedures are in place. Additionally, the University Treasurer may periodically designate staff authorized to initiate or approve EFTs on behalf of the University.
EFT can be accomplished via the Automated Clearing House ("ACH") or wire transfer. ACH is the University's preferred mechanism, but wire transfer is acceptable when conditions do not support the use of ACH. Except in rare circumstances, both ACH and wire transfers are processed through on-line banking software provided by the University's banking partner.
- The procedure to initiate an EFT is subject to the same financial policies, procedures, and controls that govern disbursement of University funds by any other means.
- EFT transactions will not be made without proper authorization of affected parties in accordance with applicable law and regulations and accepted business practices.
- The University will provide to the disbursing bank the names of persons authorized by the University to initiate wire transfer requests (authorized representatives), as well as associated transfer limits.
- All EFTs should be initiated by computer-based systems. Phone transfers should be used only as back-up in an emergency. Phone transfers, except for transfers between University accounts, will require approval by an authorized representative other than the initiator.
- The mechanism by which EFT requests are communicated to the disbursing bank will have adequate controls to prevent unauthorized access to both the system and to its various functionalities. These controls should include password protected user accounts, Personal Identification Numbers (PINs), and a designated security administrator role. The Treasurer shall ensure that adequate separation of duties exists in accordance with accepted internal control standards and will protect the integrity of system user profiles. This includes assigning system IDs to users, changing user IDs as necessary, and assisting users with technical problems related to the EFT system. In addition, the Treasurer will assign access to functions to users and is authorized to lock out personnel.
- Requests for the electronic transfer of funds, other than repetitive transfers, require approval by an authorized representative other than the initiator. In no case will an individual have the capability to initiate, approve, and record a non-repetitive EFT to the general ledger.
- Where EFT's are recurring, the Treasurer will initiate the establishment of a template with receiving and disbursing bank information that may not be altered by those assigned to its use. The set-up of and modifications to these templates will require the two authorized University personnel.
- Bank transactions will be monitored daily for unusual or unexpected transactions.
- Reconciliation of banking activity to the general ledger will be accomplished in a timely manner with investigation and resolution of reconciling items.
This policy is adopted pursuant to the requirements of Section 1010.11, Florida Statutes.