6.3.3 Bank Accounts, Purchases and Controls
All funds, including weekly collections, tuition and fees, support receipts, sports program proceeds, scrip, bingo, gifts, and any other revenues are to be processed in approved bank accounts and reflected in monthly and annual reports.
Locations may open checking accounts, including interest bearing checking accounts, at their local bank. Without specific authorization from or approval by the FInancial Services Group, locations may not retain more than three months' worth of total operating expenses in the aggregate (as specified in the annual report) in their local bank checking accounts. Locations are not authorized to open or maintain savings, investment or money market accounts at any financial institution. All amounts in excess of three months' operating funds shall be deposited in the archdiocesan Investment Portfolio.
Bank Account Titles and Tax Identification Numbers
All banking accounts must be established under the name stated on the federal Employer Identification Number (EIN) confirmation letter that the location received from the Internal Revenue Service. If the location does not have a copy of the letter, contact Financial Services helpdesk at 213-637-7500 or fshelpdesk@la-archdiocese.org. Every parish and school bank account must use its own EIN. Fiesta and other parish or school groups may not apply for or use their own EIN and must use a parish or school EIN and subaccount for their banking purposes.
Each location in the archdiocese is assigned a separate location code by the Financial Services Group. This code is not the same as the EIN and cannot be used interchangeably.
Note: Locations may not use any other archdiocesan EIN or tax identification numbers without prior authorization by the Financial Services Group and/or the Office of the Legal Counsel. The USCCB Group Ruling number may not be used on any documentation under any circumstances.
Federal Banking Regulations and Location Bank Accounts
Federal banking regulations have become more stringent in requiring banks to verify the identities of their account holders. Consequently, archdiocesan locations, which do not conform to traditional corporate, partnership or other organizational structures, may encounter some difficulties when opening new accounts or in changing the signatories on established accounts. To assist locations in responding to issues that may arise in these circumstances, the Office of Financial Services and the Office of Legal Counsel have prepared two memoranda. The memorandum entitled: Account Holder Information for Customer Due Diligence Requirements for Financial Institutions may be provided to bank staff for an explanation of the applicable rules. Locations should refer to the memorandum entitled: Frequently Asked Questions Regarding New Banking Regulations and Account Requirements for additional guidance.
6.3.3.1 Bank Account Signatories
Parish accounts – required signatories:
Elementary school and parish high school accounts – required signatories:
Archdiocesan high school accounts – required signatories:
For other allowable authorized signatories for the accounts listed above, see Parish/School Bank Accounts - Signature Cards and Petty Cash Guidelines. If a location establishes a new account or any change in authorized signatures on existing accounts is necessary, new signature cards must be prepared. Locations should contact the Financial Services Group for information about a particular bank's requirements for signatures.
To facilitate signatory changes, obtain appropriate signature cards from the bank in which the account is kept and:
- Fill the card out completely using current signature cards as a sample
Have the principal, president and/or pastor and other designated signer(s) sign as required
Send the signed cards to the Financial Services Group for the signatures of the other designated signers
After the signatures have been obtained at the ACC, the completed signature cards will be returned to the location, which must keep a copy of the cards before delivery to the bank.
6.3.3.2 Bank Account Controls and Online Banking
No authorized signer should approve a check made out to himself or herself (except regular payroll) and may not approve check requests for himself or herself. Another authorized signer should sign the check and approve check requests, as applicable. An exception is made when the pastor is the only local authorized signer on a parish account.
Blank checks should be kept in a secure, locked safe or cabinet and should not be signed in advance of preparation; checks should be made available to authorized signers only after preparation.
Elementary school principals are restricted from signing checks over $3,000. Any checks requiring payment of more than $3,000 must be signed by the pastor.
High school principals/head of school or presidents are restricted from signing checks over $20,000. Any checks over $20,000 may be signed by the high school principal/head of school or president, provided that the expenditure has been properly authorized.
The restrictions for checks apply equally to on-line banking.
