Responsible Executive: Finance and Administration

Approving Official: Vice President for Finance and Administration

Effective Date: January 1, 2014

Revision History: August 21, 2017 (Formatting only)

1. INTRODUCTION
   1. OBJECTIVE
      1. The purpose of this policy is to prescribe the control and accounting procedures under which any funds under the University’s control are allowed to be moved by electronic transfer for any purpose including direct deposit, withdrawal, or payment.
   2. RESPONSIBILITY
      1. The Controller’s Office is responsible for the daily management of the University cash balances and the general oversight of Electronic Funds Transfers (EFTs).
   3. DEFINITIONS
      1. Electronic Funds Transfer (EFT) – The exchange or transfer of money electronically from one account to another, either within the same enterprise or across different enterprises. Examples of EFTs include Automated Clearing House (ACH) transfers and Wire transfers.
         1. ACH Transfer – A method of electronic funds transfer processed through the Automated Clearing House. The transfer may take 1 to 3 days to complete but is less costly than a wire transfer.
         2. Wire Transfer – A method of electronic funds transfer from one bank account to another. The transfer usually occurs within hours to complete but is more costly than an ACH transfer.
            • Non-repetitive wire transfer – Wire transfers for which all the beneficiary information is entered each time a wire is initiated.
            • Repetitive wire transfer – The receiving bank account information is established in a template and the only information that changes is the amount of the transfer. Repetitive wire transfers are used when funds are sent to the same party on an ongoing basis.
2. POLICY
   1. CONTROL PROCEDURES
      1. To promote the safety of University funds in the electronic funds transfer environment, the following procedures will be adhered to:
         1. The procedure to initiate, approve, and record an EFT payment is subject to the same financial policies, procedures, and controls that govern disbursements made by any other means.
         2. EFT transactions will not be made without proper authorization of affected parties in accordance with federal and state statutes and accepted business practices.
         3. The University Controller will authorize individuals to initiate wire transfer requests as well as associated transfer limits.
         4. All EFT payments should be initiated by secure computer-based systems. Phone transfers will only be used if approved in advance by the Controller or another authorized representative other than the initiator.
         5. The mechanism by which EFT payment requests are communicated to the disbursing bank will have adequate controls to prevent unauthorized access. These controls should include password protected user accounts, Personal Identification Numbers (PINs) and a designated administrator.
         6. The University Controller will designate a primary administrator to manage and control access to the systems used to process EFT transactions. The administrator shall ensure that adequate separation of duties exists in accordance with accepted internal control standards. In addition, the administrator shall ensure approval and maintenance of user system IDs, user permissions, including authorized representatives and their associated transfer limits.
         7. The person who initiates an EFT payment cannot approve or release the associated non-repetitive wire transfer or record the transaction to the General Ledger.
         8. Because EFT transfers between University bank accounts have reduced risk, the Controller’s Office may use EFTs on a routine basis to concentrate funds for payment and investment purposes. Although the risks are minimal for transfers between University accounts, reasonable controls should exist with regard to authorization, reconciliation, and review of these transactions.
         9. For EFT payments that are recurring, the administrator will coordinate the establishment of a template with receiving and disbursing bank information that may not be altered without the approval of two authorized university signatories.
         10. Bank activity will be monitored daily for unusual or unexpected transactions.
         11. Reconciliation of bank activity to the General Ledger will be performed in a timely manner with all exceptions resolved.
3. LEGAL SUPPORT, JUSTIFICATION, AND REVIEW OF THIS POLICY
   1. Section 1010.11, Florida Statutes
   2. This policy shall be reviewed by the Associate Vice President for Finance & Administration (AVP) every seven years for its effectiveness. The AVP shall make recommendations to the Vice President for Finance and Administration for any modification or elimination.