The Office of Finance consists of five major functional areas:
- ♦ Office of the Controller
- ♦ Financial Planning and Budget Analysis
- ♦ Procurement Services
- ♦ Contract and Grant Accounting
These areas are responsible to the Associate Vice Chancellor for Finance who reports to the Vice Chancellor for Finance and Administration.
The offices of the Office of Finance are located as follows:
- ♦ Office of the Controller – 821 Boyd Street
- ♦ Financial Planning and Budget Analysis – Mossman Administration Building, Room 243
- ♦ Contract and Grant Accounting – 2511 HHRA Building
- ♦ Procurement Services – 840 Neal Street
Accounting – University Concepts
Accounting in a university is the means by which financial data are made available for efficient administration. A State university is in the nature of public trusts. Therefore, the inherent obligations for stewardship and accountability necessitate a system of accounting that ensures control and complete disclosure of the results of its operation and of financial position.
The University follows the fund accounting and reporting guidelines recommended by the National Association of College and University Business Officers (NACUBO) and the American Institute of Certified Public Accountants (AICPA) guided by the standards of the Governmental Accounting Standards Board (GASB). Certain concepts are embodied in the financial accounting system for The University of North Carolina at Greensboro which differ from private enterprise. Higher educational institutions are created to carry out the function of instruction, research and public service rather than to produce profits. The user of higher education financial data, therefore, must focus on the sources and uses of institutional resources and the way in which those uses contribute to the attainment of the institution’s objectives. To satisfy the requirement to account properly for the diversity of resources and their uses, the principles and practices of “fund accounting” are employed. Refer to Policy 4 for definitions of ” fund accounting”.
To observe limitations and restrictions placed on the use of the resources available to the University, the resources of the University are maintained in accordance with the principles of fund accounting. Resources for various purposes are classified into funds that are in accordance with activities or objectives specified. Separate resources are maintained for managing these resources on a daily basis; however, for reporting purposes, funds with similar characteristics are combined into fund groups and reported accordingly.
Within each fund group, fund balances restricted by outside sources are so indicated and distinguished from unrestricted funds allocated for specific purposes. Externally restricted funds may be utilized in accordance with the purposes established by the source of such funds and are contrasted with unrestricted funds which may be used in achieving any of the University’s institutional purposes.
Current Funds represent unrestricted and restricted resources which are available for the operating purposes of performing the primary missions of the University. Included are the University’s auxiliary enterprises which are managed as self-supporting activities and exist to furnish goods or services to students, faculty and staff.
Current Funds at the University must consist of two subgroups – Unrestricted and Restricted. Unrestricted Current Funds include all resources received for which no stipulation was made by the donors or other external agencies as to purposes for which they should be expended. It includes, by definition, all federal and state appropriations. The University’s auxiliary enterprises are also unrestricted current funds. Restricted Current Funds are those resources available for financing operations, but which are limited by donors and other external agencies to specific purposes, programs, departments or line items, e.g., contract and grant monies.
Loan Funds represent resources received from donors, governmental agencies, and mandatory institutional matching grants which are restricted for use in making loans to students.
Endowment Funds represent those resources received from benefactors who stipulate the principal of their gifts be invested and only the generated income be utilized. Also included in this fund group are quasi-endowment funds, which the University, rather than the donor, has determined that the resources are to be retained and invested. The Board of Trustees has adopted the policy that spending (monies available for current use) from the Fund in any one fiscal year shall not exceed a specified percentage of the “average market value” of the Fund. The specified percentage is determined by the Board each year. The “average market value” is defined as an average of the market values on December 31 of the previous three years. This statement is issued by the Board and governs the maximum spending allowable from the Fund. The actual spending rate may be less than the specified percentage rate due to the economic environment.
The Plant Funds group consists of:
- ♦ resources to be used for the acquisition of physical properties for institutional purposes but unexpended at the date of reporting;
- ♦ resources set aside for the renewal and replacement of institutional properties and for debt service charges and the retirement of indebtedness on institutional properties; and
- ♦ resources expended for and thus invested in institutional properties. Assets of the investment in plant subgroup consist of land; buildings and infrastructures; equipment; and Construction in Progress.
Agency Funds are resources held by an institution which acts as custodian or fiscal agent for others, e.g., student organizations.
The Office of the Controller of Finance consists of: the General Accounting unit, the Financial Systems and Reporting unit, and the Cashiers and Student Accounts unit. A brief description of the functional responsibilities of each section of the Office of the Controller is as follows:
The General Accounting unit is responsible for all funds which flow out of the University. These responsibilities include processing all University payments for goods and services (in accordance with State and Federal requirements), administering proper budgetary controls, maintaining the University’s fixed asset system, cash management, and reconciliation of the University’s and Office of State Controller cash records. This section is also responsible for project accounting for Capital Improvement budget codes and Repair and Replacement projects.
The General Accounting Section also includes the Payroll section. The Payroll section is responsible for the preparation of all payrolls and for rendering timely and accurate payroll payments to all employees. The Payroll section ensures that all payroll deductions have been properly authorized. This section is also responsible for the preparation of the necessary reports for all statutory deductions; remittance of all authorized deductions to the proper governmental agencies and private companies; and maintenance of all records required for state and federal agencies and the University. The Payroll section is also responsible for the annual issuance of all Federal W-2 forms to employees. Individuals should contact the Payroll section for information or inquiries concerning payroll items.
Financial Systems and Reporting
The Financial Systems and Reporting section is responsible for the continued maintenance of the Banner Finance system which includes; chart of accounts updates, organizational changes, check writing, and data control. This section is also responsible for all University internal and external financial reporting, debt service accounting, loan fund accounting, and the interface of the Banner Finance system with State of North Carolina Accounting System and the UNC DATAMART. Individuals should contact the Financial Systems and Reporting section with inquiries concerning fund codes, organization codes, organizational code changes, and responsible persons.
The Cashiers and Student Accounts section serves as a depository for the cash receipts collected by University departments and organizations and for maintaining student account and student loan records. This section is responsible for the appropriate charging, billing, and timely collecting of student tuition and fees, student loans, and other debts owed to the University. Students should contact the Cashiers and Student Accounts Office concerning questions and/or inquiries about their account or loan.
All requests for the establishment of an institutional trust fund must be documented. Refer to Policy 10.1 on Gift receipting and Reporting, in the subsection entitled “Establishing New Funds,” for information on establishment of an institutional trust fund to receive unrestricted and restricted gifts to the University. For institutional trust funds not funded by gifts, the department requesting the fund to be established must prepare form FIN-04, Request for Institutional Trust Fund, and submit it to the Office of the Controller, 821 Boyd Street, with the documentation attached. A detailed and comprehensive description of the activities, programs, and/or operations to be supported by the fund must be provided on the form. Also, any specific restrictions, terms, or conditions for the use of monies deposited to this fund must be indicated on the FIN-04 form. Additionally, photocopies of correspondence, agreements, award letters and other relevant documentation must be attached. Refer to Procedure Number 5 for a sample of form FIN-04.
Upon receipt of the form in the Office of the Controller, the documentation is reviewed. If additional documentation is required, the department/individual(s) making the request to establish the fund will be contacted. No further action is taken until all documentation is complete. It should be noted that certain funds cannot be established until an award or funding authority is received from the funding agency, e.g. contract and grant accounts.
Each request to establish a fund must be approved by the University Controller. After approval, a fund number is established and the requesting department/individual(s) is notified by email from the Office of the Controller. Please allow a minimum of 10 business days for funds to be established.
The administration of The University of North Carolina at Greensboro, being mindful of its responsibilities to manage funds from all sources which are entrusted to it for carrying out its programs and activities, deems it advisable to promulgate written policies, guidelines, and procedures for the prudent expenditure of those funds. Such policies assist the University in meeting its obligations of public accountability and responsibility to the State of North Carolina and to other constituencies which have made those funds available. Our responsibility is to facilitate the support of quality programs while ensuring that resources for those programs are spent legally and wisely. The State Auditor, and other relevant agencies, have insisted upon certain standards.
