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MARICOPA COUNTY INTERNAL POLICY Policy Number: A2512 Policy Title: Current Adoption 02-13-2019 ELECTRONIC FUNDS TRANSFER (EFT) Date: Current 02-13-2019 Implementation Date: Approved by: Board Agenda C-18-19-004-6-00 Number: BOARD OF SUPERVISORS Original Adoption Date: 10-19-2011 I. PURPOSE To establish procedures and overall responsibilities regarding the appropriate usage of EFT payments made outside of the County’s Financial (Accounting) system which may include Automated Clearing House (ACH) or direct Wire Transfers. It is the County’s policy to limit the use of EFT payments whenever possible. Payments made through the County’s Financial (Accounting) System are referred to as Accounts Payable EFTs and are the preferred method. II. AUTHORITY Arizona Revised Statute §11-493.4 requires the County Treasurer’s Office (Treasurer’s Office) to disburse County money: 1) by warrant that is issued by the County Board of Supervisors and that is signed by the chairman and the clerk of the board, 2) by electronic transfer with written authorization from a person designated by the governing board, or 3) as provided by law. III. APPLICATION This Policy applies to all Maricopa County appointed departments as well as the Flood Control District of Maricopa County, the Maricopa County Library District, and the Maricopa County Stadium District (Special Districts). The Board of Supervisors is authorized to jointly adopt policies applying to the Special Districts under the Intergovernmental Agreement, C-06-18-393-6-00, approved on April 11, 2018. This policy also applies to employees of County elected and judicial branch offices unless the elected official has implemented a similar policy specific to his or her office. IV. DEFINITIONS A. Accounts Payable EFT: A method of payment (see D below) which serves as an alternative to the issuance of a warrant and which is processed by the Department of Finance, Accounts Payable Division, in much the same manner as a warrant. B. Automated Clearing House (ACH) – A method of EFT from the County to another entity (such as a vendor, bank or other government agency). ACH transactions require 24-48 hours advance notice. ACH payments to vendors for goods or services can be initiated by Departments through the County’s Financial (Accounting) System or can be processed directly by the Treasurer’s Office. ACH is the preferred method of payment for all EFT payments requested by Departments as they are the least costly. ACH payments are assigned a settlement date, therefore, they can be initiated in advance of a specific pay date. For internal control purposes, County dual control procedures are required to initiate an ACH payment. C. Department – For the purpose of this policy, “Department” refers to any division of the County including elected and judicial branch offices and Special Districts. Policy Title: Policy Number: A2512 ELECTRONIC FUNDS TRANSFER (EFT) Current Adoption Date: 02-13-2019 D. Electronic Funds Transfer (EFT) –The electronic exchange or transfer of money from one bank account to another, either within the same bank or different banks. There are various and different types of EFTs, but for purposes of this policy, EFTs will refer to electronic transfer of funds by ACH or Wire Transfer. E. Journal Voucher (JV): An internal County document used to process and record transactions in the County’s Financial (Accounting) System. The JV contains vital accounting string codes which are used to post to specific Funds, Departments, Units, Activities, Balance Sheet Accounts and/or Revenue/Expense object codes as indicated on the document. F. Wire Transfer – A method of EFT from the County to another entity (such as a vendor, bank, or other government agency). A wire transfer is made from one bank account to another bank account, either within the same bank or different banks. Wire transfers are processed by the County Treasurer’s Office when same day credit of funds are required. Wire transfers are the quickest and most costly method of money movement. For internal control purposes, County dual control procedures are required to initiate a wire transfer. A. Background Under normal circumstances, expenditures should be paid by using the County’s Financial (Accounting) System thereby recording the transaction(s) directly to the general ledger. Such payments are made by Accounts Payable EFT or warrant, depending upon vendor registration selections. Utilizing the Financial (Accounting) System is the preferred method of recording transactions as this facilitates: 1. Automatic tracking and reporting of transactions, as further defined below, 2. Auditing of transactions by internal and external auditors, 3. Uses existing and established internal controls over the accounts payable process, and 4. Provides a greater level of transparency. Financial (Accounting) System – automatic tracking and reporting of transactions include, but are not limited to: 1. Grant expenditure transactions are tracked for Federal and State grant reporting purposes including the annual reporting under the Schedule of Expenditures for Federal Awards (SEFA). 