§ 32.377  INTERNAL ACCOUNTING CONTROLS TO MONITOR USE OF ACH TRANSACTIONS MADE BY THE TOWNSHIP.
   The following system of internal accounting controls will be used to monitor the use of ACH transactions made by the township.
   (A)   The Treasurer shall prepare a list of vendors authorized to be paid by ACH transaction and provide that list to the Clerk.
   (B)   The Clerk initiates the transaction upon receipt of an invoice included on the authorized ACH list approved by the appropriate township official. ACH invoices must be approved before payment. The Clerk signs the ACH invoice, which then acts as the warrant.
   (C)   The Clerk presents the warrant or check, a list of bills for payment, and a separate list of the electronic payments for Township Board approval. The Board approves all transactions prior to disbursement.
   (D)   Following Board approval, the Treasurer signs the ACH warrant, initiates the electronic transaction with the vendor and makes the actual transfer of funds.
   (E)   The Treasurer shall retain all ACH transaction documents for audit purposes. The Clerk shall retain all invoices for audit purposes.
   (F)   A township should use a separate imprest bank account for EFTs. A township may wish to consider using a separate bank account to accomplish ACH electronic transactions, effectively creating a “firewall” between the township’s funds and outsiders. Include in the ACH policy the list of specific types of payments pre-authorized for post-audit by the Board.
      (1)   Recommend disbursement accounts;
      (2)   Accounts payable (small dollar, limited individual transactions);
      (3)   Accounts payable (larger transactions);
      (4)   EFT account;
      (5)   Payroll account; and
      (6)   Property tax.
(Board and Administrative Policies Manual, § 4.56)