These policies, guidelines, and procedures are applicable without exception to all funds owned or administered by The University of North Carolina at Greensboro. All expenditures of the University are to be consistent with applicable State and Federal laws and regulations; any restrictions, rules, or regulations placed on the use of the funds by donors and granting or contracting agencies; and prudent management practices. In addition, all expenditures from University funds must be reasonable and necessary for carrying out the programs and activities of the University, and are to be documented in a way which clearly substantiates such reasonableness and necessity.
Procurement Services Policies And Procedures
Before expenditures are made against any University funds, there must be evidence that the Procurement Services policies and procedures have been followed, thereby ensuring that a valid commitment of University funds has been made. Obligations incurred by any employee of the University in conflict with the Procurement Services policies and procedures become personal obligations of the employee and not of the University. For a more precise and detailed description of those policies and procedures relating to purchasing commitments, reference should be made to the Procurement Services Section of the Policies and Procedures Manual.
Approval Of Expenditures
Signature of the appropriate person responsible for a fund, or a designee, is required for expenditures to be made against the fund. Since there are a number of ways in which obligations are incurred and expenditures made, the signature of the fund holder is required on those documents pertinent to the situation. The individual with fund responsibility (usually a Department Head, Director, Dean or other management level position) has ultimate responsibility for all transactions for their fund(s) and are held accountable.
Purchases not requiring approval from Procurement Services prior to purchase. Items qualifying as purchases of this nature are specified explicitly by Procurement Services:
- ♦ Expenditure Authorization (Procedure 2), Form BANFIN-32
- ♦ Interdepartmental Invoices (Procedure 6), Forms BANFIN- 59, 60, 66, 69, 72
In addition, prior to the time a check is written, each request for expenditure must be signed on behalf of the Vice Chancellor for Finance and Administration by a designated employee of the Office of Finance. Requests for expenditures not meeting the documentation standards and other guidelines must be rejected, and a reason for such rejection clearly stated. Unless the problem is resolved by the requesting account holder, the Vice Chancellor for Finance and Administration, who has final authority in resolving all questions relating to validity of expenditures, will not approve the payment.
Documentation Standards For Expenditures
Expenditures require the following documentation:
- ♦ Original Invoice from the vendor.
- ♦ Authorized Signature(s) of Fund Holder(s) or designee on the documents indicted in the section above relative to Approval of Expenditures.
- ♦ Evidence of receipt of goods/services including the Date on which the goods and/or services were received or performed and the signature of the person receiving the good, using the on-line receipt system, as applicable. Expenditure authorizations must be filed within 45 days of the date of the invoice/receipt.
- ♦ Expenditure Authorization (Procedure 2), Form BANFIN-32, for those purchases not requiring approval from Procurement Services prior to purchase.
- ♦ Petty Cash Establishment/Reimbursement (Procedure 1), Form BANFIN-34, for expenditures made using petty cash funds.
- ♦ Other pertinent supporting schedules and/or information required to document the expenditure. For example, entertainment expenditures require identification of persons or group being entertained, the location of the entertainment, and the purpose of the entertainment.
- ♦ Voucher form indicating account distribution of expenditures and approval for payment.
Documentation standards for travel expenditures are documented in the Travel Section of the Policies and Procedures Manual.
State Restrictions On Expenditures
The State of North Carolina forbids or restricts the expenditures of State Appropriated Funds for the following:
- ♦ Employee’s moving expenses
- ♦ Entertainment
- ♦ Alcoholic Beverages
- ♦ Gifts
- ♦ Honoraria for employees*
- ♦ Excess travel expenditures unless allowed in Travel policies of the State. (See Travel Section of the Policies and Procedures Manual.)
*Such payments are additional payments to the employee’s salary.
University Funds Restrictions On Expenditures
University funds are restricted or may not be expended for the following:
- ♦ Honoraria for employees must be treated as additional payments to the employee’s salary and processed through Human Resources/Payroll system.
- ♦ Business gifts must be authorized by the appropriate Vice Chancellor or Chancellor and cannot exceed fifty dollars($50.00). They must be paid from a discretionary fund funded by Chancellor discretionary allocation.
- ♦ Travel expenditures must be consistent with Travel policies and procedures. Refer to Travel Section of the Policies and Procedures Manual.
- ♦ Entertainment expenditures must be consistent with Busines Entertainment policies. Refer to Policy 8.
- ♦ Expenditures must be consistent with the restrictions placed on the fund by the donor or the University.
Invoices for payment of goods and services (except payroll) are processed normally within ten (10) working days after receipt of the required documentation in the Office of the Controller. Refer to Policy Number 7, relative to Documentation Standards for Expenditures and for Approval of Expenditures. Failure to submit the proper documentation delays the invoice processing and generation of payment. If the incomplete or missing documentation pertains to the Receiving Copy of the Purchase Order, or to an Expenditure Authorization or Petty Cash Establishment/Reimbursement, the individual responsible for the fund is notified and no further action is taken until all documentation is complete. If there is a deficiency relative to the vendor invoice, it is resolved by the Office of the Controller and/or Procurement Services. If an interdepartmental invoice cannot be paid due to insufficient budget or another reason, the invoice is returned to the campus vendor.
If extenuating and non-recurring circumstances create the immediate need for a University check, an emergency check is prepared. Such emergency requests must be submitted on form BANFIN-32, Expenditure Authorization (Procedure 2), with supporting documentation to the Office of the Controller before 11:00 A.M. The emergency check will be available by 2:00 P.M. on the next working day. The supporting documentation must include a written substantiation of the need for an emergency check.
Telephone Charges – Direct Charge
All telephone charges – base and long distance charges – are charged directly to the University fund of the appropriate University department/school or office which established the telephone service. Each University department, school or office is responsible for analyzing their telephone charges to determine if any charges are to be reimbursed to the department.
Reimbursement of Telephone Charges From a University Fund
Reimbursement of telephone charges by one University fund to another is accomplished utilizing the form BANFIN-33, Interdepartmental Invoice (Procedure 6). This form is used if any portion of the telephone charges – base and/or long distance charges – should be paid from another University fund. The person responsible for the University fund that should be charged must prepare an Interdepartmental Invoice and submit it to the person/department responsible for the fund originally charged. The information provided on this form indicates the fund that is to be charged and the fund to which the deposit is to be made for reimbursement. The completed Interdepartmental Invoice is submitted to the Office of the Controller which will deposit the reimbursement with Cashier’s. Telephone charges against a contract or grant after their termination date are the responsibility of the department.
University personnel should not charge personal calls on University telephones. If an employee should improperly charge personal telephone calls to the University, it is the department’s responsibility to collect reimbursement from the employee and deposit with Cashier’s such reimbursement to the proper fund.
Interdepartmental Invoices must be utilized for all purchases of goods and/or services by any university department from any other university department. The Interdepartmental Invoice authorizes payment of the order; therefore, it is utilized as the authority to direct charge the cost of the purchase to the university fund stated on the form. Interdepartmental invoices representing reimbursement of expenditures must be deposited in the fund and account code where the original expense was incurred. There is no sales tax charged on sales between university departments. The University Bookstore and Food Service operations are contracted to private companies.
The university department providing the goods and/or services is referred to as the campus vendor. Five campus vendors are responsible for most interdepartmental activity and likewise must supply their unique version of the Interdepartmental Invoice for campus use. These major campus vendors and their Interdepartmental Invoice forms are as follows:
- ♦ Physical Plant | BANFIN-59 →
- ♦ Telephone Service | BANFIN-66 →
- ♦ University Bookstore | BANFIN-60 →
- ♦ University Food Service | BANFIN-69 →
Campus vendors other than those listed above utilize the BANFIN-33, Interdepartmental Invoice. Refer to Procedure Number 6 for the procedures relative to the use and preparation of Interdepartmental Invoices.
