Internal Control Procedures

(DRAFT APPROVED BY THE TREASURER AND THE COUNSEL)  

[Download a pdf version of this document] 

1. BANK ACCOUNTS  

1.1. Policies

a) Approval of the Board of Directors (BOD) and the President of the Foundation is obtained when opening new accounts. A copy of the Board enacted resolution designating authorized signers shall be forwarded to the bank in a timely fashion.

b) Any changes in authorized signatories are forwarded in writing to the bank using a corresponding corporate resolution and signature verification card.

c) Any bank account not being used is closed by written notice to the bank. Unused checks relating to a closed account are destroyed at the time of the account closing

d) As two signatures are required for each check or withdrawal, the BOD should authorize 4 persons to sign checks to include the President, Executive Director and the Treasurer of the Foundation. The 4th person could be a non board member.  

1.2. Bank Statements Procedures

a) Monthly bank statements are received unopened and reviewed by President of the Foundation, the primary check signor and the Treasurer. The Treasurer examines all checks to ensure each one is proper and properly signed. Also any other withdrawals from the account are reviewed and deposits are noted as well.

b) Each month the bank statement is reconciled to the general ledger using QuickBooks software by the Financial Manager (Financial Manager). Outstanding items (checks or deposits) are reviewed with Financial Manager and the President of the 2 Foundation and, if appropriate, action is taken as soon as possible.

c) Any adjustments to the general ledger and checkbook identified through the reconciliation are authorized by the President of the Foundation or the Treasurer and prepared promptly by Financial Manager.

d) An on-line access is established for accounts at Citibank Bank. Only the Treasurer and Financial Manager has access through a secured password process. Activities allowed by this process are review of current transactions (like an on-line bank statement), transfer of funds between EIF accounts (checking & savings) and domestic/international wire transfers only as authorized by BOD.  

2. CASH TRANSACTIONS  

2.1 Cash Receipts

a) The Financial Manager opens the mail and keeps a chronological log listing each check received.

b) Checks for deposit are passed on to the Financial Manager. Every check is photocopied, fitting as many checks as reasonable onto each page. Budget account to be credited (general, gala, book purchases, etc) should be indicated on each copy. Any restrictions required by the donor should be noted on the copy as well. The checks are batched for deposit and stamped “for deposit only” and taken to the bank by the Financial Manager.

c) For any Cash received (as opposed to checks), the Financial Manager should receive a written memo with responsible staff person’s signature as to nature of cash payment. This memo should also be attached to deposit receipt (above).

d) All deposits are made to Citibank Bank checking account. After making the bank deposit the Financial Manager staples the bank receipt to the appropriate photocopies. The completed batch is passed to the President of the Foundation who reviews each batch. Then Financial Manager enters the data into the QuickBooks system and then files each batch chronologically in a 3 ring binder.  

2.2. Cash Disbursements  

2.2.1 Policies

a) Every financial transaction such as a check and wire transfer requires a supporting document. This is usually a vendor invoice but can also be a staff memo requesting payment. Generally payment should be made from original invoices, not be made from statements or invoice copies. Upon payment every supporting document should be marked “Paid” with indication of check number, date paid, etc.

b) All checks require the signature of two Board appointed persons. These authorized persons do not maintain accounting records or control cash.

c) After the checks are signed they are returned to the Financial Manager, who mails them to the vendors and files supporting documents alphabetically, by vendor.

d) Both the President and the Treasurer have the authority to make single purchases of non-budgeted items up to $10,000 without Board approval. Any such transactions are to be reported at the next meeting of the Board and via an email addressed to the Chairman of the Board at the time of purchase.  

2.2.2. Procedures

a) When invoices are received, they are forwarded to the responsible staff person to review and approve for payment. Approved invoices and check requests are forwarded to Financial Manager who reviews each invoice for staff approval, mathematical accuracy, etc.

b) Financial Manager writes and presents check(s) with all attached documentation for signature. Signed checks are retuned to Financial Manager. Financial Manager mails checks and files supporting docs alphabetically.

3. PAYROLL

Payroll is calculated by Financial Manager based on approved salaries by the President of the Foundation. Financial Manager also prepares quarterly and annual payroll tax returns/reports. Financial Manager writes payroll checks as well as payroll taxes to the IRS and NY State each month. The Treasurer maintains a personnel file for every employee containing documentation concerning the following: letter of hire, position within the organization, job changes, rates of pay, disciplinary actions, commendations, terminations and all authorizations for deductions.  

4. ENDOWMENT FUND  

4.1. DESCRIPTION AND POLICY

a) “Prudent Investment Policy” To be written by The Finance Committee and approved by the BOD.

b) The President, the Executive Director, and the Treasurer of the Foundation are authorized, on behalf of the BOD, to sign all transactions of the Endowment with approval of the BOD. Any changes in authorized signatories are forwarded in writing to the broker of the Endowment using a corresponding corporate resolution and signature verification document.  

4.2. PROCEDURES

4.2.1. Withdrawal: Appropriations from the Endowment Fund may only be made by action of the BOD and the President of the Foundation.

4.2.2. Investment Monitoring: The portfolio shall be reviewed by the investment broker and the President of the Foundation at least monthly. The Finance Committee shall review the Investment Fund statement(s) monthly. The investment broker shall review the portfolio performance with the Finance Committee at least annually during the Association’s third fiscal quarter.  

5. REPORTING

Reporting is a key part of internal control. A regular financial report (minimum quarterly) is prepared by the accountant for the President of the Foundation and the Finance Committee. This report includes a Statement of Financial Position (Assets & Liabilities) as well as statement of Revenue & Expenses. In addition to current status reports include prior year audited data and current approved budget. Each year Financial Manager, working jointly with the Executive Director and Treasurer will prepare a draft budget prior [how long in advance? 45 days?] to the start of each fiscal year for EIF to be approved by the BOD. The BOD for the annual audit shall engage an independent auditor each year. The Financial Manager and accountant are responsible for preparing for the annual audit and assisting with process as required.  

CONFLICT OF INTEREST POLICY AND CODE OF ETHICS

The Foundation will adopt Columbia University’s Code of Ethics and Conflict of Interest Policy.