Managing GSA SmartPay Purchase Card Use
|
|
- Roxanne Hoover
- 8 years ago
- Views:
Transcription
1 U.S. Geeral Services Admiistratio Maagig GSA SmartPay Purchase Card Use A Pla for Success
2 Table of Cotets Overview... 1 Chapter 1: Uderstadig Cardholder Misuse ad Fraud... 2 Chapter 2: Uderstadig No-Cardholder Fraud... 5 Chapter 3: Liability for Purchase Card Trasactios... 7 Chapter 4: The Review Process... 8 Chapter 5: Idicators of Cardholder Misuse or Fraud Chapter 6: Usig Reportig Tools to Fid Misuse ad Fraud Chapter 7: Prevetative Measures Chapter 8: Takig Actio Chapter 9: Web site Idex Chapter 10: Defiitios ad Acroyms Quick Referece Guide Appedix 1: Sample Aual Review Process Appedix 2: Sample Questioable Purchases Form... 44
3 Overview The GSA SmartPay purchase card program provides cards to federal employees to make official govermet purchases. As the Agecy/Orgaizatio Program Coordiator (A/OPC) assiged by your agecy to oversee the use of the card, detectio of misuse/fraud by govermet employees is your resposibility. This maual is ot a govermetwide policy hadbook. Rather, it is iteded to serve as a iformatio source for assistig i the oversight role. Use of the card should be i accordace with agecy-specific policy. As used i this guide, the terms bak ad cotractor are iterchageable: they represet the three baks awarded cotracts uder the GSA SmartPay 2 Master Cotract. Maagig Purchase Card Use: A Pla for Success 1
4 Chapter 1: Uderstadig Cardholder Misuse ad Fraud If a employee i a agecy becomes aware of possible misuse of a purchase card, the cardholder activity should be examied by the desigated Agecy/Orgaizatio Program Coordiator (A/OPC) to determie if further actio is required. Some activity may appear suspect upo iitial review, but with further ivestigatio may be determied to be legitimate govermet busiess that ca iclude a broad rage of activities. A/OPCs have access to cardholder iformatio ad would be the first poit of cotact i most situatios. What is cardholder misuse ad fraud? As a geeral matter, fraud is the itetioal misrepresetatio of facts, deceitful practice, or willful device with itet to deprive aother of his or her right or to do ijury or damage to him or her. I the case of govermet purchase cards, itetioal use of the purchase card for other tha official govermet trasactios costitutes misuse. Ad depedig o the facts, it may ivolve fraud. The employig agecy of a cardholder employee who misuses the card or who participates i fraud may cacel the purchase card ad take discipliary actio agaist the employee, as appropriate. I the case of card misuse, the employee will be held persoally liable to the govermet for the amout of ay uauthorized (ogovermet) trasactio. 2
5 Additioally, depedig o the facts ivolved, a employee may be subject to fie or imprisomet for actio relatig to purchase card misuse ad fraud. For example, if covicted uder 18 USC 287, a perso is subject to fies ad/or imprisomet for ot more tha five years. Military members may be subject to court martial uder 10 USC 932, UCMJ Art Also, depedig o the circumstaces, other sectios of the USC may apply ad may carry additioal pealties or fies: Frauds ad Swidles (Mail Fraud) 18 USC 1341; Fraud by Wire, Radio, or Televisio 18 USC 1343; Cospiracy to Commit Offese or Defraud Uited States 18 USC 371; Bribery of Public Officials ad Witesses 18 USC 201; Lauderig of Moetary Istrumets 18 USC 1956; Public Moey, Property, or Records 18 USC 641; Statemets or Etries Geerally 18 USC 1001; Extortio by Officers or Employees of the Uited States 18 USC 872; Cospiracy to Defraud the Govermet with Respect to Claims 18 USC 286; ad Persos i a Positio of Trust Normally used durig setecig. This statemet is usually itroduced by the assistat U.S. attorey to obtai additioal poits from the Federal Setecig Guidelies. Employees issued a card have a resposibility to use the card to procure supplies ad services at the directio of the agecy uder official purchase authorizatio. Examples of misuse iclude: (1) purchases that exceed the cardholder s limit; (2) purchases ot authorized by the agecy; (3) purchases for which o fudig exists; (4) purchases for persoal cosumptio; (5) purchases that do ot comply with the Federal Acquisitio Regulatio (FAR) ad/or other applicable procuremet statutes ad regulatios; ad (6) purchases billed by the merchat but ot received by the agecy. Cosequeces Agecies should establish guidelies ad procedures for discipliary actio to be take agaist idividuals for the improper, fraudulet or abusive use of the purchase card. Purchase card misuse or fraud may have the followig potetial cosequeces: Couselig; Cacellatio of purchase card; Notatio i employee performace evaluatio; Reprimad; Suspesio of employmet; Termiatio of employmet; ad Crimial prosecutio. Maagig Purchase Card Use: A Pla for Success 3
6 The purchase card shall be used to purchase supplies ad services i accordace with the FAR ad agecy policy. Purchase card use as the procuremet ad paymet tool for micro-purchases is defied i FAR Micro-purchase meas a acquisitio of supplies or services i which the aggregate amout does ot exceed $3,000, except that the limit is $2,000 i the case of costructio. GSA cardholder traiig o use of the purchase card may be foud o the GSA SmartPay Web site. For purchases above the micro-purchase threshold, the purchase card may be used as a orderig ad paymet mechaism, ot a cotractig mechaism. Whe used as a orderig ad paymet mechaism, cotractors may bill agaist the card. For example, a order has bee placed with a cotractor o a GSA Federal Supply Schedule for $15,000. The award was made usig the orderig procedures i accordace with FAR 8.4. The cotractor agrees to accept the purchase card as paymet. Whe the order is delivered, the cotractor bills the purchase card accout istead of issuig a ivoice directly to the agecy. All applicable requiremets of the Competitio i Cotractig Act, other statutes ad Executive Orders, the Federal Acquisitio Regulatios, as well as agecy supplemets, apply to purchases made with the purchase card as the orderig ad paymet mechaism. Limits o Use To allow agecies the maximum latitude, the GSA SmartPay 2 Master Cotract excludes oly a few categories of purchases, such as log-term retal or lease of lad or buildigs, travel or travel related expeses (except it may be used for meetig spaces ad local trasportatio services such as Metro fare cards, subway tokes, etc.), ad cash advaces. Agecies may impose other restrictios o use of the card as well as ay exceptio procedures. The GSA SmartPay 2 Master Cotract does ot specifically address the maximum trasactio amout that may be charged whe usig the card. Cetrally billed GSA SmartPay 2 accouts caot be used for private gai. May GSA SmartPay 2 cardholders have asked whether they ca register their GSA SmartPay 2 purchase cards i beefit programs such as Upromise. The aswer is o. The Stadards of Ethical Coduct for Employees of the Executive Brach (Title 5, Chapter XVI, Sectio 2635 of the Code of Federal Regulatios) states: a employee shall ot use his public office for his ow private gai. The purchase card is used to acquire products ad services iteded for the govermet s use, ad charges made o the card are paid for with govermet fuds. Govermet purchase cardholders who register their GSA SmartPay 2 purchase cards with these etworks are usig their public office for private gai ad are therefore i violatio of ethics rules. If you or your cardholders have questios about ethics rules, please cotact your agecy Ethics Official (usually, a attorey i your Office of Geeral Cousel). 4
7 Chapter 2: Uderstadig No-Cardholder Fraud No-cardholder fraud ivolves the use of the purchase card or cardholder data by a uauthorized perso. The risk of o-cardholder fraud is higher i certai situatios icludig: Card ever received A ew or replacemet card has bee mailed to the cardholder but was ot received. Due to the possibility that the card could have bee itercepted by a third party, the accout will be cacelled by the bak upo otificatio from the cardholder. A ew card with a ew accout umber will be issued. Each cardholder will be required to activate his or her card by phoe oce they receive it. Lost card The cardholder reports that the card as misplaced or lost. The accout will be closed, ad a ew card will be issued. Reportig the card as lost does ot relieve the govermet for paymet of ay trasactios that were made by the cardholder prior to reportig it lost. The cardholder may be required to sig a affidavit cofirmig the card was lost. If trasactios ot made by the cardholder appear o the statemet, the cardholder must submit a dispute form to the bak withi 60 days of receipt of the statemet. Failure to submit the dispute form ad/ or affidavit could result i liability of the govermet for the trasactio charge(s). A Cardholder may forfeit his or her rights to dispute if the form is ot set i withi 60 days. Maagig Purchase Card Use: A Pla for Success 5
8 Stole card The cardholder reports the card as stole. The accout will be closed, ad a ew card will be issued. Reportig the card as stole does ot relieve the govermet of paymet for ay trasactios that were made by the cardholder prior to reportig it stole. The cardholder may be required to sig a affidavit cofirmig the card was stole. If the cardholder did ot make the trasactios appearig o the cardholder statemet, the cardholder must submit a dispute form to the bak withi 60 days. Failure to submit the dispute form ad/or affidavit could result i liability to the govermet. Altered or couterfeit cards These types of cards are ormally idetified by the bak s authorizatio process or by the cardholder whe he or she receives his or her statemet. Third parties obtaied accout iformatio ad used that iformatio to make purchases with a altered or couterfeit card. If the baks recogize a fraudulet patter of use at the time of authorizatio, the bak will validate the use of the card with the cardholder ad/or susped the card. The cardholder may be asked to sig a affidavit verifyig that the trasactios were fraudulet. If the cardholder did ot make trasactios appearig o the cardholder statemet, the cardholder must submit a dispute form to the bak withi 60 days. Failure to submit the dispute form ad/or affidavit could result i liability to the govermet. Accout takeover This may be kow as idetity theft. I this case, the cardholder s idetity has bee compromised, ad a third party requested a ew card by providig cofidetial iformatio about the cardholder. Ay cardholder who believes that he or she may have bee subject to idetity theft should cotact the bak s customer-service departmet. Oce a determiatio is made that a accout has bee compromised, ivestigatio of the activity o the accout is the resposibility of the bak. Uless a govermet employee is determied to be ivolved i the fraud, the agecy geerally does ot participate i the ivestigatio. The accout will be closed, ad a replacemet accout opeed. Nocardholder fraud is ivestigated by special uits withi the baks resposible for iitiatig civil actios ad commuicatig with govermet law eforcemet orgaizatios. Ay iformatio that you may acquire related to o-cardholder fraud should be reported to your bak. Cardholders should cotact customer service at the toll-free umber provided o the back of the card to report ay suspected fraud. 6
