Policy - Electronic Funds Transfer
Section: Human Resource Policies
Policy Owner: Ignition633 Ministries Human Resources
Policy Name: Electronic Funds Transfer Policy
Origination Date: April 2025
Electronic Funds Transfer Policy
Purpose
The Electronic Funds Transfer Policy establishes guidelines for initiating, approving, and processing electronic fund transfers. This policy ensures secure and accurate processing of all electronic payments and transfers while maintaining appropriate controls. The policy helps protect against unauthorized transfers and ensures compliance with banking regulations and internal control requirements.
Scope
This policy applies to all electronic funds transfers initiated by or on behalf of 633Donor Solutions, including ACH transfers, wire transfers, and online banking transactions. It covers all employees involved in the electronic funds transfer process, from initiation to approval and reconciliation. The policy also establishes daily transfer limits and authorization requirements for different transaction types.
Procedures for Initiation
All personnel must adhere to the following standardized initiation procedures. Compliance with these procedures is required to decrease risk exposure and maintain auditable transaction records.
- All electronic transfer requests must be submitted via the Electronic Transfer Request Form, with all required information completed prior to processing.
- Supporting documentation (e.g., contracts, approved invoices) must be attached to verify the legitimacy of the transaction and create an audit trail.
- Only authorized personnel who have completed Treasury Operations training may initiate transfers within the system.
- Verification of recipient banking details by a second authorized person is required before submission to prevent fraud.
Authorization Requirements
Authorization thresholds have been established based on institutional risk assessment and financial control best practices. These requirements align with our Financial Control Framework and banking industry regulations.
- Transfers under $10,000 require documented approval from the department director and countersignature by a Finance Department representative.
- Transfers between $10,000-$50,000 require CFO or Deputy CFO approval, with written authorization kept on file.
- Transfers exceeding $50,000 require an Executive Authorization Form with CEO or Board Treasurer signature obtained before processing.
- All international transactions require additional due diligence documentation and senior leadership approval regardless of amount.
Security Protocols
The following security measures have been implemented pursuant to the Information Security Framework adopted by the Board. Non-compliance may result in suspension of transfer privileges.
- Multi-factor authentication using organization-issued security devices is mandatory for all system users without exception.
- Passwords and access credentials must be changed quarterly and immediately revoked when staff members leave or change roles.
- All electronic transfer activities must be conducted on secure computers within the organization's network or via approved secure connection.
- System access is restricted to approved computer locations as maintained by the Information Security team.
Documentation and Reporting
In accordance with regulatory requirements and audit standards, the following documentation and reporting procedures have been established to ensure transparency and accountability.
- All transfer records must be retained for a minimum of seven years, including request forms, approval documentation, and confirmation receipts.
- Monthly reconciliation reports must be completed by the 15th of the following month by staff members who are not involved in initiating transfers.
- Internal Audit will conduct quarterly reviews to ensure compliance with this policy.
- Any suspicious activity must be reported to the CFO and Information Security Officer within one business day of discovery.
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This policy will be reviewed annually and is subject to change. Any changes will be communicated to all employees promptly.
For any questions or further assistance regarding this policy, employees should contact the HR department at hr@ignition633.org.