The Departmental Sales Invoice, BANFIN-35, is utilized by university departments to bill for the sale of goods and/or services to customers who are not departments within the University.
Application of Policy
All persons rendering services to the University must be paid through the Payroll System except those contracted as an independent contractor. Procurement Services Policy 4.10 provides information on the procurement of Contracted Personal Services.
Types of Employment Relationships
There are four common types of employment relationships recognized by the Internal Revenue Service. These relationships are:
- ♦ an independent contractor;
- ♦ a common law employee;
- ♦ a statutory employee; or
- ♦ a statutory nonemployee.
An Independent Contractor
Individuals who follow an independent trade, business or profession, are generally not employees. This category includes lawyers, contractors, subcontractors, accountants, auctioneers, and others who offer their services to the general public. The general rule of thumb is that an individual is an independent contractor if the employer has the right to control or direct only the result of the work and not the means and method used to accomplish the result.
Common Law Employee
Under the old common law rules, every individual who performs services that are subject to the will and control of an employer, as to what must be done and how it must be done, is an employee. The University’s faculty and staff are in this category.
If there is an employee relationship it makes no difference how it is described. Consequently, it does not matter if the employee is called an employee, agent or independent contractor. It does not matter how the payments are measured, how they are made, or what they are called. Also, it does not matter if the employee is full-time, part-time or is hired only for a short period.
Two of the usual characteristics of an employer-employee relationship are that the employer has the right to discharge the employee and the employer supplies the tools and a place for him/her to work. In an employee relationship it does not matter whether the individual is employed full-time or part-time and there is no distinction between classes of employees, i.e., managers, supervisors or other types of personnel.
A statutory employee is an individual who works for an employer but is not an employee within the meaning of a common law employee as described above.
Examples include someone paid on commission, full-time life insurance sales agents and full-time traveling or city salespersons. This employment relationship is generally not applicable for the University. If additional information is needed concerning this type of employment relationship, the Office of the Controller should be contacted.
This category includes direct sellers, licensed real estate agents, and certain companion sitters. This employment relationship is generally not applicable for the University. If additional information is needed concerning this type of employment relationship, the Office of the Controller should be contacted.
Criteria to Distinguish Employee or Independent Contractor Relationship
See the Internal Revenue Service – Publication 15-A – Employer’s Supplemental Tax Guide, pages 6 thru 8
Other Stipulations for the Use of Independent Contractors
- ♦ Contracted service fees from federal funds may not be paid to a full-time employee of the federal government.
- ♦ Services to be provided are essential and cannot be provided by persons receiving salary support in the area of responsibility.
- ♦ A selection process has been employed to secure the most qualified individual available, considering the nature and extent of services to be required.
- ♦ The charge is appropriate considering the qualifications of the consultant, his/her normal charges, and the nature of the services to be provided.
- ♦ Transportation and subsistence will be the responsibility of the consultant. (In those situations where it would not be practical for the contractor/honorarium recipient to include expenses in the contract, the contract will lay out the terms for expense reimbursement to comply with state policies.)
- ♦ Full-time University and other state employees are not authorized to be paid consultant fees by the University. This restriction also applies to corporations and partnerships in which an employee of the University or faculty member serves as either a principal or employee. Issues involving conflict of interest are subject to state criminal statues.
- ♦ Intra-university consultation payments to faculty members are not permitted. Payments can be made only to the faculty member’s home department or school. Such funds are to be used for furtherance of department or school programs or activities and not for supplementary salary or equivalent payments to the faculty member. In effect, intra-university consultation represents a donation of services by the faculty member.
Tax Reporting and Withholding Requirements
Independent Contractors. The University does not have to withhold or pay income or social security taxes on payments made to independent contractors. Individual independent contractors are responsible for these taxes as well as the self-employment tax. Independent contractors will be sent a Form 1099-Misc at the end of the year if the payment made during the year aggregate to more than $600. Backup withholding may be required if the independent contractor does not furnish the University with a Taxpayer Identification Number.
Nonresident Independent Contractors: The University withholds 4% income tax from nonresident contractors who are paid more than $1,500 during a calendar year for a performance, an entertainment, an athletic event, a speech, or the creation of a film, radio, or television program. Nonresident entities are defined as: a foreign (out-of-state) limited liability company or a foreign limited partnership.
No tax is required to be withheld from partnerships that have a permanent place of business in North Carolina. The partnership must furnish the University their taxpayer identification number and address to be eligible for this exception.
No tax is required to be withheld from a foreign limited liability company or foreign corporation that has obtained a certificate of authority from the N.C. Secretary of the State. The identification number provided by the N.C. Secretary of the State must be furnished to the University to qualify for the exception. This is not the same as a federal identification number.
Common-law Employees. The University’s faculty and staff are in this category. Federal income taxes, state income taxes, FICA taxes, and medicare taxes are withheld on payments made to common-law employees. In addition, the University is responsible for the employer’s matching portion of FICA and medicare taxes and must make contributions to the Employment Security Commission or to the Trust Fund set up to cover payments to eligible unemployment compensation recipients. Common-law employees will receive a Form W-2 at the end of the calendar year for all compensation received during the year.
Statutory Employees. The Office of the Controller should be contacted if it appears this category of employee relationship exists.
Statutory Nonemployees. The Office of the Controller should be contacted if it appears this category of employee relationship exists.
A cash fund to make low-cost, infrequent purchases or to provide change for the cash receipting function may be requested. All purchases of equipment must be requested through Procurement Services on a “Procurement Services Requisition”. All purchases of capitalized fixed assets must be done in accordance with Policy 7.8 – Fixed Assets.
The custodian of the cash fund is responsible for keeping the fund in a secure location and not a personal checking account, and must be able to account for the fund at all times. The cash fund must be available for audit by the Internal Auditor and by the N.C. Office of the State Auditor.
Petty cash expenditures are limited to $100.00 per purchase. Reimbursements must be filed within 45 days of the date of expenditure. Refer to Procedure Number 1 for an explanation of the operation of a cash fund.
University checks for the payment of goods and services (except payroll) can be converted to a foreign currency if circumstances require. The department should make a written request and clearly indicate the foreign currency and amount needed. All normal expenditure documentation standards must be met. A university check will be written in U.S. dollars and payable to the commercial bank used by the University based on the current currency exchange rate. The bank will then issue a check payable to the appropriate vendor in the foreign currency needed.
The sale of goods and/or services by university departments to customers who are not departments within the University must utilize the Departmental Sales Invoice, BANFIN-35. The departmental sales invoice authorizes the Cashier’s Office to receive payment and deposit the funds to the appropriate departmental fund. The sales tax portion of the remittance is sent to the N.C. Department of Revenue by the Office of the Controller.
If a departmental sales invoice is not paid, the Cashier’s Office sends a past due notice to the customer. Departmental sales invoices which remain unpaid are returned to the originating university department.
The sale of goods and/or services by university departments to other university departments must utilize the interdepartmental invoice. Refer to Policy Number 7.3 for information on use of interdepartmental invoices.
The University’s Fixed Assets Section has procedures in place to ensure compliance with the North Carolina Office of the State Auditor, North Carolina Office of the State Controller, University of North Carolina Finance Improvement and Transformation Project Capital Assets Standards, Generally Accepted Accounting Principles, federal and state laws, and private granting agencies regulations. The accountability, proper care, maintenance and security to prevent misuse or loss for all UNCG personal property is delegated to vice chancellors, deans and department heads, depending on their division or area of responsibility. Non-numbered tags are available to departments for identifying additional equipment not recorded on the Fixed Assets System. Departments are encouraged to maintain an in-house inventory of all equipment items purchased (particularly, equipment which may be sensitive to theft or misappropriation or that is insured), regardless of whether the item is recorded on the Fixed Assets System. Department heads appoint a permanent employee as designee to assist with the daily care of property within individual departments and to assist with the annual physical inventory process.