9 Chapter 3: Liability for Purchase Card Trasactios The GSA SmartPay 2 Master Cotract clearly defies liability for purchase card trasactios. Liability for trasactios made by authorized cardholders rests with the govermet. If the card is used by a authorized cardholder to make a uauthorized purchase, the govermet is liable for paymet ad the agecy is resposible for takig appropriate actio agaist the cardholder. Use of the card by a perso other tha the cardholder, who does ot have actual, implied, or apparet authority for such use ad for which the cardholder receives o beefit, is ot the liability of the govermet. If it is discovered that someoe other tha the cardholder has used the card, it should be reported immediately to the A/OPC ad the bak s customer service represetative. Uder the terms of the GSA SmartPay 2 Master Cotract, liability of the govermet for lost or stole cards shall ot exceed the lesser of $50 or the amout of moey, property, labor, or services obtaied before otificatio to the cotractor. The cotractor ad the Agecy/Orgaizatio Program Coordiator (A/OPC) are to be otified whe it becomes evidet that a card has bee lost or stole. Cards that have bee reported lost or stole are blocked immediately. The cotractor will issue the cardholder a ew card with a ew accout umber. After the cardholder reports a lost or stole card, the cotractor will sed the cardholder a letter explaiig the steps that eed to be take. The cardholder should follow the istructios i that letter to mitigate liability for ay uauthorized trasactios. Uauthorized trasactios may appear o the cardholder statemet eve though the card has bee reported lost or stole. If uauthorized trasactios appear o a cardholder statemet, the cardholder should cotact the bak s customer-service departmet. Maagig Purchase Card Use: A Pla for Success 7
10 Chapter 4: The Review Process Give that the agecy is liable for uauthorized purchases by a authorized cardholder, agecy purchase card policy should address reviews to be udertake by the Approvig Official (AO) ad Agecy/Orgaizatio Program Coordiator (A/OPC) to mitigate risk to the agecy. Level 1 review by the AO ad/or A/OPC, icludig first had kowledge of the type of products ad services authorized by the orgaizatio, is the first lie of defese. Cardholder At the ed of each billig cycle, the cardholder shall recocile the trasactios appearig o his/her mothly statemet by verifyig their accuracy agaist cardholder records. The cardholder shall review all iformatio o the mothly statemet, verifyig charges, credits, outstadig disputes, ad refuds. Approvig Official (AO) The AO is resposible for esurig that all purchases made by the cardholder(s) withi his/her resposibility were appropriate ad the charges are accurate. He/she must resolve all questioable purchases with the cardholder. I the evet a uauthorized purchase is detected, the AO must otify the A/OPC ad other appropriate persoel i accordace with agecy policy After review, the AO will sig the accout statemet ad maitai the documetatio i accordace with agecy procedures. As desigated by the agecy, the AO may also be resposible for certifyig the mothly ivoice resultig from the purchases/trasactios of the cardholders withi his/her accout structure. The umber of cardholders ad the volume of trasactios for which a approvig official is resposible eed to be reasoable, so that the official may coduct reviews i a timely maer. Timely reviews of trasactios are ecessary to esure detectio of possible cases of card misuse ad fraud. The umber of cardholders assiged to a AO should be reasoable, cosiderig the volume of cardholder activity ad the orgaizatioal structure. The AO should have direct kowledge of the cardholder s role i the agecy ad the ability to verify receipt of the purchase. I situatios where cardholder use is ifrequet, more cardholders could be assiged to the AO. 8
11 Agecy/Orgaizatio Program Coordiator (A/OPC) A/OPC reviews of the purchase card program must be accomplished to esure adequate local iteral cotrols are i place. The review should cosist of a evaluatio of local operatig procedures to esure that cardholders ad approvig officials are operatig withi the prescribed policies. A review should ecompass the followig areas: Compliace with agecy policies; Applicable traiig requiremets; Appropriate delegatio of authority; Itegrity of the purchase process; Compliace with procuremet regulatios; Receipt ad acceptace procedures; ad Records retetio. Agecy policy may require a aual review by each A/OPC. Depedig o the umber of accouts, the aual review may be performed o each accout or o a radom basis. A sample checklist for a aual review is icluded i Appedix 1. Best Practice: Cardholders should use a stadardized form to provide additioal iformatio to A/OPCs o questioable trasactios (see Appedix 2). Who Should Have Cards? There is o right umber of cardholders for your agecy. I certai circumstaces, a large umber of cardholders may be required to accomplish the missio of the agecy. The risk of issuig more cards must be weighed agaist the eed for more cardholders. A regular review of accout activity will idetify accouts with little or o activity. You should review use ad close accouts that are o loger eeded. Best Practice: A/OPCs are ecouraged to review the umber of cardholders as part of the Aual Review Process. Cards with little or o activity should be cosidered for cacellatio. Separatio of Duties Agecy policy should iclude directio regardig separatio of duties to miimize the risk of fraud ad/or loss of property. I particular, resposibilities of cardholders, AOs, ad A/OPCs should ot overlap, to esure that maagemet cotrols are ot circumveted. Assigmet of duties (such as authorizig, approvig, ad recordig trasactios), receivig assets, approvig cardholder statemets, makig paymets, certifyig fudig, ad reviewig or auditig should be assiged to separate idividuals to the greatest extet possible. Best Practice: Whe appoitig A/OPCs or AOs, cosider factors such as grade, positio, traiig, etc., to esure they ca successfully perform their duties. Maagig Purchase Card Use: A Pla for Success 9
12 Chapter 5: Idicators of Cardholder Misuse or Fraud Some simple thigs to keep i mid whe lookig at trasactios: Card misuse ad cases of fraud ofte start small ad may ot stop after oly oe actio. No matter how small the misuse or fraud, it should be addressed immediately to prevet ay future occurreces. Cards must oly be used by the cardholder. If the cardholder is ot directly ivolved i the trasactio, there is greater risk that fraud will be committed. Cardholders should be able to provide documetatio of purchases, such as ivoices, receipts, etc. whe requested by the Approvig Official (AO), Agecy/ Orgaizatio Program Coordiator (A/OPC), or auditors. Esure that cardholders certify trasactios promptly. Prompt certificatio allows for prompt remedial actio i the evet of misuse or fraud. Radom reviews of cardholder records by the A/OPC will discourage misuse ad fraud sice cardholders, ad AOs kow their actios are beig moitored. Govermet ivestigators idicate that, i may istaces, the AO ad/or A/OPC would have detected fraud earlier with proper review. The checklist o page 11 is provided to highlight idicators that may poit to cardholder fraud. It is importat to uderstad that these are idicators oly. As such, they must be ivestigated further with the cardholder or other idividuals. Merchat Category Codes (MCCs) are ofte used to highlight trasactios requirig further ivestigatio. While a trasactio with a merchat i a questioable MCC (see the Quick Referece Guide) may iitially raise questios, further ivestigatio may reveal that the trasactio was a legitimate purchase or that the merchat was misclassified. 10
13 Issue Yes No Commets 1._ 2._ 3._ 4._ 5._ 6._ 7._ 8._ 9._ Does the trasactio fall withi a bolded merchat category code i the MCC table? Does the merchat ame appear to be outside the cardholder s geeral area of resposibility? _Does the cardholder have several trasactios with the same merchat withi a short time frame, ad does the amout of the trasactios total more tha $3,000? Has the accout bee closed due to fraud ad a ew card issued? Has the cardholder disputed trasactios o a frequet basis? Has the cardholder had multiple declied authorizatios? Does the cardholder have trasactios (authorizatios) occurrig o o-workig days (e.g., weekeds)? Does the cardholder have higher-tha-ormal expeditures durig the billig cycle? Has the dollar limit o the accout bee raised durig the billig cycle? Possible split trasactios Cardholder traig recommeded A/OPC review recommeded 10._ 11._ 12._ 13._ Has the cotractor bee debarred (see for listig) by the federal govermet? Is the cardholder uable to provide proofs-of-purchase such as receipts? Does the cardholder have multiple trasactios of eve dollar amouts (e.g., $20, $100)? Has the cardholder allowed others i the office to use his/her card for makig purchases? 14._ Does the cardholder have recurrig purchases of a high dollar value? 15._ 16._ 17._ Does the cardholder have trasactios with two merchats with two differet ames but same address ad ower? Does the cardholder repeatedly do busiess with the same merchats (miimal rotatio)? Does the cardholder make repeated purchases close to his/her sigle purchase limit? 18._ 19._ Does the cardholder cosistetly hit his/her mothly limit? Does the merchat address appear to be a home address? Maagig Purchase Card Use: A Pla for Success 11
