Electronic Transfer of Funds (Policy 5.051)

Authority:	F.S. 215.85, 668, 1001.02, 1001.64, 1010.11
Date Adopted:	05/2013
Date of Review:	---

Definition

Electronic Funds Transfer (EFT) is defined as the transmission of an electronic message to a financial institution with instructions to make an electronic entry reflecting the transfer of ownership of funds from one depositor to another. EFT’s can be accomplished via the Automated Clearing House (ACH) or via wire transfer. Both are processed through an online banking software provided by the College’s banking partner.

Policy

The College will ensure that all electronic fund transfers are recorded in the College accounts and properly supported by bank documents, statements, or other electronic documentation as appropriate for the transaction. This may include documentation provided by the recipient payees if appropriate to correctly direct funds.

1. Electronic Fund Transfers Policy
   1. Direct Deposit: The College may make electronic payments to students, employees, and vendors at the payee’s documented direction. The College will employ standard controls for payments as with any other non-electronic payment. The College will maintain records of payees that have requested via their own manual signature or an electronic self-certifying directive online.
   2. Wire Transfers: Wire transfers may be recurring or one time payments directly from the College’s bank account. The College may be mandated to wire monies to certain entities for payments including but not limited to the State of Florida, retirement account vendors, and the Internal Revenue Service. In addition, to banking online controls, including encryption, tokens, passwords, and certificate protection, the College’s payments will:
      1. Be sent to pre-approved payees only by designated personnel with access to the online banking system, and
      2. Be approved by a second designated person.
         1. Payees are to be added as necessary and input by personnel designated by the Executive Vice President/CFO,
         2. Payees must have a second designated approver prior to their usage in the online banking.
   3. Withdrawals: The College does not maintain the ability to withdraw funds electronically, but may from time to time transfer between its own accounts within or among its own bank or investment accounts.
   4. Payments: Efficient use of payment systems are to be employed whenever practical. Usual and customary controls are to be in place similar to non-electronic payment transactions including approvals, and account allocations.
      1. The College will use the same self-directed payment information as noted in the Direct Deposit section of this policy.
      2. Bank accounts will be monitored at least weekly for unusual or unexpected transactions and reconciliations of banking activity to the General Ledger will be accomplished in a timely manner with investigation and resolution of reconciling items.
      3. The accounts will be reconciled monthly.
2. The President will develop detailed procedures to implement the controls noted above.