EFTA02710571

TRANSITION TO ONLINE BANKING GOAL: Implement structured internal control process over banking function that improves operational efficiencies. Online banking system provides framework for control environment where every banking transaction, regardless of type or level, is pre-defined and controlled by system administrators. Specific achievements to be gained: • Segregation of duties • Rigorous internal controls [fraud reduction) • Consistent error-proof process • Improved transaction processing and reporting I. Seoreoatlon of Duties Current: overlap between approval and payment functions Proposed: clear delineation of responsibilities of various personnel 1. Approval and payment process are two distinct functions that should be performed by separate persons. 2. Individuals responsible for approval have no (or limited) involvement with payment function. 3. Individuals making investment decisions are not involved in payment process. 4. Within online platform, restriction on permission for transaction creation and processing ensures that payment function cannot be performed by same individual. 5. With permissions implicit in banking platform, the payment/ fund release function is limited to certain individuals with different levels of approval, e.g. require two individuals to approve release large sums. 6. Levels match skillsets and job responsibilities; e.g. template creation and wire preparation are performed by bookkeeping (vs C-level person). II. Internal Controls Current: limited control environment in place fraud risk via e-mail communication to bank, eg spoofing or leaving computer on (unauthorized use of email account) authorizations/ approvals not enforced by banking personnel Proposed: controls at user, account, transaction levels 1. System access is highly customizable with restrictions/ permissions available at various levels - user, account, payee, and transaction type and dollar amount. 2. Users can be customized with transaction creation and authorization permissions at account and/ or entity level. 3. Access to online platform and user permissions are governed by dual system administrators. 4. All payment related processes require involvement of two persons, each of whom are pre- authorized for respective function. Specific transaction types or amounts can require additional persons; dual approvals for large dollar amounts. 5. No transaction can be initiated and completed with payment by a single person. 6. Payments can only be made to pre-approved vendors. The set-up of payees is governed by permissions granted by system administrators. 7. Transaction approval required before banking function can be initiated. EFTA_R1_02122759 EFTA02710571 8. Secure system payment platform — access to platform requires individual token password entry; code changes every 15 seconds. Robust platform protected by banking security protocols. 9. Account authorizations will be updated so that online approvals are consistent throughout bank documentation. 10. Authorizations are consistent across banking institutions. 11. Banking platform provides automated reporting to end users to provide control over transactions, change in permissions, new user set-up, new account set-up, etc. III. Consistent Process Current: payment process highly variable (i.e., e-mail, excel template) via multiple offices and various personnel Proposed: centralized transaction processing which adhere to strictly defined process 1. All pre-approved payments are directed to and processed by Accounting group 2. Creation of vendor templates which provide for consistent transaction processing 3. Transaction approval document is embedded into banking transaction template for verification purposes prior to payment/ release of funds 4. Transactions requiring special/additional approvals are pre-defined 5. Execution process and persons are consistent for all transactions across banking institutions and entities. IV. Reporting Current: limited access to real-time data on all accounts; report gathering is manual process Proposed: real-time access to all accounts rather than isolated subset; automated data integration with office accounting system automated user reporting directly from bank 1. Real-time access to funds receipt or payment. 2. Implement automatic notifications of transaction or account activity to specific users. 3. Ability to view all DDA accounts in a single location. 4. Banking activity can be exported directly to accounting system. 5. Reports, either standard or customized, can be set up for automatic distribution to specified recipients, e.g. trustee report with trust-only cash balances. EFTA_R1_02122760 EFTA02710572 Screenshots of various system controls: CashPro Online — Administration controls ran imnouatufs ..TICICL/V1T311/1r rvr 15CIIITIV up (at] VT 1,..,IZT1 n-ry 47,51WITI112-529111r5SCITTU1 Training Center Training Webinars Frequently Asked Questions New Admonertratoes Guide Hew Users Guide now to Videos Activate Your Token Create en Inbound Wire Alert Install YOUR' Digital Certificate Log In to Caliber° Online Manage Your Dashboard Navigate CashDro Online Reset Your Pitasoord =1511111 Bank of ATT,IinCS eai Codes Sank of Ammo& EITRS Coder • CashPro Requieweents Currency Codes by Country Data Reteebon Data Transmmsion Download Software File Formats IRAN Yalfdator Payment Cutoff TimeS Security Features Worldmd• sank Calendar Contact Us Administrators also manage user access by actryabng deactivating. deleting, resetting passworc users. Administration is designed to promote ennanced security and fraud prevention for your coi transactions Riesources For AdtnInletrattOn training documentation review to following • Administration User Manuat • Administration Reporting Lisp( Manual If you desire training on this seintico. contact Client Education at 866 355 9388 o gcsclienteducation@bankcifamencacorrt. ▪ Creating Users e Managing User 8 Entitling Users Ea Entitling Users ▪ Entitling Users e Entitling Users Ea Entitling Users e Entitling Users e Entitling Users 8 [flirting.; Users 8 Copying Entitlements Eit Approving Requests e Generating Administrative Reports e Managing Tokens and Certificates e Using Cashpro Mobile with Administration El Managing Company Settings e Additional Resources Access to Reporting Services to liquidity Services to Payments Services to Receipts Services to Trade to Notifications to Service Center to Other Services EFTA_R1_02122761 EFTA02710573 CashPro Online — Global Payments USER controls Account level rBaTrkof America --;# Merrill Lynch 1;asliPro Online REPORTING PAYMENTS RECEIPTS NOTIFICATIONS SERVICECENTER Utmost° (21 Accounts end* unsigned) Filter by Category hfloobor A4counl Parmeat Lion ly 24 3141.4* Categoom rM L IT VS O ELI.: Lee or.n1 leleit a+ a. go rd 0 AKA/ Usef Dubois Cusxm ADMEN SUPPORT :norn 21 Avail. 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Fut ' zits' : 0 Activties (15 Acrivain currently assignee) General Restricted Template Acreage C reate/Pla ntain import Profiret Maintain Renehemy ft Om:maim Table Inrorn ng Payment Sammarytemil Peports Outgoing Payment SainrnsryDeby Reports 7amplite FummaryiNitail Pepions CreateeApprove Paymar ts 8 'emplstes • Control a users capabilities with the Payments application • restrict users to "creation only" or "approve only" • user can be restricted to creation by template, freeform or both Create Diemen•s Create FX Payments Import Premen•s Approve Datiments Approve FX Payments Reject Paj moots Croatollaiotain Tomplotos Apprcvo Templar's Reject Tomplate EFTA_R1_02122763 EFTA02710575 CashPro Online — Global Payments approval requ Token requirement Bank of Anierkae CashPro` Online Merrill Lynch REPORTING PAYMENTS I RECEIPTS NOTIFICATIONS SERVICE CENTER IN SW want Payments Approvais Payment rxt rrort:AC Activate Your SafePass® Token Repot Template Marilee? Fie Itravt peeve outer Me ioraIN4mbar from .our token and deck next RI for to de exernekte to no rght Ind no Duel nurebor Your Senal Number- Cancel • Global Payments requires a token response to release payments • a minimum of 1 approval is required for all payments • token response can be for individual payments or a batch klutti-key SafePass Token Card Serenest Token EFTA_R1_02122764 EFTA02710576