RubinBrown Team Member Manual

Section: Client Cash Disbursement Policy 1216

Policy Title: Policy Number:

Risk Management

Effective Date:

Supersedes Policy Dated:

06/01/2024

06/01/2023

Background: There are various service lines at RubinBrown that process disbursements for their clients. Depending on the individual agreement with each client, disbursements may be processed as often as daily, but typically at least weekly. After approved invoices are received and processed, disbursements are made via check, wire, or ACH transaction directly from the clients’ bank accounts. In some cases RubinBrown has access to clients’ bank accounts and have the ability to process electronic payments and account transfers. Therefore adequate internal controls are necessary to ensure the proper safeguarding of client assets and reduce RubinBrown’s reputational risk. These service lines currently use third party accounting or financial software programs to record invoices and process payments. Therefore, RubinBrown has responsibility over the cash disbursement process which includes, but is not limited to: • Receipt of invoices through service line designated post office box or directly from client; • Ensuring that proper invoice approvals are evident; • Recording approved invoices; • Maintaining physical security of client check stock; • Restricting access to client information in QuickBooks, Quicken, or other financial software; • Restricting access to client bank information including the ability to execute wires and ACH transactions; • Processing invoice payments in a timely manner; • Processing checks received for deposit; • Reconciling bank statements; and • Maintaining proper segregation of duties. The following policies address the key internal control risks associated with cash disbursements. These controls should be in place and utilized in the development of procedures for processing invoices and making cash disbursements. General 1. RubinBrown’s professional standards apply to this policy in their entirety, including but not limited to, record retention, quality, and internal inspection. 2. A standard RubinBrown form that details the specific parameters over the invoice processing and cash disbursements, as agreed to with the client, will be completed at the beginning of each new engagement. 3. The form must be signed and dated by the client and will serve as a record for both parties of the specific engagement parameters agreed upon. 4. A Segregation of Duties matrix must be completed for each engagement over cash receipts and disbursements to ensure that incompatible duties are not being performed by engagement personnel. Any incompatible duties identified must be evaluated and addressed such that the identified risk(s) are corrected or mitigated. 5. An engagement letter for each new client must be prepared at the beginning of each engagement. Additionally, a new engagement letter will be sent to each client each year per firm policy regardless of changes to the services provided, fee rate changes, etc. 6. All RubinBrown personnel with access to the client(s) disbursement process will be subject to a criminal and financial background check that may be more invasive than those conducted as a part of the firm’s hiring process. 7. Compliance with this policy will be monitored as a part of the internal inspections for each relevant service line.

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