14 Coveiece Checks Some agecies allow for the use of coveiece checks. Coveiece checks are a paymet ad/or procuremet tool iteded oly for the use with merchats that do ot accept purchase cards ad for other authorized purposes where charge cards are ot accepted. Coveiece checks should be used as a paymet method of last resort, oly whe o reasoable alterative merchat is available who accepts the charge card. If your agecy/orgaizatio determies a eed for coveiece checks, your purchase charge card cotractor bak will provide a supply of checks to the desigated cardholder draw o the cardholder s purchase charge card accout. The checks will be processed as they are preseted for paymet. Coveiece checks are multi-copied (oe copy for the cardholder s records; the origial for the merchat). Due to the icreased potetial of fraud ad abuse, specialized traiig o coveiece checks is required prior to beig authorized to write checks. If ay misuse or abuse is discovered, the employee will lose coveiece check ad purchase card privileges. That employee will the be referred for discipliary actio i accordace with agecy procedure. Coveiece checks may NOT be writte for purchases above the micropurchase limits as defied i FAR Sectio 2.1. I additio, coveiece checks may NOT be writte to: Vedors who accept the purchase card; Vedor trasactios already uder aother method of acquisitio (purchase orders, cotracts, etc); Employee reimbursemets; Cash advaces; Salary paymets, cash awards, or ay trasactio processed through the payroll system; Travel-related trasportatio tickets; Meals or lodgig related to employee travel except as related to emergecy icidet respose; ad Other restrictios as determied by Agecy policy. Checks must be used i sequetial order. Each coveiece check must be etered i a check register or log for trackig purposes. The followig iformatio must be writte o each check: Date the check is beig issued; The ame of he payee; Amout of the check; ad A origial sigature. 12
15 Due to the ature of this product, additioal care should be take i maagig accouts with the coveiece check feature: Checks should be secured at all times to esure agaist physical theft. Checks are egotiable istrumets ad are to be stored i a locked cotaier, such as a safe or metal filig cabiet. Checks should be accouted for appropriately to prevet loss, theft or potetial forgery. The umber of accouts should be limited to reduce risk. The umber of checks o had should be limited to reduce risk. Before a check is issued, every reasoable effort should be made to use the purchase card. Maximum efforts should be made to fid ad use vedors who accept the purchase card. Due to the cost associated with coveiece checks, the umber of checks writte should be kept to a miimum. The GSA SmartPay 2 Master Cotract requires olie access or cotractorprovided software to eable agecies/ orgaizatios to automate their coveiece check system. The system shall, at a miimum, provide the ability to track, add, tally, report ad reorder coveiece checks, view cleared checks, as well as iput 1099 iformatio, such as merchat TIN, address, etc. The bak will: (1) provide a supply of checks to the desigated coveiece check accout holder, (2) process ad pay the checks as they are preseted through the bak check-clearig system for paymet withi established sigle-purchase limits established by the A/OPC for each idividual, ad (3) provide a listig of the checks cleared o the mothly cardholder statemet. Hard copies of checks are geerally available upo request. The A/OPC is resposible for the implemetatio of the appropriate iteral cotrols ad oversight of coveiece check activity, icludig esurig that all checks issued are for official govermet busiess oly. The A/OPC must verify that each check issued was both ecessary ad i compliace with the agecy s coveiece check policy. The cardholder should record i his/her files the date, check umber, payee, ad amout of each check. Maagig Purchase Card Use: A Pla for Success 13
16 Chapter 6: Usig Reportig Tools to Fid Misuse ad Fraud A Agecy/Orgaizatio Program Coordiator (A/OPC) ca use the servicig bak s electroic access system i order to geerate agecy reports as a meas of detectig fraud. There are several essetial reports that ca provide trasactio data with differet levels of detail. Each report ca be made available at every level of the hierarchy. The followig reports may be utilized to detect misuse ad fraud withi your program: Accout Activity Report This report shows all active accouts ad the spedig for each accout durig a billig cycle. It provides details o each trasactio, icludig trasactio date, trasactio type (credit, debit, coveiece check, etc.), merchat ame, ad dollar amout. This report allows a A/OPC to sort trasactios by dollar size, merchat, date, or type. The Accout Activity Report is particularly useful for idetifyig: Suspicious merchats; Uusually high spedig patters; Excessive coveiece check usage; or Utimely purchases. Declied Authorizatios Report The declied authorizatio report will idetify cardholders who have attempted to use a card to buy a item: For which they are ot authorized; That exceeds their sigle-purchase limits; That exceeds their mothly purchase limit; or From a merchat that falls uder a blocked Merchat Category Code (MCC). If a cardholder cosistetly has declied authorizatios, the A/OPC should take actio by providig additioal traiig or makig a chage to the cardholder authorizatio cotrols or dollar limits. 14
17 Disputes Report The disputes report idetifies date, merchat, reaso code, dollar amout, ad status of each dispute filed by a cardholder. Reviewig the report would idetify cardholders with excessive disputes. These cardholders may either require traiig or may be tryig to disguise misuse or fraudulet activity. Approvig officials ad A/OPCs should track ad follow up o disputes to determie their outcomes. Cardholders should attempt to resolve disputes directly with merchats prior to filig a disputes report. If a merchat is cosistetly appearig o the disputes report, the A/OPC should determie whether the merchat may have billig issues, quality issues, or is attemptig to commit fraud by submittig false trasactios. Master File The master file should be reviewed periodically to elimiate cardholders who are o loger employed i the agecy, correct addresses, ad verify whether card limits ad authorizatio cotrols are appropriate. Ad Hoc Reports The baks offer a wide rage of ad hoc reportig tools. Check with your bak to determie what is available. Best Practice: Place ad hoc reports i a shared folder so all A/OPCs ca access them. This saves A/OPCs from developig reports ad esures cosistecy across the orgaizatio. Uusual Spedig Activity Report The baks offer various reports idetifyig trasactios that may warrat further review. These reports vary by bak. Lost/Stole Card Report The lost/ stole card report idetifies cards that are reported lost or stole. This report may be reviewed to idetify cardholders who have repeatedly reported their cards missig. This may either be a idicator that the cardholder eeds to secure his/her card or that the cardholder is attemptig to disguise misuse or fraudulet activity by deyig the charges. Maagig Purchase Card Use: A Pla for Success 15
18 Chapter 7: Prevetative Measures Credit Limits Credit limits ca be set up to restrict sigle-purchase or daily/weekly/mothly expeditures by the cardholder. I accordace with agecy policy, a Agecy/ Orgaizatio Program Coordiator (A/OPC) sets credit limits which best meet the agecy s eeds. Settig limits that are realistic but ot excessive will deter cardholder misuse. By reviewig cardholder spedig patters, you may be able to lower limits without jeopardizig the employee s missio. A/OPCs have the authority to raise limits at ay time i respose to emergecy or uforesee situatios. Best Practice: Oly Level 1 A/OPCs may raise limits accordig to agecy policy. Merchat Category Code (MCC) Blocks MCCs are established by the bakcard associatios or baks to idetify differet types of busiess*. Merchats select the codes best describig their busiesses. A A/OPC may limit the types of busiesses where the card will be accepted by limitig the MCCs available to the cardholder. The bak has established sample templates that may assist i determiig which MCCs should be restricted. I the evet that a cardholder eeds to make a purchase outside of his/her restricted MCCs, a A/OPC is authorized to override the restrictio for a trasactio by cotactig the bak s customer service represetative. Agecy policy should specify who is authorized to perform overrides. If a A/OPC has a questio about a purchase based o the MCC, the A/OPC should discuss the matter with the cardholder to determie the ature of the purchase. What may appear to be a iappropriate use of the card actually may be a matter of a erroeous or misclassified MCC. Some merchats operate multiple types of busiesses or chage the ature of their busiesses over time. If a merchat has a iaccurate MCC, the merchat should otify his or her acquirig bak ad request that it be corrected. * A sample list of MCCs is located o page 30 i the Quick Referece Guide. 16