2. Capital expenditure transactions are tracked for Construction in Progress and the Capitalization of Capital Facilities and Capital Projects. 3. Contractual expenditures are tracked to ensure compliance with the contract award. 4. Facilitates the request for public record requests as the transactions and supporting documentation are posted to the Financial (Accounting) System and imaged in OnBase. 5. Transactions posted to the Financial (Accounting) System ensure proper annual reporting of IRS Form 1099 (Misc. Income), as applicable. EFTs processed by the Treasurer’s Office, as opposed to those processed through the County’s Financial (Accounting) System, are posted by Departments to the Financial (Accounting) System by Journal Voucher (JV) which may not capture all the information as required above. V. POLICY A. Accounts Payable EFTs are the County’s preferred method for processing EFT payments as they utilize the County’s Financial (Accounting) System to record the transaction(s) directly to the County’s general ledger. Such payments are easily processed by the Department of Finance, Accounts Payable Division, so long as the vendor registration is properly established in the accounting system. Accounts Payable EFTs facilitate: Page 2 of 5 Policy Title: Policy Number: A2512 ELECTRONIC FUNDS TRANSFER (EFT) Current Adoption Date: 02-13-2019 1. The auditing of transactions by internal and external auditors, 2. The use of existing/established internal controls over the accounts payable process, 3. A greater level of transparency, and 4. Automatic tracking and reporting of transactions, such as: a. Tracking of grant expenditure transactions for Federal and State grant reporting purposes including the annual reporting under the Schedule of Expenditures for Federal Awards (SEFA). b. Tracking of capital expenditure transactions for Construction in Progress and the capitalization of Capital Facilities and Capital Projects. c. Tracking of contractual expenditures to ensure compliance with contract awards. d. Easier management of public record requests as the transactions and supporting documentation are posted to the Financial (Accounting) System and imaged in the system. e. Proper annual reporting of IRS Form 1099 (Misc. Income), when applicable. B. By contrast, EFT payment requests processed directly through the Treasurer’s Office are not automatically recorded in the County’s Financial (Accounting) System and require the processing of a separate journal voucher in order for the transaction to be properly reflected in the general ledger. Therefore, when choosing to process an EFT payment directly through the Treasurer’s Office, Departments should bear in mind that these transactions should: 1. be infrequent in nature, 2. require immediate and/or guaranteed funds, 3. and generally carry a negative consequence if payment is not made by a certain date. C. Examples of some EFT transactions which may be processed directly by the Treasurer’s Office include, but are not limited to, the following: 1. Debt service payments for long-term obligations. 2. Payments to escrow agent/title company for the purchase of real property. 3. Payments requiring same-day settlement. D. When requesting EFTs directly through the Treasurer’s Office, Departments must: 1. Obtain Board of Supervisors’ (Board) authorization and approval to initiate and request EFT payments from the Treasurer’s Office on an annual basis. This is achieved by submitting a Board Agenda item which, at minimum, must contain the following information: a. A formal request for approval and a description of the purpose(s) and frequency of the EFTs, b. The annual dollar amount(s) or range(s) (if the exact amount is unknown) of the EFTs, c. Identification of the individuals who are authorized by the Department to initiate Treasurer’s Office EFTs. Authorized individuals may include the Director, Deputy Director, Manager, or other individuals deemed to have the capacity to authorize the transaction, and Page 3 of 5 Policy Title: Policy Number: A2512 ELECTRONIC FUNDS TRANSFER (EFT) Current Adoption Date: 02-13-2019 d. The number of authorized individuals needed to initiate or approve the Department’s EFT request. At a minimum, two authorized individuals are required. 