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HomeMy WebLinkAboutElectronic Banking Policy TOWN OF ITHACA ELECTRONIC BANKING POLICY I. PURPOSE The Town Board recognizes the use of various electronic banking transactions as a faster, easier, and more efficient substitute for paper transactions. Electronic banking uses computer and electronic technology to streamline the processing and recording of receipts and disbursements, while reducing thecost of processing these transactions. Receipts, disbursements, and transfers in proper circumstances canbe processed via electronic funds transfer (EFT) services, whether transferring funds from a savings to achecking account at the same bank or making a payment to a vendor's bank across the country. Internal controls, such as written policies and procedures, authorizations, segregation of duties and monitoring, however, are still important in the new technological world. The Town Board shall authorize the Finance and Human Resource Offices to engage in electronic banking in accordance with all applicable laws and regulations including General Municipal Law Section 5-a authorizing the use of electronic or wire transfers and in conformity with the guidelines established by this policy. The Town Board also recognizes that most banking institutions no longer provide cancelled paper checksto their customers, but instead offer an electronic image obtained online or on a CD. As such, the Town Board authorizes the acceptance of these electronic images in lieu of cancelled checks as required by statute. II. SCOPE/SERVICES Electronic banking activities will be used for,but not limited, to the following: 1. Online banking services (reviewing account balances, retrieving bank statements, downloading copies of cancelled checks, making stop payment orders, etc.) 2. Check fraud prevention services (Positive Pay—Tompkins Community Bank) 3. Electronic depositing of checks received 4. Pre-authorized debit payments 5. ACH vendor payments 6. ACH payroll direct deposit 7. ACH Water& Sewer automatic payments 8. EFT or wire transfers 9. Electronic Federal Tax Payment System (EFTPS) 10. Electronic State Tax Payment System (Prompt Tax) Adopted 2022-05-23 Page 1 of 3 Online Banking Services are recognized as standard practice and procedure for maintaining an effective cash management program. Access to any of the Town's online bank accounts will be managed by the Finance Officer to allow other users restricted access as necessary for banking functions as needed. The Finance Officer will utilize a separate, limited access account for daily online banking. The super user/admin account will be reserved for account administration purposes. (Examples of daily online banking functions include monitoring account balances, positive pay functions, retrieving copies of cancelled checks, etc. Examples of account administration would be adding authorized users, adding/deleting permissions, adding wire beneficiaries, etc). Check Fraud Prevention Services — To help protect against the threat of check fraud, a file of all Accounts Payable cash disbursement payments made by paper checks will be uploaded to the bank's positive pay system. This process provides details about checks the Town has written ad compares that information to checks being processed to the bank for payment. The Town is notified by the bank of any exceptions by 8:00 a.m., these exceptions will be decisioned by the Finance Officer or Bookkeeper by noon. The benefits include reducing the risk of check fraud by providing the Town with the ability to monitor and control checks presented against any Town account so only authorized items are paid. Electronic Funds Transfers (EFT's) and wire payments can only be initiated by the Finance Officer, Human Resource Manager, or Bookkeeper. All EFT's and wire payments require dual authorization by either the Human Resource Manager, Bookkeeper, or Finance Officer. An email and text will be sent by the bank notifying the Human Resource Manager,Bookkeeper and Finance Officer that there is a payment pending approval. Someone (other than the initiator) must log in to Treasury Management before 3:00 p.m. to authorize the payment. The recording of such transactions will be captured manually by the Bookkeeper using journal entries. Dual approvals are required for any transaction with an end recipient not a Town of Ithaca account or in a different financial institution. Electronic wire transfers to foreign banks are not enabled in Treasury Management. ACH Vendor Payments are authorized by the Finance Officer or the Human Resource Officer after standard payment process recording through the abstract cycle and auditing process. Recording of ACH vendor payments will be the responsibility of the Bookkeeper through the standard posting of cash disbursements journal(s). All payments made through this process are subject to the same claims audit process as exists currently with paper drawn checks. Releases of payments are made by the Finance Officer only after the completion of the approval and claims auditprocess. Pre-authorized ACH Payments are authorized by the Human Resource Manager and/or Bookkeeper and are restricted to payroll related deduction payments to authorized third party administrators of the Town. Any such ACH payments must be taken from the payroll bank account. All ACH payments require dual authorization by either the Human Resource Manager, Bookkeeper, or Finance Officer. Recording of such transactions will be by the Bookkeeper using journal entries. Adopted 2022-05-23 Page 2 of 3 Revenue Collection 1. Electronic Deposit of Checks by means of utilizing a secure remote deposit device (provided by the bank) for checks received are authorized as delegated by the Finance Officer. The use of a remote deposit capture device helps improve security, efficiency, and cost effectiveness of making deposits. Recording of such deposits will be the responsibility of the Bookkeeper through the standard posting of the cash receipts journal. The Clerk's office will provide a monthly cash receipt report with the Supervisor's payment. 2. Electronic payments received from customers are acceptable and will be recorded by the Bookkeeper through the regular cash receipts transaction journal. Automatic ACH payments for Water and Sewer invoices will be authorized in writing by the customer. III. SAFEGUARDS AND BEST PRACTICES All banking transactions for the Town will be conducted on a Town computer with a secure internet connection. Town computers employ two-factor authentication and password complexity requirements. Employees will: • Type the bank's website address into the internet browser's address bar every time because email and search engine links may not be secure. • Check that the session is secure before undertaking any online banking. • Log out of all banking websites and close the browser window. • Erase the web browser cache,temporary internet files,cookies and history after each online banking session so that if the system is compromised, that information will not be on the system to be stolen by an attacker or malware program. • Never access the bank's website from a public computer, unprotected mobile device or public WIFI (i.e. Starbucks, hotel, etc). • Always use the Town's virtual private network (VPN) when accessing the bank while working offsite. IV. MONITORING The Finance Officer is responsible for implementing adequate internal controls for each of the electronic banking methods utilized. An effective internal control system includes, but is not limited to, segregation of duties, proper authorization, monitoring bank accounts daily for unauthorized or suspicious activity, and adequate documentation for all electronic transactions. Adopted 2022-05-23 Page 3 of 3