19 Agecy Policies Policy will vary from agecy to agecy, based o missio cosideratios. It is recommeded that agecy policies address the followig areas to esure that clear guidace is provided to A/OPCs, AOs ad cardholders: Delegatio of cotractig authority; Traiig requiremets; Accout limits; Uses of the card; Receipt ad acceptace of supplies ad services; Recocilig accouts; Review procedures; Spa of cotrol for AOs ad A/OPCs; Criteria for establishig accouts; ad Criteria for deactivatig or cacellig accouts with miimal activity. Defie the A/OPC Role Each agecy should iclude a list of A/OPC duties ad resposibilities i its writte policy ad A/OPC traiig materials to esure that all parties uderstad their role. This is particularly importat i situatios where there is frequet turover of A/OPCs. Cotractor provided A/OPC guides ca assist agecies i traiig their A/OPCs. The A/OPC geerally serves as the focal poit for aswerig questios, cotract admiistratio, coordiatio of the applicatios, issuace ad destructio of cards, settig authorizatios, establishmet ad review of reports, ad admiistrative traiig. Typically, resposibilities iclude: Maitaiig a up-to-date list of accout ames, accout umbers, addresses, addresses, ad telephoe umbers of all curret cardholders ad accouts. Providig to the cotractor(s) ay chages i their respective orgaizatioal structures that may affect ivoice/report distributio. Reviewig ad evaluatig the cotractor s techical ad admiistrative task order performace ad compliace. Resolvig techical ad operatioal problems betwee the cotractor ad cardholders. Takig appropriate actio regardig deliquet accouts ad reportig to iteral ivestigative uits ad the GSA Cotractig Officer ay observed violatios of applicable executive orders, laws, or regulatios. Participatig i traiig cofereces ad traiig cardholders. Esurig cardholders use the card program correctly. Moitorig accout activity ad maagig deliquecies. Esurig that appropriate steps are take to mitigate suspesio or cacellatio actios. Maagig Purchase Card Use: A Pla for Success 17
20 The A/OPC is the eyes ad ears of the orgaizatio. The A/OPC s role is of extreme importace to the agecy. Audits ad Ivestigatios The Ispector Geeral Act of 1978 established the Office of Ispector Geeral (IG) i departmets ad agecies to: Coduct audits ad ivestigatios related to programs ad operatios; Provide leadership; Recommed policies that detect ad prevet fraud ad abuse i programs ad operatios; ad Provide a meas for iformig the head of the departmet or agecy of problems or deficiecies. A strog bod betwee the purchase card program office ad the IG s office is the key to successful maagemet of your card program. The two types of fuctios geerally performed by the IG are audits ad ivestigatios. Audits are performed to esure compliace with policy ad to detect fraud ad misuse. They are geeral i ature ad ot focused o specific actios or idividuals. Audits may review iteral or exteral operatios. Ivestigatios are more specific i ature, although they may look at several areas or idividuals iside ad outside the orgaizatio. The purchase card office should work with the IG to gather data o completed ivestigatios so that prevetive measures ca be addressed i agecy purchase card policy. Joit Agecy Coordiatio Joit agecy coordiatio is importat because fraud ad abuse foud through ivestigatios i oe agecy could ucover ad/or prevet similar situatios occurrig i aother agecy. The types of crimial acts ivolved i purchase card fraud are ofte coducted i rigs. Further, i the case of cotractor ivolvemet, the cotractor ormally does busiess with multiple federal agecies ad usually cotiues similar behavioral patters with other govermet employees. A example of joit agecy coordiatio is the Joit Federal Task Force Sudde Impact, assembled by the Federal Bureau of Ivestigatios (FBI). This task force was comprised of multiple federal agecies, ragig from the U.S. Army Crimial Ivestigatio Commad to the Defese Crimial Ivestigatio Service to the Evirometal Protectio Agecy. This task force met o a regular basis, ot oly to discuss ew purchase card ivestigatios, but also to coduct proactive aalysis of purchase card activity. The FBI provided space with computers i order to dowload ad compile purchase card activity for task force review. The task force received prosecutorial assistace from attoreys withi the Justice Departmet ad the Departmet of Defese. 18
21 Traiig Materials Traiig is a key compoet of fraud prevetio. GSA offers umerous traiig opportuities to assist A/OPCs i the admiistratio of the purchase card program; however, some agecies may require supplemetal traiig to address agecy specific issues. Followig is a list of free tools that GSA ad/or the cotractors offer to agecies: A/OPC Guide The guide addresses issues of cocer to the A/OPC, icludig resposibilities of program participats, accout setup ad maiteace, accout suspesio/cacellatio, disputes, reports, ad ivoicig procedures. The guide is available from your cotractor as a hard copy or electroically. A/OPC Olie Traiig GSA desiged this olie traiig for purchase charge card A/OPCs. Olie traiig ca be foud o the GSA SmartPay Web site. Aual GSA SmartPay Traiig Coferece GSA sposors a aual coferece to trai A/OPCs o accout admiistratio, program maagemet, reports, ad electroic access systems. I additio to A/OPCs, the coferece is beeficial for approvig ad billig officials, ispectors ad auditors. Iformatio regardig the coferece may be foud at Cardholder Guide The cardholder guide addresses authorized uses of the card, disputes, ad billig. This guide ca be requested through your bak. Purchase Cardholder Olie Traiig GSA desiged this course to provide cardholders basic iformatio eeded to make official purchases. It is available olie by goig to the GSA SmartPay Web site. Deactivatio I istaces whe cards are ot eeded o a cotiuous basis, deactivatio of the card may serve as a deterret to fraud or misuse. A/OPCs may deactivate cards whe cardholders are ot usig them. Deactivatio/activatio ca be completed through the bak electroically or by callig customer service. If someoe attempts to use a deactivated card, the authorizatio will be declied. The card is ot cacelled ad ca easily be reactivated by the A/OPC, either electroically or through customer service. If you ited to use this process, be sure you uderstad ay relevat timeframes for reactivatio. Automated Trasactio Review The baks ca provide trasactio files i a electroic format to agecies. With receipt of electroic trasactio data, a agecy has the optio of reviewig cardholder activity through data miig. Data miig is the extractio of useful iformatio from a database usig artificial-itelligece algorithms ad eural etworks. Several agecies have developed data-miig tools to highlight potetial misuse ad fraud. The accuracy of the tools is cotiget o models that depict fraud occurreces. I order to develop accurate models, the patters of cardholder misuse ad fraud must be documeted ad uderstood. Maagig Purchase Card Use: A Pla for Success 19
22 Chapter 8: Takig Actio As the Agecy/Orgaizatio Program Coordiator (A/OPC), you have the resposibility to report ay suspected or actual fraud to the appropriate authorities withi the govermet. If fraud by a cardholder, merchat, or other third party is suspected, a A/OPC ca file a complait with his/her agecy s Ispector Geeral (IG). Ivestigatios are iitiated upo receipt of a complait or other iformatio that gives a reasoable accout of the wrogful or fraudulet act. May agecies provide fraud hotlie umbers to facilitate reportig of fraud. Make sure that A/OPCs, AOs, ad cardholders are aware of the hotlie umber. Be as specific as possible whe callig or sedig i a complait. If the complait relates to a cardholder, a A/OPC you should provide the followig: The employee s full ame; Rak or pay grade; Duty statio; Specific suspected fraudulet act or wrogdoig; Specific dates ad times; Specific locatio of where the suspected fraudulet act occurred; ad How the idividual completed the alleged fraudulet act. Iquiries that are iformal admiistrative ivestigatios ormally are completed withi 180 days. However, the time required to coduct a iquiry may vary depedig o the complexity or amout of additioal iformatio eeded to complete the ivestigatio. Typically, the ivestigator will be able to tell if the case is ope or closed because of restrictios o disclosure of records covered by the Privacy Act of If a copy of the report is required, the A/OPC ca make a writte request to the IG s office. Based o the fidigs of the ivestigatio, a A/OPC may be required to otify a employee s supervisor ad huma resources office for further iteral admiistrative actio. Depedig o the circumstaces, a A/OPC may eed to cotact other orgaizatios, icludig: The bak s fraud uit; The IG; The Fraud Hotlie; The DoD Crimial Ivestigative Service (DCIS); The Federal Bureau of Ivestigatio (FBI); The Naval Crimial Ivestigatio Service (NCIS); The U.S. Army Crimial Ivestigatio Commad (USACIDC); ad/or The Air Force Office of Special Ivestigatios (AFOSI). 20
23 Chapter 9: Web Site Idex The Office of Govermet Ethics (OGE) Web site provides the Stadards of Ethical Coduct for employees of the executive brach. The GSA SmartPay Web site provides a copy of the GSA SmartPay 2 Master Cotract, cotractor guides, performace summaries, olie traiig, ad a list of agecy represetatives who ca aswer questios. This Web site provides policy ad operatioal guidace, as well as other related resources for Departmet of State, USAID, USIA, ad the Peace Corps (icludes both domestic ad overseas activities). ccpmd/purchase_card This Web site displays policy ad related liks for the Departmet of the Navy purchase card program. This Web site displays iformatio o the scope of resposibility ad leadership offered to prevet ad detect fraud ad abuse i programs through the Office of the Ispector Geeral. This Web site was developed to provide program participats with access to iformatio that will assist them i complyig with all regulatory requiremets ad istructios received from DoD, DLA ad DSCC. The Federal Acquisitio Regulatio (FAR) was established to codify uiform policies for acquisitio of supplies ad services by executive agecies. It is issued ad maitaied joitly, pursuat to the OFPP Reauthorizatio Act uder the statutory authorities grated to the Secretary of Defese, the admiistrator of Geeral Services Admiistratio, ad the admiistrator of Natioal Aeroautics ad Space Admiistratio. This Web site displays policy ad operatioal guidace for Departmet of Defese (DOD) purchase card program. Maagig Purchase Card Use: A Pla for Success 21