2. Upon receipt of Board approval, submit the following to the Treasurer’s Office (items may be scanned and sent via email to wire.transfer@mail.maricopa.gov): a. Board agenda item approving and authorizing the Department and individuals initiating EFTs, b. An original document prepared on Department letterhead requesting the EFT and signed by the authorized individuals and including the following information: i. Department responsible for the expenditure, vendor invoice, statement, support, etc. indicating the amount and due date and ii. EFT instructions necessary to process the transaction. (i.e., bank account information, etc.) c. If the items mentioned in 2a and 2b are not properly approved and complete, the Treasurer reserves the right to deny EFT payment. Additionally, the Treasurer’s Office requires 24-hour advance notice for processing of EFT wire payments. 3. Upon completion of EFT payment, Departments must prepare and process a corresponding journal voucher (JV) to recognize the transaction in the County’s Financial (Accounting) System. The JV must be processed in the same accounting period as the EFT. It is critical that accurate and complete information be provided within the JV document to ensure that tracking and reporting processes are not compromised. VI. EXAMPLES THE FOLLOWING EXAMPLES ARE FOR REFERENCE ONLY AND NOT CONSIDERED PART OF THE EFT POLICY. AS SUCH, THE EXAMPLE OF AGENDA ITEM LANGUAGE MAY BE PERIODICALLY UPDATED WITHOUT BOARD APPROVAL. A. Example of Annual Board Agenda Item for Frequent EFT Requests Pursuant to Electronic Fund Transfer Policy (A2512), the <insert Department Name> is requesting authorization to have the Treasurer’s Office process Electronic Funds Transfers for the annual Debt Service payments due to the Trustee in the amount of $XX million in Fiscal Year 20XX. The payments have been budgeted. The debt service payments are typically due on January 1st and July 1st of each fiscal year. <insert Department name> request for authorization to the Treasurer’s Office will come from the Chief Financial Officer, <insert authorized personnel>, and the Deputy Finance Director, <insert authorized personnel>. Debt Service payments require guaranteed funds. The Department will prepare a corresponding journal voucher to record the EFT transaction on the County’s Financial (Accounting) System in the same accounting period as the EFT. B. Example of Board Agenda Item for a Single/One-time EFT Request Pursuant to Electronic Fund Transfer Policy (A251), the <insert Department name> is requesting authorization to have the Treasurer’s Office process an Electronic Funds Transfer for $XX million as an escrow payment to the trustee for the purchase of real property <insert description>. The payment has been budgeted. It is anticipated that the escrow payment will be paid in December 20XX. Departmental request for authorization to the Treasurer’s Office will come from the Chief Financial Officer, <insert authorized personnel>, and the Deputy Finance Director, <insert authorized personnel>. Escrow agent requires Page 4 of 5 Policy Title: Policy Number: A2512 ELECTRONIC FUNDS TRANSFER (EFT) Current Adoption Date: 02-13-2019 guaranteed funds. The Department will prepare a corresponding journal voucher to record the EFT transaction on the County’s Financial (Accounting) System in the same accounting period as the EFT. C. The Board Action may require additional information depending upon the action being requested. D. Example of Departmental Letter Requesting a Treasurer’s Office ACH/Wire Transfer Letter to be put on Departmental Letterhead DATE: December XX, 20XX TO: Maricopa County Treasurer - <insert name of personnel responsible> FROM: <Department Authorized Individual(s) as approved by the Board of Supervisors> SUBJECT: Request for ACH/Wire Transfer (Department to indicate transaction type) Per the attached Board approved agenda, I am requesting that you process an (ACH/Wire Transfer) payment for $XX,XXX.XX due on (date required). The payment is for (identify purpose of payment). Also attached is the (invoice, statement, letter or other form of communication) as support for the payment. Listed below are the EFT transfer instructions for the outgoing payment. Name of Bank, Trust Agent, etc. ABA #: (Bank Routing Number) Account Name: Account Number: Reference/Description: used for tracking purposes For accounting purposes, monies will come from Treasurer’s Fund 3X-XXX-000. (Treasurer Fund represents the Fund in which the expenditure will be paid from) Please call (Department Contact) at (602) 506-XXXX if you have any questions. Revision History Version Revision Date Description of Revision 1 10/19/2011 Initial version. (C-18-12-014-6-00, C-18-12-015-6-00, C-18-12-016-6-00, C- 18-12-017-6-00) 2 02/13/2019 Review, update language, and cite authority. Update to current policy formatting. (C-18-19-004-6-00) Page 5 of 5