A. Remote Depositing:
- Remote depositing encompasses the on-site depositing of payments to the district made by check or money order, to the districts’ depository bank accounts.
- The district maintains several on-site scanning stations which are each under the supervision of an assigned employee.
- On a regular basis, such checks/money orders are electronically transmitted, via secure websites, using appropriate security procedures to the districts’ bank accounts.
- Such checks/money orders are endorsed and properly secured and maintained for a minimum of three (3) months, at which time they are securely destroyed.
B. Transfer between District Bank Accounts:
- A transfer between district bank accounts is defined as the ability to transfer funds between Board approved bank accounts for the purpose of satisfying claims, paying employees and investing funds.
- Such transfers are processed by the School Business Administrator on an as- needed basis through the secured banking website using appropriate passwords. The District Treasurer provides oversight by daily monitoring of bank transactions. Further, on a monthly basis, the Claims Auditor reviews and approves of such transfers though her/his audit of all warrants.
C. Automated Clearing House (ACH) Transfers
- ACH transfers are defined as a more secure method of transferring funds to outside organizations. Though similar to wire transfers, ACHs are preferred due to additional controls developed by the districts’ banks.
- ACH transfers are initiated by the School Business Administrator on the secured banking website on an as-needed basis, after being approved by the Claims Auditor and/or Purchasing Agent. The District Treasurer/Deputy Treasurer reviews the proposed transfer and releases the transaction through the secured banking website.
- On a monthly basis, the Claims Auditor reviews and approves of such transfers though her/his audit of all warrants.
D. Wire Transfers to Outside Organizations (Debt Service Payments)
- The School Business Administrator will prepare the supporting documentation for the wire transfer of funds. The Treasurer/Deputy Treasurer will initiate the transfer per receipt of all supporting documentation using the secured banking website.
- The Chief School Business Official, will review the supporting documentation and authorize the wire transfer by signing the pending release wire statement.
- Both the Treasurer/Deputy Treasurer and Assistant Superintendent for Business, will log on to the on-line banking system and review the transaction and supporting documentation. The Chief School Business Official using an assigned token, will release the wire. In addition, and as a secondary security procedure, the bank will personally contact the Chief School Business Official as verificationthat the wire was legitimately executed; and written documentation of each transaction will be properly filed in the Business Office.
- The Claims Auditor will review the wire disbursement after the release of the wire as part of the cash disbursement review, as authorized by the NYS Comptroller.
A. Additional Security Measures Procedures
The District shall:
- utilize Payee Check Positive Pay on our General Fund and Payroll checking accounts in an effort to reduce the risk of fraudulent activities.
- implement ACH debit block on our General Fund money market account and ACH debit filters on high volume checking accounts.
- utilize ACH and Payee Check Positive Pay daily email notifications for exceptions on checking accounts (Payroll and General Fund)
- establish wire transfer limits.
- establish wire transfer for call back provision with bank.
- use a dedicated computer for online banking.
- strive to provide:
- updated network security with high level internet security and firewall protection
- updated PC and email security
- updated anti-virus software
The Treasurer shall:
- review accounts daily to identify unauthorized ACH debits.
- monitor/review encrypted files for banking non-check disbursements.
- review use of repetitive ACH/wire payment templates to prevent unauthorized modifications to keyfields, such as beneficiary information.
- immediately notify the Bank’s Government Banking Team if potential fraud is detected on any account. The Government Banking team will take measures to secure the District’s accounts which could include the immediate securing or closing of accounts, or suspending the District’s online banking. Should this occur, the Treasurer will also notify all individuals involved with online banking transactions (Assistant Superintendent for Business, School Business Administrator, and Deputy Treasurer), as well as the Superintendent of Schools.
The Business Administrator shall:
- set authorization rights for each online banking user.
Adopted: April 22, 2014
Amended: December 21, 2015