UNCG capitalizes fixed asset purchases of vehicles, machinery, furniture, equipment, works of art and historical treasures, and all other tangible assets used in operations with a cost of $5,000 or greater and a useful life of two years or more; otherwise the expenditure is recorded as an operating expense in the fiscal year incurred. Capitalized equipment is barcode tagged and physically inventoried annually.
Purchases of land, improvements to land, buildings, building improvements, easements, infrastructure, and intangible assets are capitalized within the guidelines of the Office of the State Controller.
The sale of UNCG fixed assets is not permitted by individuals or departments. In addition, UNCG equipment cannot be donated, thrown away or discarded. All UNCG fixed assets should be disposed through the Warehouse Services and Surplus Property office. Departments may contact the Warehouse Services and Surplus Property at 336-334-5927 with questions regarding disposal of an asset.
UNCG elected to use the straight-line method of depreciation with the half-year convention and assumed salvage value of zero. Land, certain land improvements, construction-in-progress, and inexhaustible works of art, historical treasures and similar assets are not depreciated.
The 1997 session of the General Assembly enacted legislation which requires the University to withhold 4% for State income tax on non-wage compensation paid to nonresident (i.e. out-of-state) contractors for personal services unless certain criteria are met.
The tax withholding requirement applies to payments made on or after January 1, 1998. The tax withholding requirement does not apply to purchases of goods, but rather is limited to the purchase of services. Also the new tax withholding requirement does not affect the payments of salaries and wages made to University faculty, staff, student, and temporary employees. The new requirement does affect payments made to independent contractors, partnerships, corporations, and other businesses. Payments for personal services are currently processed several ways. The Contracted Services/Honoraria (form BANCPS), Expenditure Authorization (form BANCPS), and the Purchase Requisition can be used to pay for some form of personal services. The Accounts Payable department will review the disbursements made using these various methods and ensure that the new tax withholding and reporting requirements are followed.
Frequently Asked Questions
Nonresident Individual: The withholding requirement applies to an individual who does not reside in North Carolina.
Nonresident Entity: The withholding requirement applies to nonresident entities which are defined as:
- • a foreign* limited liability company
- • a foreign limited partnership or a general partnership formed under the laws of any jurisdiction other than NC
- • a foreign corporation
*For purpose of this legislation, “foreign” means out-of-state.
Nonresident Individual: Non-wage compensation payments for personal services performed in NC are subject to the withholding requirement.
Nonresident Entity: Non-wage compensation payments for personal services performed in NC are subject to the withholding requirement.
Nonresident Individual: Withholding is required only if compensation is for services performed in North Carolina. The “duty day” method should be used to allocate compensation for services performed both in NC and other states. Refer to the explanation regarding the “duty day” allocation method listed below.
Nonresident Entity: Withholding is required only if compensation is for services performed in North Carolina. The “duty day” method should be used to allocate compensation for services performed both in NC and other states. Refer to the explanation regarding the “duty day” allocation method listed below.
Nonresident Individual: 4% of the non-wage compensation amount.
Nonresident Entity: 4% of the non-wage compensation amount.
Nonresident Individual: January 1, 1998 for all personal services.
Nonresident Entity: The effective date depends on the type of personal services being provided.
- • January 1, 1998 for personal services related to a performance, an entertainment or athletic event, the creation of a film or a TV program, or the construction or repair of a building or highway.
- • January 1, 1999 for all other personal services.
Nonresident Individual: Yes. Payments to ordained or licensed members of the clergy are not subject to withholding.
Nonresident Entity: Yes. Tax is not withheld from:
- • a limited liability company that has obtained a certificate of authority from the NC Secretary of State,
- • a foreign limited partnership that has a permanent place of business in NC,
- • a foreign corporation that has obtained a certificate of authority from the NC Secretary of State.
Nonresident Individual: A certificate of authority does not apply to individuals.
Nonresident Entity: A certificate of authority does not apply to partnerships. A limited liability company or foreign corporation may obtain an application for a certificate of authority by:
- • writing to the Secretary of State, Corporations Division, 300 N. Salisbury Street, Raleigh, NC 27603-5909
- • faxing the Secretary of State at (919) 733-1837,
- • downloading from the Secretary of State’s website.
Nonresident Individual: Withholding is not required if individuals provide the University with their NC address and social security number.
Nonresident Entity: Withholding is not required if:
- • a limited liability company provides its certificate of authority number obtained from the Secretary of State,
- • a foreign limited partnership provides its NC address and Federal tax identification number,
- • a foreign corporation provides its certificate of authority number obtained from the Secretary of State.
Nonresident Individuals: Accounts Payable will issue a Federal form 1099-MISC by each January 31 to report the non-wage compensation amount and tax withholdings for the University funds. Tax reporting for funds of affiliated organizations will be the responsibility of the affiliated organization.
Nonresident Entity: Accounts Payable will issue a Federal form NC 1099-P.S. by each January 31 to report the non-wage compensation amount and tax withholdings for University funds. Tax reporting for funds of affiliated organizations will be the responsibility of the affiliated organization.
Nonresident Individual: Accounts Payable (AP) will revise its procedures and the AP system will be modified to accommodate the new State income tax withholding requirement for University funds.Withholding and remitting taxes for disbursements of funds of affiliated organizations will be the responsibility of the affiliated organizations.
Nonresident Entity: Accounts Payable (AP) will revise its procedures and the AP system will be modified to accommodate the new State income tax withholding requirement for University funds.Withholding and remitting taxes for disbursements of funds of affiliated organizations will be the responsibility of the affiliated organizations.
Explanation: A “duty day” is any day or part of a day in which an activity connected with the service is performed. The nonresident contractor’s compensation which is subject to withholding is determined by allocating the total compensation to the duty days spent in NC rendering services and to the duty days spent outside NC rendering services. For example, assume a nonresident corporation contracts for $10,000 to provide an architectural design for a University building being constructed. The corporation’s representative spends one day on campus to view the construction site and discuss potential designs, spends eight days outside NC drawing the designs, and one day on campus presenting the designs. The amount of withholding would be $80 which represents 4% of $2,000. The amount of $2,000 is subject to withholding since two days were spent working in NC at a fee rate of $1,000 per day. The vendor will need to indicate on the invoice the number of duty days in NC and outside of NC. The absence of such information will necessitate withholding on the entire amount.
Discretionary funds are non-state unrestricted funds arising from unrestricted gifts and investment income. These funds are available to the Chancellor for administrative and service functions not met from other funding sources. These funds are available to supplement other resources. This policy also applies to non-operating departmental accounts funded by unrestricted gifts. The following statements define the framework within which discretionary expenditures are to be made:
- • Expenditures from Discretionary Funds shall only be made for University purposes, and not for personal use or personal enrichment.
- • Discretionary funds are discretionary as to use, not process. University purchasing policies and procedures shall be followed in making expenditures from discretionary funds. Also, appropriate documentation shall be provided to support discretionary expenditures.
- • Discretionary expenditures may be made to support those representing the University at events in an official capacity, including the Chancellor’s spouse. This may include travel and other related expenses.
- • Discretionary expenditures may be made to support events for building or enhancing campus community and for building relationships and providing services on behalf of UNCG. This may include receptions, mealtime gatherings, dedications, and other events in which the University representation and/or sponsorship are consistent with its mission and expectations.
- • Discretionary expenditures may be made for educational and general University expenses that could be appropriately met from other fund sources, where funding from other sources is insufficient.
- • Discretionary expenditures may also be made for administrative expenses not appropriately met from other fund sources. This may include travel to meetings and conferences, business meals, and awards. Discretionary expenditures may also be made for expressions of congratulations and sympathy in an official capacity.