24 Chapter 10: Defiitios ad Acroyms Defiitios Agecy/Orgaizatio Program Coordiator (A/OPC) The A/OPC geerally serves as the focal poit for aswerig questios, task order admiistratio, establishig ad maitaiig accouts, ad issuace ad destructio of cards. Oly the A/OPC is authorized to request the cotractor establish ew accouts. The A/OPC oversees the card program(s) for his or her agecy/orgaizatio ad establishes guidelies. Chages to authorizatio cotrols must be submitted to the cotractor by the A/OPC. Approvig Official (AO) A idividual tasked with reviewig the trasactios of cardholders to assure proper use of the purchase card. AOs make sure that purchases are ecessary for accomplishig the missio of the agecy. They may also be kow as reviewig or certifyig officials. Cardholder Ay idividual or agecy/ orgaizatio compoet desigated by the agecy/orgaizatio to receive a card. GSA SmartPay / GSA SmartPay 2 Cotracts maaged by GSA to provide fleet, travel, purchase ad itegrated charge cards to federal agecies/orgaizatios. Purchase Card A type of charge card issued by a GSA SmartPay 2 cotractor that is used to pay for supplies or services procured at the directio of a federal agecy/orgaizatio uder official purchase authority. The agecy is ivoiced for the purchases ad makes paymet directly to the bak. List of Acroyms A/OPC: Agecy/Orgaizatio Program Coordiator DSCC: Defese Supply Ceter Columbus OFPP: Office of Federal Program Procuremet Policy AO: Approvig Official FAR: Federal Acquisitio Regulatios UCMJ: Uited Code of Military Justice AFOSI: Air Force Office of Special Ivestigatio FBI: Federal Bureau of Ivestigatio USACI: U.S. Army Crimial Ivestigatio DCIS: DOD Crimial Ivestigative Service IG: Ispector Geeral USAID: U.S. Agecy for Iteratioal Developmet NCIS: Naval Crimial Ivestigative Service USC: U.S. Code USIA: U.S. Iformatio Agecy 22
25 Quick Referece Guide Cotract Specific Iformatio This Quick Referece Guide provides a A/OPC with a cosolidated look at the GSA SmartPay 2 Master Cotract. This guide will help you aswer questios about cotract terms ad coditios ad what your roles ad resposibilities are as a purchase card A/OPC. What is the scope of the GSA SmartPay 2 Master Cotract? The scope of the GSA SmartPay 2 Master Cotract is to provide a worldwide procuremet, paymet, ad fuctioal datastorage mechaism to support authorized purchases, expeses, ad/or streamlie purchase ad paymet systems for the fleet, travel ad purchase card programs, as well as a itegrated solutio. All fiacial, maagemet, ad admiistrative products ad services (curret ad emergig), which assist i the support of authorized purchases, expeses, ad/or streamlie purchase ad paymet systems, fall withi the scope of this cotract. Additioal requiremets may be icluded i the task order issued to your bak. What are the purposes of the Govermetwide Purchase Card Program? The purpose of the purchase card program are to: Provide commercial charge cards ad associated services i support of official govermet purchases; Streamlie orderig, paymet ad procuremet procedures, ad reduce admiistrative cost uder the simplified acquisitio threshold; Improve govermet operatios by simplifyig the fiacial process; ad Allow a platform to improve govermet operatios ad accoutability. Maagig Purchase Card Use: A Pla for Success 23
26 What type of cotract vehicle is used for the purchase card? The GSA SmartPay 2 Master Cotract is a fixed price, idefiite delivery, idefiite quatity (IDIQ) task order cotract. The cotract period for SmartPay 2 icludes a trasitioal period ad a trasactioal period. The trasitioal period bega o the date of award ad eds November 29, The trasactioal period (whe actual trasactios bega to be processed through systems belogig to/associated with successful offerors) bega as early as November 30, 2007, ad has a four-year base period, with oe four-year optio period, ad oe three-year optio period. What is a Cetrally Billed Accout? A Cetrally Billed Accout (CBA) is a card/accout established by the cotractor at the request of the agecy/orgaizatio or their desigee. These accouts may be card/ cardless ad paymets are made directly to the cotractor by the agecy/orgaizatio or their desigee. All purchase cards are set up uder a cetrally billed accout. How ca my agecy utilize Purchase Card Services? The agecy s chief fiacial officer, chief admiistrative officer, ad procuremet executive decide which bak will be issued a task order to provide purchase cards to the agecy. The task order will desigate who has authority withi the agecy to admiister the program (set up accouts, receive reports, etc.). The agecy may also choose to tag alog with aother agecy s task order to obtai more favorable terms. What are the basic roles ad resposibilities as the? Agecy Each agecy must desigate a Agecy/Orgaizatio Program Coordiator (A/OPC) who shall fuctio as the agecy s primary liaiso to the purchase card cotractor ad to GSA. The agecy must also idetify cardholders ad desigate a billig ad disputes office. A/OPC A A/OPC shall have the overall resposibility for the purchase card program withi his/her agecy/ orgaizatio. The A/OPC geerally serves as the focal poit for: Aswerig questios Cotract admiistratio Coordiatio of applicatios Issuace ad destructio of cards Establishmet ad review of reports Admiistrative traiig Establishmet of guidelies for the agecy/cardholder Moitorig fraud ad misuse withi their program 24
27 Cardholder Cardholders are resposible for: Uderstadig their respective agecy s policies ad procedures regardig the use of a purchase card; Usig the card for authorized purchases; Reportig lost or stole card; Keepig a record of purchases; Recocilig accout; ad Disputig trasactios i accordace with the bak s policy. AO The approvig official is resposible for: Coductig a idepedet review of cardholder trasactios; Esurig all charges are proper, meet agecy eeds, ad are recociled i a timely maer; ad Approvig mothly billig statemet. What olie tools are available to the A/OPC? The cotractor will provide a electroic access system i order for the A/OPC to implemet, maage, receive ad complete all reportig requiremets. The electroic access system will allow the A/OPC to view statemets, sed i program forms, set up accouts, maitai accouts, activate/deactivate accouts, update authorizatios, ad dowload reports. How are accouts set up ad cacelled? The A/OPC is resposible for the set up ad maiteace of all accouts. Accout set up forms must be completed for each cardholder ad approved by the A/OPC. You ca acquire the accout set-up forms from your official A/OPC guide or from your bak s Web site. Completed accout forms ca be set to the bak by fax, mail, , or the bak s electroic access system. I emergecy cases, a A/OPC ca give verbal directios to the bak to set up a accout with electroic/writte cofirmatio to the bak withi three busiess days. Settig up a coveiece check accout may also be accomplished by completig a bak-provided form. Whe ca the bak susped a accout? The bak shall otify the A/OPC ad the Desigated Billig Office (DBO) requestig paymet o udisputed past due accouts (45 days from billig date). The bak shall provide a pre-suspesio report to the A/OPC to idetify the udisputed overdue amouts. After 55 caledar days from the billig date, the bak shall otify the A/OPC ad the DBO electroically, or i writig, of suspesio if the paymet for the pricipal amout is ot received by the close of busiess o the fifth caledar day after otificatio. The bak is required to reistate, automatically suspeded accouts, upo paymet of the udisputed pricipal amout ad Prompt Paymet Act iterest. Maagig Purchase Card Use: A Pla for Success 25
28 Whe ca the bak cacel a accout? The bak has the discretio to iitiate cacellatio procedures o accouts. Cacellatio must be iitiated withi 180 caledar days of the billig cycle i which the charge appeared. If the bak iitiates cacellatio, it shall provide a presuspesio/pre-cacellatio report to the A/OPC to idetify the udisputed amout that is overdue. There are two reasos i which a bak may iitiate cacellatio: (1) the accout has bee suspeded two times durig a 12 moth period for udisputed amouts; or (2) the accout is 120 caledar days past the billig date ad suspesio procedures have bee met. After 120 caledar days past the billig date, the bak shall sed a letter to the A/OPC ad the DBO requestig paymet of the udisputed pricipal amout. If paymet is ot received by the close of busiess o the fifth caledar day after otificatio (126 days from the billig date), the bak may cacel the accout. The bak may, but is ot required to, reistate cacelled accouts upo paymet of the udisputed pricipal amout ad Prompt Paymet Act iterest. A/OPCs have the discretio to iitiate suspesio ad/or cacellatio procedures. They must documet the reaso for cacellatio or suspesio. What items caot be purchased with the card? It is the A/OPC s resposibility to coordiate, establish, set up, ad uderstad his or her agecy s policies ad procedures regardig the defiitio of authorized purchases. However, the GSA SmartPay 2 Master Cotract specifies that the followig items shall ot be purchased with the purchase card: Log-term retal or leasig of lad or buildigs; Travel or travel related expeses (except the purchase card may be used for meetig spaces, ad local trasportatio services, e.g., Metro fare cards, subway tokes, etc.); ad Cash advaces. How are ivoices issued ad processed? Ivoicig will occur o a mothly basis, uless otherwise specified by the agecy. The agecy policy shall iclude a process for a thorough maual or electroic recociliatio of all trasactios, debits ad charges posted to the accout durig the billig cycle. Settlemets for cetrally billed accouts are made directly by the agecy/ orgaizatio desigee. The cotractor shall accept paymet from multiple sources electroically ad post such paymets withi two busiess days of receipt of paymet to the agecy s specified accout. 26
There s Wealth in Our Approach.
Electroic Fud Trasfers/ Automated Clearig House Services There s Wealth i Our Approach. A divisio of RBC Capital Markets, LLC, Member NYSE/FINRA/SIPC. Electroic Fud Trasfers/Automated Clearig House Services
More informationAnti-Money Laundering
Ati-Moey Lauderig Over the last year, moey-lauderig crimes siphoed a estimated $1.3 trillio out of the global ecoomy.* I light of this staggerig statistic, the resultig striget legislatio is uderstadable.