6.3.3.3 Bank Statements
Bank statements and any related credit card statements may be received by the location in hard or electronic copy, but in all cases the person in charge at the location should be the first to review all bank statements and copies of checks, electronic transfers, and other transactions, before providing the statements to the business manager or bookkeeper for recording and reconciliation.
For schools, the principal shall make a preliminary review and should confirm review by dating and signing a hard copy or making an electronic notation of the review. For parishes, the pastor/administrator shall make a preliminary review and should confirm review by dating and signing a hard copy or making an electronic notation of the review.
Bank statements must be reconciled within 10 days of receipt by a financial staff member (preferably one not directly involved in the receipt or disbursement of funds) and all discrepancies are to be addressed immediately with the bank or the related credit card company. The person in charge or a designated member of the Finance Council must review the reconciliation, then sign and date to confirm the review.
For archdiocesan high schools, a copy of the bank statement should be forwarded to the Department of Catholic Schools, together with the monthly report, by the due date prescribed.
6.3.3.4 Credit Cards
A parish or school credit/store/debit card can be used only for authorized parish or school transactions. Any other use, including any use for personal purposes, is subject to employee discipline, including termination. Any person who becomes aware of any irregularity with credit card use at a location must report the irregularity immediately to the Office of Financial Services, or report it anonymously by telephone at 855-420-8644 or via the EthicsPoint™ website. See Whistle-Blowing.
A personal credit card may be used for business and location expenses only with the consent of the pastor (for parishes and schools) or the principal (for high schools). They must be used with care and all transactions and reimbursements are to be covered by the budget and included in the monthly and annual reports.
Permission and Authorized Signers
Prior to applying for a school or parish credit card, archdiocesan high schools are required to obtain permission from the Department of Catholic Schools and parishes and parish schools are required to obtain permission from the pastor. Only persons authorized to sign on the location's bank account may apply for a credit card. Credit card limits must be consistent with the financial signature authority for the location. If a location has more than one credit card, the total limits on all credit cards may not exceed the financial signature authority for that location.
The credit card(s) should be kept locked in the principal's office (for schools) or the parish business manager's office (for parishes) and checked out only by the authorized user, with the principal's or parish business manager's permission.
Documentation
Before the credit card is checked out, the purpose for its use should be documented and then signed by the appropriate supervisor.
After the purchases are made and charged, the purchase receipt(s) must be turned in immediately to the bookkeeper and the credit card must be returned to the principal's or parish business manager's office. The bookkeeper should review the credit card charges against the monthly statement before making payment. If a receipt is missing, a detailed explanation of the charges must be attached and signed by the principal or parish business manager. The purchase receipts should be attached to the monthly statement and kept on file. All credit card transactions must be accounted for in the monthly and annual reports.
If the pastor, parish business manager, or principal uses a credit card, the same procedure regarding obtaining supporting documentation must be followed.
6.3.3.5 P-Cards
P-cards are debit cards and are preferable to credit cards. Not all locations may qualify for P-card use. Contact the Financial Services Group for guidance.
6.3.3.6 Petty Cash
Petty cash should only be used for small, unplanned, occasional purchases. All petty cash activity must be:
Petty cash accounts should not exceed $300 in an elementary school, high school, or parish.
For additional information, see Parish/School Bank Accounts - Signature Cards and Petty Cash Guidelines.
In lieu of petty cash, locations should obtain and use a P-card or location credit card for such items as postage and small office needs and then account for the same items in the monthly and annual reports. Cash and the credit card or P-card are to be kept in a locked, fire-resistant cabinet, drawer or a safe.
6.3.3.7 Payroll
For information about payroll refer to Payroll-Record Requirements.
Payroll Services
Locations are required to use ADP Vantage for payroll services Each location may contract with an outside bookkeeping service to provide assistance with ADP Vantage.
Classification of Paid Staff
Paid staff members must be properly classified for wage and hour purposes according to the classifications identified in Employee Classification, Wage Rules, and Staff Categories.