- • If there is a question as to whether an anticipated discretionary expenditure in in conformity with this policy, please contact Steve Honeycutt, Interim University Controller at firstname.lastname@example.org or at (336) 334-5795 for clarification.
The administration of The University of North Carolina at Greensboro recognizes that business entertainment can be essential to the operation of the University. The purpose of this policy is to place this activity in proper focus, to prevent abuses, and to ensure prudent control of these expenditures. This policy applies to all funds of the University, except those funds appropriated by the State of North Carolina which cannot be expended for these purposes under any circumstances.
- ♦ The purpose of the entertainment must be business and not personal.
- ♦ Entertainment expenditures must be documented to show the following:
- • Identification of the persons or group being entertained. If a small group is being entertained, the names of all persons attending must be shown; for large groups, only the name or names of the guests should be shown along with the number of persons attending.
- • A statement as to the reason for such entertainment, indicating how the entertainment benefited the University and clarifying the relationship of the persons in attendance to the particular aspects of the University’s programs or activities (titles, committee names, field of interest of person being entertained, reason for visitor being on campus, etc.)
- • The place of entertainment. Itemized receipts for entertainment expenses are required for reimbursement to the faculty or staff member. If payment is to be made to a vendor, the normal invoice or statement of costs is required.
- ♦ Payments are not to be made for entertainment expenditures unless the documentation is complete. A request for documentation is forwarded to the individual responsible for the fund when additional documentation is required. If appropriate action cannot be taken to properly document the expenditure, the individual staff or faculty member must bear the cost of the entertainment.
- ♦ No entertainment expenses can be charged to contracts or grants unless such entertainment is specifically authorized by the terms of the contract or grant.
Categories or Entertainment
- ♦ Prospective Faculty and Staff
The University recruits in a highly competitive market for top faculty and staff. It is the policy of the University to invite prospective faculty or staff, and on occasion both candidate and spouse, to visit the campus. Travel and all other reasonable and necessary expenses for such activities are reimbursed in accordance with the travel policies and procedures addressed in the Travel Section. However, prudence suggests that prospective faculty and staff (including spouses) involved in this type of entertainment are limited to:
- • in the case of faculty: key faculty, department heads, and dean or associate dean;
- • in the case of department heads: the dean, associate dean, key faculty of department, and administrative officials;
- • in the case of recruitment of deans: the members of the selection committee, faculty as appropriate, and deans and administrative officials; and
- • in the case of major administrative officials: the members of the selection committee, faculty and administrative staff as appropriate, and administrative officials.
- ♦ Official Guests of the University
The University is not normally expected to reimburse official guests for travel and related expenses, except where the guests travel to the University on specific invitation. However, it is recognized that entertainment of guests is essential. Examples of official guest would include the following: visiting lecturers; visitors from foreign countries; representatives of research organizations; visitors from other universities; individuals interested in university programs and problems (potential donors); guests invited to assist in the development of new programs (both paid and non-paid consultants); and business and community leaders. The relationship between the visitor and the university staff or faculty attending the function or their areas of responsibility must be clearly indicated, particularly for those who are at the campus on specific business on behalf of the University.
- ♦ Conferences, Workshops, Meetings, Seminars, etc.
In the case of conferences and workshops conducted by the University which are supported by income from registration fees, all entertainment expenses must be covered from the revenue produced by the event and separate records maintained. Further information concerning group activity is addressed in the Travel Section of the Policies and Procedures Manual.
- ♦ Reception
Receptions for students, faculty, alumni and friends of the University held by the Chancellor or those whom he holds responsible for such activities are reimbursed as entertainment.
The Chancellor or his/her designee may, from time to time, hold dinner meetings for administrative officers, deans, department heads, and faculty, including spouses, for the purpose of discussing items of general University intererest. Such meetings are reimbursed by the University as entertainment.
The Payroll Department is responsible for the preparation of all University payroll payments to faculty, staff, and student employees. The University payroll includes the following:
- ♦ EPA
- ♦ SPA
- ♦ Graduate Assistant
- ♦ Undergraduate Assistant
- ♦ Federal Work Study
- ♦ Temporary
- ♦ Summer Session (Included, as separate item, with normal monthly pay)
All employees are paid by University direct deposit or check (possible initial payment only) and are paid the last working day of each month. All employees are required to be paid by Direct Deposit. (Note: Hourly employees including temporary and departmental students are paid for hours worked for the period 11th of one month through the 10th of the following month.)
In order to comply with necessary and required deadline dates, payroll normally starts processing about the 13th of the month. Exceptions are normally in November, December, and January due to holiday schedules. To ensure timely and accurate payments, all payroll documents, (e.g. personnel actions, EPAFs, etc.) must be received in the Human Resource Offices prior to payroll preparation. The deadline dates for personnel actions can be found on the deadline webpage. Any personnel action forms or EPAFs which require processing through the UNCG Human Resources Offices should be submitted sufficiently in advance of the Payroll Department initiating the payroll process. Therefore, any additions, changes, or deletions to payroll can be processed in a timely manner.
In addition the following dates apply for tax forms and direct deposit forms:
- ♦ Employee’s Withholding Allowance Certificate (Both Form W-4 [Federal] and Form NC-4 [or appropriate state]) – by 5:00 PM on the 10th of the month or the first working day thereafter if the 10th falls on a non-working day.
- ♦ Authorization Agreement for Automatic Direct Deposit (BHR-Direct Deposit Form)- by 5:00 PM on the 10th of the month or the first working day thereafter if the 10th falls on a non-working day.
Direct deposit notifications are mailed to the department payroll representative as indicated on the personnel action form. Payroll checks are mailed to employee’s home address listed in the HRS system.
The designated payroll representative is responsible for performing the following duties:
- ♦ Missing Payroll Direct Deposit Notifications
When an expected payroll direct deposit notification appears to be missing from the direct deposits received by the department or school representative, the Payroll Department must be contacted. There are several reasons why a direct deposit may not have been issued or distributed, such as wrong check distribution code in employee payroll record, the delinquent submission of personnel action forms or payroll manifest.
- ♦ Unearned Payroll Checks/Direct Deposit Notifications
If an employee is not entitled to a payroll check or direct deposit notice, the employee’s department or school representative must return it immediately to the Payroll Department. An incorrect payroll check must never be held by the employee or the department. The Payroll Department must cancel the check or direct payroll deposit and credit the budget source and the employee’s earnings records.
- ♦ Delivery of Direct Deposit Notifications
It is the responsibility of the department or school representative to distribute direct deposit notifications within their department or school. If a payroll direct deposit notification cannot be distributed to the payee, the direct deposit notification, including an explanation, should be returned to the Payroll Department.
- ♦ Replacement of Stolen or Lost Checks
If a payroll check is stolen or lost, the employee to whom the check was drawn should contact the Payroll Department immediately.
The employee must first execute an affidavit (in the presence of a Notary Public) before any further action can be taken. Once the Payroll Department has secured the affidavit, a Stop Payment Notice on the the lost or stolen check is issued to the State Treasurer’s Office. If the payroll check is found before the stop payment action has been put into effect, the Payroll Department must be contacted so the Stop Payment Notice can be canceled.
After the Payroll Department is notified by the State Treasurer that the stop payment action has been put into effect, a replacement check can be issued. (May take up to 10 days.)
Before another check can be issued to replace a forged check, the employee must sign, in the presence of a Notary Public, an affidavit attesting to the fact that the endorsement on the check is not that of the affiant.
The employing department is responsible for preparing and submitting the required position and personnel forms/EPAFS and for performing time entry by the prescribed deadlines. Problems occur if the necessary actions are not received on time or they are in error; or if errors are made in coding and data entry. An error correction Payroll Exception Process within the Banner HR Payroll System will be run as described in this policy which will require multiple steps processing to pay the employee accurately, assess and remit taxes properly, resolve individual payroll problems, and correct the payroll records.