More informationsummary of cover CONTRACT WORKS INSURANCE
1 SUMMARY OF COVER CONTRACT WORKS summary of cover CONTRACT WORKS INSURANCE This documet details the cover we ca provide for our commercial or church policyholders whe udertakig buildig or reovatio works.
More informationBest of security and convenience
Get More with Additioal Cardholders. Importat iformatio. Add a co-applicat or authorized user to your accout ad you ca take advatage of the followig beefits: RBC Royal Bak Visa Customer Service Cosolidate
More informationHandling. Collection Calls
Hadlig the Collectio Calls We do everythig we ca to stop collectio calls; however, i the early part of our represetatio, you ca expect some of these calls to cotiue. We uderstad that the first few moths
More informationLEASE-PURCHASE DECISION
Public Procuremet Practice STANDARD The decisio to lease or purchase should be cosidered o a case-by case evaluatio of comparative costs ad other factors. 1 Procuremet should coduct a cost/ beefit aalysis
More informationI apply to subscribe for a Stocks & Shares NISA for the tax year 2015/2016 and each subsequent year until further notice.
IFSL Brooks Macdoald Fud Stocks & Shares NISA trasfer applicatio form IFSL Brooks Macdoald Fud Stocks & Shares NISA trasfer applicatio form Please complete usig BLOCK CAPITALS ad retur the completed form
More informationFIRE PROTECTION SYSTEM INSPECTION, TESTING AND MAINTENANCE PROGRAMS
STRATEGIC OUTCOMES PRACTICE TECHNICAL ADVISORY BULLETIN February 2011 FIRE PROTECTION SYSTEM INSPECTION, TESTING AND MAINTENANCE PROGRAMS www.willis.com Natioal Fire Protectio Associatio (NFPA) #25 a mai
More informationInformation about Bankruptcy
Iformatio about Bakruptcy Isolvecy Service of Irelad Seirbhís Dócmhaieachta a héirea Isolvecy Service of Irelad Seirbhís Dócmhaieachta a héirea What is the? The Isolvecy Service of Irelad () is a idepedet
More informationFor customers Key features of the Guaranteed Pension Annuity
For customers Key features of the Guarateed Pesio Auity The Fiacial Coduct Authority is a fiacial services regulator. It requires us, Aego, to give you this importat iformatio to help you to decide whether
More informationMainStay Funds IRA/SEP/Roth IRA Distribution Form
MaiStay Fuds IRA/SEP/Roth IRA Distributio Form Do ot use for IRA Trasfers or SIMPLE IRA INSTRUCTIONS Before completig this form, please refer to the applicable Custodial Agreemet ad Disclosure Statemet
More informationFrance caters to innovative companies and offers the best research tax credit in Europe
1/5 The Frech Govermet has three objectives : > improve Frace s fiscal competitiveess > cosolidate R&D activities > make Frace a attractive coutry for iovatio Tax icetives have become a key elemet of public
More informationI apply to subscribe for a Stocks & Shares ISA for the tax year 20 /20 and each subsequent year until further notice.
IFSL Brooks Macdoald Fud Stocks & Shares ISA Trasfer Applicatio Form IFSL Brooks Macdoald Fud Stocks & Shares ISA Trasfer Applicatio Form Please complete usig BLOCK CAPITALS ad retur the completed form
More informationA GUIDE TO BUILDING SMART BUSINESS CREDIT
A GUIDE TO BUILDING SMART BUSINESS CREDIT Establishig busiess credit ca be the key to growig your compay DID YOU KNOW? Busiess Credit ca help grow your busiess Soud paymet practices are key to a solid
More informationHow To Find FINANCING For Your Business
How To Fid FINANCING For Your Busiess Oe of the most difficult tasks faced by the maagemet team of small busiesses today is fidig adequate fiacig for curret operatios i order to support ew ad ogoig cotracts.
More informationRevised Special Terms & Conditions
Call: 0191 505 0033* Lies are ope betwee 9am to 6pm Moday to Friday (excludig UK bak holidays) Email us: customerservice@highyieldaccout.co.uk** Write to us: High Yield Vaquis Bak, Freepost RSGY-CKJA-BKCS,
More informationConsider these sobering statistics
Idetity Theft is a form of fraud or Idetity theft cotiues to icrease every year ad has impacted millios of Americas. cheatig of aother perso s idetity i which someoe preteds to be someoe else by assumig
More informationBaan Service Master Data Management
Baa Service Master Data Maagemet Module Procedure UP069A US Documetiformatio Documet Documet code : UP069A US Documet group : User Documetatio Documet title : Master Data Maagemet Applicatio/Package :
More informationSavings and Retirement Benefits
60 Baltimore Couty Public Schools offers you several ways to begi savig moey through payroll deductios. Defied Beefit Pesio Pla Tax Sheltered Auities ad Custodial Accouts Defied Beefit Pesio Pla Did you
More informationBUY TO LET MORTGAGE APPLICATION FORM
BUY TO LET MORTGAGE APPLICATION FORM STAGE 2 OF 2 Please submit Stage 2 form to upgrade to full applicatio oce customer has read ad accepted the Mortgage Illustratio. Please complete this page if form
More informationFlorida Governor Rick Scott Signs Senate Bill 408 Into Law
JUNE 2011 Florida Goveror Rick Scott Sigs Seate Bill 408 Ito Law Florida Goveror Rick Scott siged Seate Bill 408 (SB408) ito law o May 17, 2011. The legislative itet of SB408 is to reform the ustable property
More informationInformation for Programs Seeking Initial Accreditation
Iformatio for Programs Seekig Iitial Accreditatio Aswers to Frequetly- Asked-Questios (from www.abet.org/ew-to-accreditatio/) Assurig Quality l Stimulatig Iovatio This documet iteds to aswer may of the
More informationSaudi Aramco Suppliers Safety Management System
Saudi Aramco Suppliers Safety Maagemet System SAFETY is Protectio (if oly we follow the rules) ''To live each day ijury ad violatio free, o ad off the job'' Foreword Foreword Saudi Aramco has developed
More informationAmendments to employer debt Regulations
March 2008 Pesios Legal Alert Amedmets to employer debt Regulatios The Govermet has at last issued Regulatios which will amed the law as to employer debts uder s75 Pesios Act 1995. The amedig Regulatios
More informationRISK TRANSFER FOR DESIGN-BUILD TEAMS
WILLIS CONSTRUCTION PRACTICE I-BEAM Jauary 2010 www.willis.com RISK TRANSFER FOR DESIGN-BUILD TEAMS Desig-builD work is icreasig each quarter. cosequetly, we are fieldig more iquiries from cliets regardig
More informationBajaj Allianz General Insurance Company Limited
Bajaj Alliaz Geeral Isurace Compay Limited Regd. Office & Head Office : GE Plaza, Airport Road, Yerawada, Pue - 411 006. PROPOSAL FORM FOR OFFICE COVER Importat : This proposal for isurace will be the
More informationCHAPTER 3 THE TIME VALUE OF MONEY
CHAPTER 3 THE TIME VALUE OF MONEY OVERVIEW A dollar i the had today is worth more tha a dollar to be received i the future because, if you had it ow, you could ivest that dollar ad ear iterest. Of all
More informationMaking training work for your business
Makig traiig work for your busiess Itegratig core skills of laguage, literacy ad umeracy ito geeral workplace traiig makes sese. The iformatio i this pamphlet will help you pla for ad build a successful
More informationHow to read A Mutual Fund shareholder report
Ivestor BulletI How to read A Mutual Fud shareholder report The SEC s Office of Ivestor Educatio ad Advocacy is issuig this Ivestor Bulleti to educate idividual ivestors about mutual fud shareholder reports.
More informationComputershare Investment Plan. Best Buy Co., Inc. Common Stock
Computershare Ivestmet Pla A Direct Stock Purchase ad Divided Reivestmet Pla for Best Buy Co., Ic. Commo Stock Best Buy Co., Ic. is listed o the New York Stock Exchage (Tradig Symbol BBY, CUSIP 086516101)
More informationWells Fargo Insurance Services Claim Consulting Capabilities
Wells Fargo Isurace Services Claim Cosultig Capabilities Claim Cosultig Claims are a uwelcome part of America busiess. I a recet survey coducted by Fulbright & Jaworski L.L.P., large U.S. compaies face
More informationFlood Emergency Response Plan
Flood Emergecy Respose Pla This reprit is made available for iformatioal purposes oly i support of the isurace relatioship betwee FM Global ad its cliets. This iformatio does ot chage or supplemet policy
More informationProfessional Networking
Professioal Networkig 1. Lear from people who ve bee where you are. Oe of your best resources for etworkig is alumi from your school. They ve take the classes you have take, they have bee o the job market
More informationDomain 1: Identifying Cause of and Resolving Desktop Application Issues Identifying and Resolving New Software Installation Issues
Maual Widows 7 Eterprise Desktop Support Techicia (70-685) 1-800-418-6789 Domai 1: Idetifyig Cause of ad Resolvig Desktop Applicatio Issues Idetifyig ad Resolvig New Software Istallatio Issues This sectio
More informationComparing Credit Card Finance Charges
Comparig Credit Card Fiace Charges Comparig Credit Card Fiace Charges Decidig if a particular credit card is right for you ivolves uderstadig what it costs ad what it offers you i retur. To determie how
More informationAssessment of the Board
Audit Committee Istitute Sposored by KPMG Assessmet of the Board Whe usig a facilitator, care eeds to be take if the idividual is i some way coflicted due to the closeess of their relatioship with the
More informationFinancial. Services Guide. Adviser: Graeme Hood CD, Dip FP, CFP Date of Preparation: 21/11/2005. Head Office Address:
Fiacial Services Guide Adviser: Graeme Hood CD, Dip FP, CFP Date of Preparatio: 21/11/2005 Head Office Address: Fiacial Wisdom Limited (ABN 70 006 646 108) Australia Fiacial Services Licece No. 231138
More informationHow To Write A Privacy Policy For A Busiess
Office of the Privacy Commissioer of Caada PIPEDA Privacy Guide for Small Busiesses: The Basics Privacy is the best policy Hadlig privacy cocers correctly ca help improve your orgaizatio s reputatio. Whe
More informationInvesting in Stocks WHAT ARE THE DIFFERENT CLASSIFICATIONS OF STOCKS? WHY INVEST IN STOCKS? CAN YOU LOSE MONEY?