Paid staff must also be properly classified according to workers' compensation classifications (which are not the same as exempt/non-exempt). See the list of California Workers' Compensation Standard Classifications.
6.3.3.8 Archdiocesan Assessment and Special Collections
Assessments
In accordance with canon law, the archdiocese levies an assessment of 10% on the ordinary income of parishes for the support of archdiocesan services (Canon 1263). A portion of the parish assessment is used to fund the assessment on the archdiocese by the California Catholic Conference and the U.S. Conference of Catholic Bishops. The parish assessment billing is included in the overall monthly billing from the Archdiocesan Catholic Center; this is generally referred to as the Monthly Invoice. The 10% assessment is reduced to 5% for parishes with high schools.
Special Collections
The archdiocese conducts several special collections during the year, such as the Holy Land Collection (Good Friday), Peter's Pence (Collection for the Holy Father), and National Needs Combined Collection. The receipts for these collections are to be forwarded to the archdiocesan Office of Financial Services within 45 days of the date of the collection. These funds may not be commingled with the parish's general collection.
Near the end of each calendar year, the moderator of the curia sends a letter with the dates when each of these special collections are to be taken up in the parishes.
6.3.3.9 Purchases of Supplies and Materials
Subject to the guidelines in the budgeting process, each location should establish clear and precise processes for purchasing, receiving, storing, and distributing supplies and materials of any kind that the location uses, such as:
Before approving the purchase of supplies and materials, the person in charge must confirm that the purchase is covered by the budget and funds are available to cover the cost.
All purchases and orders for supplies and materials must be authorized by the person in charge.
Using numbered purchase requisitions, supply requisitions, and purchase orders
Verifying that the contents of any shipment agree with the purchase invoice
Securing and tracking the inventory of supplies and materials
Keeping all supporting documentation in the location business office (see Document Retention)
All purchases should be entered into the location's accounting system (e.g., Quickbooks or Quicken). Do not pay any bills from incoming cash receipts for any reason.
6.3.3.10 Vehicles
Purchase Policy
The archdiocese owns and insures certain cars, trucks, vans, and other vehicles used at locations throughout the archdiocese. The vehicles are registered in the name of The Roman Catholic Archbishop of Los Angeles, a corporation sole. Currently, the archdiocese provides vehicles to priests in active ministry and arranges for vehicles to be provided to priests at retirement. Particular policies concern the pricing, insurance, and other conditions of such priest ownership. See the "Transportation" section in Compensation and Benefits for Priests.
Vehicles used in archdiocesan operations, such as at the cemeteries, as well as vehicles used at archdiocesan and parish schools and other locations are managed by the Archdiocesan Catholic Center (ACC) through the moderator of the curia and the chief financial officer. No vehicles may be acquired or transferred without appropriate consents from the ACC.
The authorized purchaser must notify the archdiocesan Insurance Department immediately when an archdiocesan, parish, or school car is purchased. Send the completed Roman Catholic Archdiocese of Los Angeles Automobile Add/Delete/Change Form to the insurance department and mail, fax, or email it to Arthur J. Gallagher & Co.
All California Certificates of Title (or the older Ownership Certificates often called "pink slips") for vehicles used by parishes and schools are retained by the location. All certificates for ACC automobiles are retained by the archdiocesan Insurance Department.
Leasing Policy
Vehicles may not be leased or financed.
Policy When Selling Cars
Since the Department of Motor Vehicles requires the legal owner of the vehicle to sign the Certificate of Title (or the older Ownership Certificate often called a "pink slip"), the Notice of Transfer and Release of Liability, and the Bill of Sale, the ACC assists locations by completing and filing the aforementioned forms for the location.
The location must deliver the unsigned Certificate of Title (or the "pink slip") to the moderator of the curia at the ACC. The Insurance Department is notified and it processes the papers to release the archdiocese from liability.
All archdiocesan cars are sold "as is" to third parties and there are no warranties whatsoever.
6-15-21, 11-23-21