The intent of this policy is to establish an efficient business process without causing a significant hardship for the employee. Basically, if the amount of incorrect pay is related to the employee’s Primary base job and the gross amount requested is at least 15% of the Primary job salary, then a Payroll Exception Process check will be issued provided the employee is not willing to have the underpayment paid in the next scheduled regular Monthly Payroll Process. If an employee is supposed to receive a regular monthly paycheck for their primary job and does not, then a Payroll Exception Process check will be issued, in accordance with compliance of Procedure 12 – Exception Payroll Check Requests.
The current policy at UNCG, which requires a position to be established, classified/designated and sufficiently funded prior to employing an individual for the position, is fundamentally sound. The PD-6, the personnel action form that reflects the funding source for the position, is required to be prepared in advance and approved by the appropriate Provost/Vice Chancellor, the Office of Financial Planning and Budgets, and the appropriate personnel office (Office of the Provost or Office of Human Resources). The fund and account number(s)/funding source must be reflected on the employment personnel action forms (EAF, PD-6, PD-7, PD-101, HRS-04, etc.). Thus, the funding for every personnel position at UNCG must be approved before an employee is ever hired and paid.
Payroll reallocations caused by funding changes should be rare and, generally, should only occur due to actions by some external agency (e.g., the federal government, the North Carolina legislature, the UNC Board of Governors). However, there will be instances where changes are necessary due to personnel actions initiated by internal management. Regardless of the funding source, changes in funding for an employee/position require that the appropriate personnel actions be prepared and approved prior to the effective date of the change.
Once sufficient funding has been secured and approved for a position, and the employee has been properly paid from the approved funding source, any changes in funding may require the reallocation of prior months’ labor and benefit charges. The reallocation will be calculated by Payroll personnel based upon personnel action forms submitted by the employing department head/dean, and approved by the appropriate Provost/Vice Chancellor, the Office of Financial Planning and Budgets and the appropriate personnel office.
Disbursement of state and federal funds must be in accordance with applicable laws, rules and regulations. In order to avoid any audit findings related to the misuse of state or federal funding, all personnel action forms must be prepared by the employing department within thirty days of the effective date of the funding notification. In addition, these forms must be submitted to all relevant offices (e.g., the appropriate personnel office, the Office of Financial Planning and Budgets, Contract and Grant Accounting, and the Payroll Office) by established due dates in order for the change to be reflected in the employee’s next paycheck. If applicable, revised Time and Effort Reports should be submitted to Contract and Grant Accounting within thirty days of the funding notification.
- ♦ A University receipt book contains fifty prenumbered receipts.
- ♦ A University receipt book must be utilized by all academic and administrative departments responsible for collecting cash. A receipt must be written for all cash received.
- ♦ All receipt books must be available for audit by the University Internal Auditor and the N.C. Office of State Auditor. The purpose of the audit is to verify that monies collected have been:
- 1. properly receipted,
- 2. deposited with the Cashier’s Office in a timely manner, and
- 3. documented as to the purpose of the deposit. Refer to Procedure No. 8 concerning use of University receipt books.
All monies received by university offices, departments, or schools must be deposited daily with the Cashier’s Office. This policy is in accordance with the State of North Carolina G.S. 147-77 which states that monies for deposit to the State Treasurer must be deposited daily.
Monies from vending machines, parking meters, etc. are considered received when the monies are removed from the devices. These monies must be deposited within 24 hours after removal from such machines. Monies deposited in such devices must be collected at least on a weekly basis.
Departmental Deposit Slip
All deposits must be accompanied with a Departmental Deposit Slip. Refer to Procedure Number 3 for instructions on the preparation of this form.
Departmental Deposit Documentation
The departmental deposit must include documents which explain the source and nature of the funds being deposited. Examples of documents include correspondence, check stubs, University receipt copies, and other information which provides a clear and complete view of the purpose of the deposit. Copies of the supporting documentation should also be retained in departmental files.
Departmental Deposit Confirmation
Deposits should be delivered directly to a University Cashier. Each depositor receives a cashiers receipt prior to leaving the Cashier’s Office for deposits made with the University Cashiers. The cashiers receipts should be retained and compared with the transaction entry on the monthly departmental accounting reports to ensure proper credit was received for deposits. Deposits received by Cashiers after 4:00 PM will be processed the following day. During heavy traffic periods, deposits may be brought to the Cashiers and Student Accounts 24 Hours Deposit Drop Box located on the Cashiers and Student Accounts Office wall outside of the Mossman Building. If the deposit is being left to be processed at a later time, a self-addressed interdepartmental delivery envelope must be left.
Safeguarding of Assets
Cash, checks and charge cards should be properly secured by the department until the daily deposit is made with the University Cashier.
- ♦ Checks to be deposited should be properly endorsed by the department. The endorsement provides a means of identifying checks deposited by a department and helps identify checks returned by the bank for any reason.
- ♦ All checks to be deposited must be endorsed on the left, reversed side, within one-half inch of the end of each check.
- ♦ Six digit fund/index code and the six-digit account code must be on back of each check.
- ♦ If the back of each check is not endorsed completely, the depositing department will be called and asked to pick up the deposit for completion.
All checks returned to the Cashier’s Office by the bank are redeposited with no service charge. If the check is returned a second time, it is handled as follows:
- ♦ Currently Enrolled Students – Returned checks written by currently enrolled students are charged to the student’s account. A twenty-five dollar ($25.00) service charge and the face amount of the check are charged to the student’s account.
- ♦ Other – All other returned checks are charged to the same departmental account into which the funds were originally deposited. Further collection attempts are the responsibility of the department which accepted the check.
Collection Of Foreign Items
Departments receiving checks drawn on foreign banks must verify that the checks are in U.S. dollars and will clear through the U.S. banking system. In order for a check to clear through U.S. banks, appropriate Federal Reserve Bank transit routing numbers must be reflected on the check.
If a department accepts a check from a foreign country, or a check which does not reflect the appropriate transit routing information, the Cashiers and Student Accounts Office (CASAO) is required by Wachovia to process the check separately as a “collection” item. In this situation, the department will not receive immediate credit for the check and will be financially responsible for any collection fees assessed by either the depository bank or the originating bank. If the check is not payable in U.S. dollars, the department will also be financially responsible for any conversion fees. Generally, the foreign check must have the equivalent value of at least $100 (U.S. dollars) to qualify for collection. The normal time period to receive credit for a collection item is six to eight weeks.
Development Services Office
An important responsibility of the Development Services Office is to receipt and document all gifts received by the University. When a gift to The University of North Carolina at Greensboro is received, the Development Services Office prepares a receipt for the gift portion of monies received and remits a copy to the donor. The OFFICIAL RECEIPT acknowledges the amount of the gift and date received.
Gifts made either to the University or to the affiliated organizations of the University are spent according to restrictions placed upon the gifts by the donors. Gifts received that are designated as unrestricted in nature are disbursed in accordance with State and University Administrative Policies and Procedures.
Schools, Departments, and Other Organizations
Gifts Received For The University
In order for a department or organization to directly receive gifts to the University of North Carolina at Greensboro, official approval must be given by the Development Services Office and the Office of Finance and Administration. These approved departments and organizations are authorized to directly receive gifts and deposit these monies to existing university accounts. For those departments or organizations that have been approved to directly receive gifts, written authorization and procedures must be obtained from the Development Services Office and the Finance and Administration Office. All gifts must be recorded and receipted in the Development Services Office.
Upon receipt of a gift, the collecting school, department, or organization should neither prepare a receipt nor remit a receipt to the donor. As previously stated, the Development Services Office is responsible for issuing the OFFICIAL RECEIPT. However, in certain cases, the school, department, or organization may deem it appropriate or necessary to prepare a receipt (i.e., cash monies are received). Under these circumstances, the collecting department must write “DUPLICATE RECEIPT” across the face of the receipt in large letters.