Ivestig i Stocks Ivestig i Stocks Busiesses sell shares of stock to ivestors as a way to raise moey to fiace expasio, pay off debt ad provide operatig capital. Ecoomic coditios: Employmet, iflatio, ivetory
More informationPENSION ANNUITY. Policy Conditions Document reference: PPAS1(7) This is an important document. Please keep it in a safe place.
PENSION ANNUITY Policy Coditios Documet referece: PPAS1(7) This is a importat documet. Please keep it i a safe place. Pesio Auity Policy Coditios Welcome to LV=, ad thak you for choosig our Pesio Auity.
More informationAGC s SUPERVISORY TRAINING PROGRAM
AGC s SUPERVISORY TRAINING PROGRAM Learig Today...Leadig Tomorrow The Kowledge ad Skills Every Costructio Supervisor Must Have to be Effective The Associated Geeral Cotractors of America s Supervisory
More informationShareholder Information Brochure
The Ivestor Service ad Automatic Divided Reivestmet Program for Shareholders of Johso & Johso Shareholder Iformatio Brochure The Program is sposored ad admiistered by Computershare Trust Compay, N.A.,
More informationEngineering Data Management
BaaERP 5.0c Maufacturig Egieerig Data Maagemet Module Procedure UP128A US Documetiformatio Documet Documet code : UP128A US Documet group : User Documetatio Documet title : Egieerig Data Maagemet Applicatio/Package
More informationCREATIVE MARKETING PROJECT 2016
CREATIVE MARKETING PROJECT 2016 The Creative Marketig Project is a chapter project that develops i chapter members a aalytical ad creative approach to the marketig process, actively egages chapter members
More informationODBC. Getting Started With Sage Timberline Office ODBC
ODBC Gettig Started With Sage Timberlie Office ODBC NOTICE This documet ad the Sage Timberlie Office software may be used oly i accordace with the accompayig Sage Timberlie Office Ed User Licese Agreemet.
More informationConfiguring Additional Active Directory Server Roles
Maual Upgradig your MCSE o Server 2003 to Server 2008 (70-649) 1-800-418-6789 Cofigurig Additioal Active Directory Server Roles Active Directory Lightweight Directory Services Backgroud ad Cofiguratio
More informationINVESTMENT PERFORMANCE COUNCIL (IPC) Guidance Statement on Calculation Methodology
Adoptio Date: 4 March 2004 Effective Date: 1 Jue 2004 Retroactive Applicatio: No Public Commet Period: Aug Nov 2002 INVESTMENT PERFORMANCE COUNCIL (IPC) Preface Guidace Statemet o Calculatio Methodology
More informationAgency Relationship Optimizer
Decideware Developmet Agecy Relatioship Optimizer The Leadig Software Solutio for Cliet-Agecy Relatioship Maagemet supplier performace experts scorecards.deploymet.service decide ware Sa Fracisco Sydey
More informationINVESTMENT PERFORMANCE COUNCIL (IPC)
INVESTMENT PEFOMANCE COUNCIL (IPC) INVITATION TO COMMENT: Global Ivestmet Performace Stadards (GIPS ) Guidace Statemet o Calculatio Methodology The Associatio for Ivestmet Maagemet ad esearch (AIM) seeks
More informationPre-Suit Collection Strategies
Pre-Suit Collectio Strategies Writte by Charles PT Phoeix How to Decide Whether to Pursue Collectio Calculatig the Value of Collectio As with ay busiess litigatio, all factors associated with the process
More informationBank Secrecy Act. Job-specific BSA tracks Related case studies Suggested courses
Bak Secrecy Act Whether your bak is big or small, Bak Secrecy Act (BSA) compliace ofte feels overwhelmig due to the complexities ad related processes ad procedures surroudig this ever-chagig legislatio.
More informationGOOD PRACTICE CHECKLIST FOR INTERPRETERS WORKING WITH DOMESTIC VIOLENCE SITUATIONS
GOOD PRACTICE CHECKLIST FOR INTERPRETERS WORKING WITH DOMESTIC VIOLENCE SITUATIONS I the sprig of 2008, Stadig Together agaist Domestic Violece carried out a piece of collaborative work o domestic violece
More informationTell us if you need help because of a disability Ask for a free interpreter
Your rights uder Califoria Welfare Programs for people applyig for or receivig public aid i Califoria Tell us if you eed help because of a disability Ask for a free iterpreter 2 Your rights all people
More informationauction a guide to buying at Residential
Residetial a guide to buyig at auctio Allsop is the market leader for residetial ad commercial auctios i the UK Aually sells approximately 1 billio of property at auctio i the UK Holds at least seve residetial
More informationA guide to School Employees' Well-Being
A guide to School Employees' Well-Beig Backgroud The public school systems i the Uited States employ more tha 6.7 millio people. This large workforce is charged with oe of the atio s critical tasks to
More informationAbout our services and costs
About our services ad costs Cotets Whose products do we offer 2 Ivestmet 2 Isurace 2 Mortgages 2 Which services will we provide you with? 3 Ivestmet 3 Isurace 3 Mortgages 3 What will you have to pay us
More informationHow To Get A Kukandruk Studetfiace
Curret Year Icome Assessmet Form Academic Year 2015/16 Persoal details Perso 1 Your Customer Referece Number Your Customer Referece Number Name Name Date of birth Address / / Date of birth / / Address
More informationTIAA-CREF Wealth Management. Personalized, objective financial advice for every stage of life
TIAA-CREF Wealth Maagemet Persoalized, objective fiacial advice for every stage of life A persoalized team approach for a trusted lifelog relatioship No matter who you are, you ca t be a expert i all aspects
More informationInformation Security Compliance
T A Uified Approach to Iformatio Security Compliace By M. Peter Adler he iformatio age has led to a heighteed cocer that persoal iformatio is ot beig protected. The high speed at which private iformatio
More informationInternal control systems and fraud
3 Iteral cotrol systems ad fraud this chapter covers... This chapter starts where the last chapter fiished, by dealig with the exteral regulatios that affect accoutig practice. Some of these are required
More informationaround-the-clock care setting or within 72 hours of discharge, including from the organization s emergency department (ED)
Setiel Evets (SE) I. Setiel Evets The Joit Commissio adopted a formal Setiel Evet Policy i 1996 to help behavioral health care orgaizatios that experiece serious adverse evets improve safety ad lear from
More informatione-trader user guide Introduction
User guide e-trader user guide Itroductio At UK Geeral our aim is to provide you with the best possible propositio for you ad your customers. We believe i offerig brokers a choice of how they trade with
More informationHow to use what you OWN to reduce what you OWE
How to use what you OWN to reduce what you OWE Maulife Oe A Overview Most Caadias maage their fiaces by doig two thigs: 1. Depositig their icome ad other short-term assets ito chequig ad savigs accouts.
More informationPart 387. Minimum Levels of Financial Responsibility for Motor Carriers. Interstate and Intrastate Commerce
Part 387 Miimum Levels of Fiacial Resposibility for Motor Carriers Iterstate ad Itrastate Commerce 35 Part 387 Miimum Levels of Fiacial Resposibility for Motor Carriers (Iterstate ad Itrastate Commerce)
More informationArt & Private Client insurance policy SUMMARY OF COVER
Art & Private Cliet isurace policy SUMMARY OF COVER 2 SUMMARY OF COVER DIOCESAN SCHOOLS LEGAL EXPENSES INSURANCE ART AND PRIVATE CLIENT POLICY SUMMARY SUMMARY OF COVER 3 Policy ref: ME773 1 07/16 What
More informationThe future of global data management is here: modular, scalable and integrated. MasterCard smartdata.gen2
The future of global data maagemet is here: modular, scalable ad itegrated MasterCard smartdata.ge2 Revolutioize your data. Trasform your busiess. MasterCard smartdata.ge2 is a revolutioary web-based
More informationGrow your business with savings and debt management solutions
Grow your busiess with savigs ad debt maagemet solutios A few great reasos to provide bak ad trust products to your cliets You have the expertise to help your cliets get the best rates ad most competitive
More informationINDEPENDENT BUSINESS PLAN EVENT 2016
INDEPENDENT BUSINESS PLAN EVENT 2016 The Idepedet Busiess Pla Evet ivolves the developmet of a comprehesive proposal to start a ew busiess. Ay type of busiess may be used. The Idepedet Busiess Pla Evet
More informationDomain 1: Designing a SQL Server Instance and a Database Solution
Maual SQL Server 2008 Desig, Optimize ad Maitai (70-450) 1-800-418-6789 Domai 1: Desigig a SQL Server Istace ad a Database Solutio Desigig for CPU, Memory ad Storage Capacity Requiremets Whe desigig a
More informationThe Vehicle Warranty Products Code
The Vehicle Warraty Products Code Applyig to warraty admiistrators govered by the Tradig Stadards Istitute-approved guidelies Cotets Itroductio 3 Defiitios 4 Advertisig What our promise meas to you 6 What
More informationPUBLIC RELATIONS PROJECT 2016
PUBLIC RELATIONS PROJECT 2016 The purpose of the Public Relatios Project is to provide a opportuity for the chapter members to demostrate the kowledge ad skills eeded i plaig, orgaizig, implemetig ad evaluatig
More informationSmall Business Environmental Management Solutions. City of Onkaparinga
City of Okapariga Small Busiess Evirometal Maagemet Solutios Busiess SA is the leadig busiess orgaisatio i South Australia. It works hard o behalf of busiess to ifluece govermet decisios, attract ivestmets
More informationIntroducing Your New Wells Fargo Trust and Investment Statement. Your Account Information Simply Stated.