Establishing New Funds
If the receipt of a gift necessitates the creation of a new University Gift Fund, the collecting school, department, or organization should submit a written request to the Development Services Office, stating the name of the fund and a brief description of the purpose of the fund. The Development Services Office is responsible for submitting all requests for new gift funds, using form FIN-04, “Request for Establishment of Fund.”
Plans and efforts to solicit gifts or funds should be approved in advance by the Development Office as stated previously. In cases which require a new account, the Development Office will submit a written request to the Development Services Office to establish the new fund.
Gifts Received For The University Affiliated Organizations
In all cases, monies designated by the donor for the University affiliated organizations (The UNCG Excellence Foundation, Inc., The University of North Carolina at Greensboro Human Environmental Sciences Foundation, Inc., The Weatherspoon Gallery Association, and the Weatherspoon Arts Foundation) must be directly deposited by the Development Services Office.
This policy provides the requirements for all payment (credit/debit) card processing activities at UNCG. It defines the responsibilities of employees, administrative units, organizations and affiliates that process payment cards on behalf of UNCG or its affiliates. All relevant provisions contained in the Information Security Policy, the Data Classification Policy and the Acceptable Use of Computing and Electronic Resources are applicable and included by reference in this document.
This policy applies to all academic units, organizations, affiliates, and employees of UNCG who accept credit/debit card payments for University business.
The Office of the State Controller has established a Master Services Agreement (MSA) with SunTrust Merchant Services. The MSA provides services to eligible state agencies, universities, community colleges, and local units of governments on a statewide enterprise basis, allowing eligible participants to benefit from the leveraging of volume pricing.
Finance and Administration has signed a Participation Agreement with the Office of State Controller (OSC) which allows campus departments to participate in the Master Services Agreement with SunTrust for the acceptance of credit cards. UNCG departments are not permitted to contract for credit card services outside of the Master Services Agreement without written approvals from the Vice Chancellor for Finance and Administration, the Vice Chancellor for Information Technology Services, and OSC. All accounts for card processing must be established by the Director of Cashiers and Student Accounts Office through OSC.
UNCG is required to be in compliance with Payment Cards Industry standards, which is referred to as PCI Compliance. All payment transactions must be captured on approved processing systems. UNCG is taking an approach to consolidate vendors and minimize complexity and effort in building interfaces in order to support existing operations and control exposure. Accordingly, there is a freeze on adding any new credit card processing systems or vendors. Any request for use of a processing system not already in place at UNCG must include an explanation why one of the existing vendors/systems will not work, why UNCG should expend additional resources for the extra work and bear the additional exposure the new system will require.
To establish credit card processing the following must occur:
- 1. The requesting entity (department, school, etc.) must forward a request to the appropriate Vice Chancellor or Provost for approval of the business need and acknowledgement of the responsibilities that are accepted by the department. If it is an unusual situation in which a new system/vendor is being requested, the request must include a thorough justification as indicated above. Additional information to be included in this request can be found in Finance Procedure 13 – Credit Card Acceptance & Processing Procedures.
- 2. The approved request is forwarded to the Vice Chancellor for Finance and Administration for review and approval. Justification for not using one of the existing credit card processing systems/vendors must be provided to include a complete explanation as to why none of the existing credit card processing systems/vendors in place at UNCG will work and why UNCG should accept the additional exposure and expend the additional resources for the extra work required for implementation and PCI Compliance.
- 3. If approved, by the Vice Chancellor for Finance and Administration, the request will be forwarded to the Vice Chancellor for Information Technology Services for review and approval on the technical compliance and security issues.
- 4. Once the approvals of both the Vice Chancellor for Finance and Administration and the Vice Chancellor for Information Technology Services are obtained, the request will be forwarded to the Director of the Cashiers and Student Accounts Office. The Cashiers Office will serve as a liaison with the Office of State Controller for requesting the issuance of a merchant number for credit card acceptance.
All Payment (Credit/Debit) Card Processing activities must comply with the state of North Carolina General Statutes (G.S.) and policies. That includes but is not limited to the North Carolina G.S. 147.77 (Daily Deposit Act), NC Office of the State Controller Policy 500.2 (Master Services Agreements for Electronic Payments), 500.11 (Compliance with PCI Data Security Standards) and 500.13 (NC Security and Privacy of Data).
Payment Card Industry (PCI) standards apply to all organizations that process, transmit or store credit cardholder information. The University and all departments that process payment card data have an obligation to adhere to the PCI Standards and must annually certify their continued compliance by submitting the PCI-DSS Self-Assessment Questionnaire (SAQ) appropriate to their credit card activities. In addition, departments must comply with all information security policies established by UNCG Information Technology Services (ITS).
All departments accepting credit cards must maintain compliance with Payment Card Industry (PCI) standards at all times, including the following:
- 1. Cardholder data may not be stored on any UNCG computer device or network.
- 2. Never send or request cardholder information via email. Credit card number should never be sent via end-user messaging technologies.
- 3. All media (including paper) containing cardholder data must be physically secured and protected against unauthorized access, and properly destroyed when it is no longer needed for business or legal reasons.
- 4. All devices that capture payment card data via direct physical interaction (example: Point-Of-Sale terminal) must be protected against tampering and substitution.
- 5. An accurate and up-to-date list of all such devices must be maintained that includes: the make and model of the device, the location of the device, and the device serial number and terminal ID.
- 6. Device surfaces are periodically inspected to detect tampering.
- 7.Departmental personnel are trained to be aware of procedures to detect and report tampering or replacement of devices.
- 8. Implement a formal security awareness program to make all personnel that interface with payment card activities or cardholder data aware of the importance of cardholder data security and their responsibilities for protection of cardholder data. Access to cardholder data must be restricted for users on a need-to-know basis.
- 9. For departments that utilize service providers, a list of service providers must be maintained. The user of services providers requires:
- • A written agreement must be maintained that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess or otherwise store, process, or transmit on behalf of UNCG, or to the extent that they could impact the security of UNCG’s cardholder data environment.
- • The service providers’ PCI DSS compliance should be monitored and verified at least annually. The service provider must be listed as compliant on Visa’s “Global Registry of Service Providers” or on the PCI Security Standards Council’s website.
- • Information must be maintained about which PCI DSS requirements are managed by each service provider, and which are managed by the UNCG department.
- ♦ Payment Card Industry Data Security Standard (PCI-DSS) →
- ♦ NC G.S. 147-77 (Daily Deposit Act) →
- ♦ NC OSC Policy 500.2 (Master Services Agreements for Electronic Payments) →
- ♦ NC OSC Policy 500.11 (Compliance with PCI Data Security Standards) →
- ♦ NC OSC Policy 500.13 (Security and Privacy of Data) →
- ♦ Annual PCI Compliance Security Procedures Review →
Any costs incurred by a department to become and remain compliant with the PCI Data Security Standards shall be borne by the department. In the event of a breach, all fines and expenses associated with the breach will be borne by the department accepting the credit card that was compromised.
In accordance with State Statute 147-86.23, interest and late payment penalty will be assessed to past due accounts. For the purpose of assessment of interest and late payment penalty, a student’s account will be considered past due when the student is no longer enrolled. A one-time charge of 10% of the past due balance will be assessed as a late payment penalty to the student’s account. In addition, interest will be assessed monthly based on the current North Carolina Department of Revenue Rate until the balance is paid.
A student account is established for each student at the time the student is admitted to the University. This account is used to record student charges and payments. Each student is responsible for the proper settlement of his/her student account.
Payment-Tuition And Fees
Tuition and fees for all University students are due and payable before or on registration day. Payments may be made by cash, money order, check, webcheck or credit card. The student’s ID number should be shown on all payments.