Itroducig Your New Wells Fargo Trust ad Ivestmet Statemet. Your Accout Iformatio Simply Stated. We are pleased to itroduce your ew easy-to-read statemet. It provides a overview of your accout ad a complete
More informationMaterial Management and
Cover Article Acquisitio of Property Through a Material Maagemet ad Accoutig System (MMAS) by Richard Culbertso, Three Rivers Chapter ad Waye Norma, CPPM, CF, Los Ageles Chapter Backgroud ad brief history
More informationCCH Accountants Starter Pack
CCH Accoutats Starter Pack We may be a bit smaller, but fudametally we re o differet to ay other accoutig practice. Util ow, smaller firms have faced a stark choice: Buy cheaply, kowig that the practice
More informationDetecting Voice Mail Fraud. Detecting Voice Mail Fraud - 1
Detectig Voice Mail Fraud Detectig Voice Mail Fraud - 1 Issue 2 Detectig Voice Mail Fraud Detectig Voice Mail Fraud Several reportig mechaisms ca assist you i determiig voice mail fraud. Call Detail Recordig
More informationDeath Beefits from Pacific Life
Ehace Your Fiacial Legacy Variable Auities with Death Beefits from Pacific Life 9/15 20188-15C FOR CALIFORNIA As You Pla for Retiremet, Protect Your Loved Oes A Pacific Life variable auity ca offer three
More informationSafeguarding Taxpayer Data A GUIDE FOR YOUR BUSINESS
Safeguardig Taxpayer Data A GUIDE FOR YOUR BUSINESS 1 Cotets The Need to Safeguard Taxpayer Data...3 Gettig Started...5 Puttig Safeguards i Place...6 Checklists 1 Admiistrative Activities...7 2 Facilities
More informationOnline Banking. Internet of Things
Olie Bakig & The Iteret of Thigs Our icreasigly iteretcoected future will mea better bakig ad added security resposibilities for all of us. FROM DESKTOPS TO SMARTWATCHS Just a few years ago, Americas coducted
More informationEnhance Your Financial Legacy Variable Annuity Death Benefits from Pacific Life
Ehace Your Fiacial Legacy Variable Auity Death Beefits from Pacific Life 7/15 20172-15B As You Pla for Retiremet, Protect Your Loved Oes A Pacific Life variable auity ca offer three death beefits that
More informationSeason s Greetings. President s Message
News SOLELY FOR BENEFIT December 2012 BOARD OF DIRECTORS PRESIDENT Tret White Pharmacists Associatio of Newfoudlad ad Labrador (PANL) SECRETARY/TREASURER Price Edward Islad Pharmacists Associatio (PEI)
More informationclient communication
CCH Portal cliet commuicatio facig today s challeges Like most accoutacy practices, we ow use email for most cliet commuicatio. It s quick ad easy, but we do worry about the security of sesitive data.
More information*The most important feature of MRP as compared with ordinary inventory control analysis is its time phasing feature.
Itegrated Productio ad Ivetory Cotrol System MRP ad MRP II Framework of Maufacturig System Ivetory cotrol, productio schedulig, capacity plaig ad fiacial ad busiess decisios i a productio system are iterrelated.
More informationCartrefi Hafod Lettings Agency
Cartrefi Hafod Lettigs Agecy The ame you ca trust LANDLORD BOOKLET Cartrefi Hafod Lettigs Agecy Cartrefi Hafod Lettigs Agecy offer help to iexperieced ladlords to maage their homes. Hafod Housig Associatio
More informationPrescribing costs in primary care
Prescribig costs i primary care LONDON: The Statioery Office 13.50 Ordered by the House of Commos to be prited o 14 May 2007 REPORT BY THE COMPTROLLER AND AUDITOR GENERAL HC 454 Sessio 2006-2007 18 May
More informationAPPLICATION FORM. Henderson Investment Funds. Valid from 11 May 2015. SECTION 1 About yourself
Hederso Ivestmet Fuds APPLICATION FORM Valid from 11 May 2015 You should use this form if you wish to ivest i the Hederso Ivestmet Fuds rage. Further iformatio is cotaied i the Prospectus, the Additioal
More informationPublic Safety Canada. Internal Audit of Talent Management. Final Audit Report
Public Safety Caada Iteral Audit of Talet Maagemet Fial Audit Report November 2011 Audit of Talet Maagemet Table of Cotets 1.0 Executive Summary 3 2.0 Backgroud 10 2.1 Audit Objective 11 2.2 Audit Scope
More informationFinancial Service Guide (FSG)
Fiacial Service Guide (FSG) Effective date: 06 August 2015 icorporatig member product guide Savigs Term Deposits Paymet Services Isurace Home Loas Credit Facilities Police Bak Ltd ABN 95 087 650 799. AFSL/Australia
More informationOccupational Safety and Health Act of 1970
Occupatioal Safety ad Health Act of 1970 To assure safe ad healthful workig coditios for workig me ad wome; by authorizig eforcemet of the stadards developed uder the Act; by assistig ad ecouragig the
More informationHealth and dental coverage that begins when your group health benefits end
Health ad detal coverage that begis whe your group health beefits ed Uderwritte by The Maufacturers Life Isurace Compay Page 1 of 5 FollowMeTM Health ca be your solutio. Life is full of chages. Some are
More informationBasic Current Account
Curret Accouts Basic Curret Accout Applicatio form Please fill i the form usig BLOCK CAPITALS ad black ik. Tick ay boxes which apply. Satader is able to provide literature i alterative formats. The formats
More informationApplying to manufacturers governed by the Trading Standards Institute-approved guidelines
The New Car Code Applyig to maufacturers govered by the Tradig Stadards Istitute-approved guidelies Cotets Itroductio 3 Defiitios 4 Advertisig Our advertisig promise 5 What our promise meas to you 5 We
More informationGet advice now. Are you worried about your mortgage? New edition
New editio Jauary 2009 Are you worried about your mortgage? Get advice ow If you are strugglig to pay your mortgage, or you thik it will be difficult to pay more whe your fixed-rate deal eds, act ow to
More informationThe Forgotten Middle. research readiness results. Executive Summary
The Forgotte Middle Esurig that All Studets Are o Target for College ad Career Readiess before High School Executive Summary Today, college readiess also meas career readiess. While ot every high school
More informationXantaro Maintenance Services & Operations. XTAC User Guide. UK Edition
Xataro Maiteace Services & Operatios XTAC User Guide UK Editio XTAC WORKFLOW The Xataro Techical Assistace Cetre (XTAC) is the cetral iterface for all techical questios ad topics for products ad services
More informationII. Goals of the Sentinel Event Policy
Setiel Evets (SE) I. Setiel Evets I support of its missio to cotiuously improve the safety ad quality of health care provided to the public, The Joit Commissio i its accreditatio process reviews hospitals
More informationMarine and Aviation Insurance (War Risks) Fund Account 2011-2012
Preseted to Parliamet pursuat to Sectio 5(4) of the Marie ad Aviatio Isurace (War Risks) Act 1952 Marie ad Aviatio Isurace (War Risks) Fud Accout 2011-2012 LONDON: The Statioery Office HC 446 6.25 Preseted
More information(VCP-310) 1-800-418-6789
Maual VMware Lesso 1: Uderstadig the VMware Product Lie I this lesso, you will first lear what virtualizatio is. Next, you ll explore the products offered by VMware that provide virtualizatio services.
More informationCode of Ethics and Business Conduct
Code of Ethics ad Busiess Coduct OUR CORE VALUES Safety, Ethics, Excellece, Oe Domiio Table of Cotets Ethics ad Compliace Our Shared Resposibility 2 Our Commitmet to Fellow Employees 6 Our Commitmet to
More informationPreserving Your Financial Legacy with Life Insurance Premium Financing.
Preservig Your Fiacial Legacy with Life Isurace Premium Fiacig. Prepared by: Keeth M. Fujita, Natioal Director, The Private Bak Specialty Fiace Group Life Isurace Premium Fiace. James Mosrie, Seior Wealth
More information