Student Credit Policy
Students that receive awards through the UNCG Financial Aid Office from one or more of the following programs must pay the amount of their bill less the amount awarded for the financial aid. Any liability resulting from a reduction of financial aid becomes the student’s responsibility payable upon notification of the adjustment of the award. Financial aid awards for purposes of the credit policy are as follows: Pell Grants, Stafford Student Loans, Federal Insured Student Loans, Institutional Loans, SEOG, Perkins Loans, College Workstudy, departmental employment, N.C. Veteran Scholarships, Vocational Rehabilitation, Disabled Veterans, Minority Presence Grants and Fellowships, Student Incentive Grants, University Scholarships, Fellowships, Assistantships and Grants.
Students wishing to utilize Veterans benefits under the credit policy must demonstrate financial need in compliance with normal financial aid standards. Credit requests under this provision must be submitted to the Financial Aid Office accompanied by a financial aid request form no later than ninety (90) days before the beginning of an academic term. Final approval is contingent upon the student’s demonstration of need and a good credit history with the University.
Recipients of scholarships awarded by organizations outside the University in which direct payment is made to UNCG and notification is on file with the Student Aid Office may qualify under the credit policy.
Non-University Financial Aid
Approved payment plans with Academic Management Services will allow you to defer the amount approved for tuition and fees. You must pay the amount of the bill less the approved amount.
Students with outstanding balances receive monthly statements. These balances must be paid prior to the end of the academic term. Students with outstanding balances at the end of an academic term are subject to holds which will result in prevention of: registration for a subsequent academic term, obtaining transcripts, or receiving a diploma. Once a hold has been placed on a student’s account, the account balance must be paid in full in order for the hold to be removed. When a student graduates or leaves UNCG, transcripts will not be granted under any circumstances until the account balance is $0.00. Students are subject to the collection policies of the University and the State of North Carolina if the outstanding balances remain unpaid.
Loan repayments for emergency loans are made at the Cashier’s Office. Perkins and Institutional loan repayments are made to the University’s billing agent, University Office of the Controller, LLC (UAS). Inquiries regarding loans-due dates, balances, and other information are to be made by calling UAS at 1-800-999-6227.
Faculty staff waivers must be turned into the Cashier’s office for credit by the last date to add or drop a class with the university registrar. Waiver requests submitted after this date will not be processed.
Part I: Policy for Students Who Completely Withdraw from UNCG
Official Notice of Intent to Completely Withdraw from The University of North Carolina at Greensboro
Students who find that they must withdraw from the University can do so by dropping all courses online via UNCGenie. Students who drop all courses within the term are considered to be withdrawn from the University and may require reactivation or readmission through either Undergraduate Admissions or The Graduate School to return to the University in subsequent terms.
The University charges tuition and fees at the beginning of the semester, to support the delivery of instruction, regardless of its mode (face-to-face, online, hybrid). The University retains the discretion to change the mode of such delivery, and in the event of any change due to the public health emergency caused by the COVID-19 pandemic, the tuition and fees charged at the beginning of the semester will remain in place and no refunds will be issued. In case of another major disaster, the University will follow UNC System Office refunding guidelines or, in the absence of such guidelines, UNC Greensboro Executive Staff decisions.
Students who wish to discuss the academic consequence of a change in enrollment status at the University may contact:
- ♦ Undergraduate Students: Students First, 101 Forney Student Success Commons
- ♦ Graduate Students: The Graduate School, 241 Mossman Building
There will be a $50.00 non-refundable processing fee charged to all students who completely withdraw from the University after the Late Registration and Schedule Adjustment period (refer to the University Academic Calendar). Tuition and fees will be adjusted per the University’s Total Withdrawal Refund Calendar. An example of this calendar may be viewed below:
|Example of Total Withdrawal Refund Calendar|
Return of Federal Title IV Funds
The federally mandated Return of Funds Policy governs the return of Title IV funds disbursed to students who complete the official withdrawal process as defined by the University and for those who unofficially withdraw from the university or are administratively withdrawn. The term refund should be understood to mean the repayment of money received by the University for tuition and fees or for a reduction of charges if tuition and fees have not yet been paid. Title IV funds include Federal Direct Unsubsidized and Federal Direct Subsidized Loans, Federal Graduate PLUS Loans, Federal PLUS Loans, Federal Pell Grants, and Federal Supplemental Educational Opportunity Grants (SEOG). Federal Work-Study is excluded from this procedure.
Unearned Title IV funds must be returned to the Title IV programs. Unearned aid is the amount of disbursed Title IV aid that exceeds the amount of earned Title IV aid. If a student completely withdraws from UNCG prior to completing 60% of the semester, the school is required to perform a Return to Title IV calculation to determine the amount of Title IV assistance earned by the student. If the amount disbursed to the student is greater than the amount the student earned, the school must return the unearned funds. A student who remains enrolled beyond the 60% point earns all Title IV aid for the term.
The percentage of the period that a student remains enrolled is determined by dividing the number of days the student attended by the number of days in the semester. Calendar days are used in the determination of percentages. Breaks of five (5) days or longer are excluded in the calculations. The percentage may be found by using the following formula: 100% – (number of days the student attended / number of days in the semester)
If the amount of the Title IV funds disbursed is greater than the amount of Title IV funds earned by a student, a return of Title IV funds is necessary. Both the University and the student are responsible for returning a percentage of the unearned aid.
The University will return federal funds to the appropriate federal program up to the total net amount disbursed from each source as required by law. The prescribed order of return is:
- ♦ Federal Direct Unsubsidized Loan
- ♦ Federal Direct Subsidized Loan
- ♦ Federal Graduate PLUS Loan
- ♦ Federal Direct PLUS Loan (Parent)
- ♦ Federal Pell Grant
- ♦ Federal SEOG
- ♦ Other Title IV Programs
Return of Non-Federal Funds
UNCG may return Non-Federal funds received and applied to a student’s account as requested by the source from which the funds were disbursed. Any outstanding financial obligation to UNCG will be deducted from the amount of Non-Federal funds to be returned. Funds will be returned to the student unless they are requested by the source from which the funds were disbursed. When a student completes the withdrawal process, the Cashiers and Student Accounts Office will initiate a refund and either mail it to the student’s current address or deposit it into their specified bank account. If a student still has an outstanding financial obligation as a result of this process, the University will bill the student for payment.
Military Call-Up Policy
Leaving Prior to the Completion of a Term
A student voluntarily or involuntarily called for active military duty in the Armed Services Reserve or the National Guard is eligible to elect one of the following options for leaving prior to the completion of a term:
A. Complete Withdrawal Option (without academic penalty)
- 1. Tuition and general fees are fully refundable.
- 2. Health fees are generally fully refundable, except for students who have used the University’s health services. These students would be billed at the service rate to a maximum charge equivalent to the health fee. Students who have enrolled in the Student Health Insurance program should contact the agent for information on a pro-rated refund of premium.
- 3. Room and board are refunded based on the number of weeks the room is occupied and the meals consumed.
- 4. The student is still responsible for all miscellaneous charges, such as library fines, parking charges, health service charges, etc.
In order to be eligible for a refund under these guidelines, the student must contact the Office of Military-Affiliated Services and provide the following:
- 1. A copy of his or her call-up papers; these serve as documentation for the refund of tuition and fees.
- 2. A mailing address to which the student would like the refund to be sent.
To ensure the privacy of student data, any students submitting orders should either e-mail copies with their social security numbers redacted directly to the Office of Military-Affiliated Services Director at email@example.com; they may also be hand-delivered to the Office of Military-Affiliated Services at 1540 Spring Garden Street, Suite 150.
The Office of Military-Affiliated Services will notify the appropriate offices of the student’s withdrawal, including Students First, The Graduate School, the Financial Aid Office, Housing and Residence Life, and the Cashiers and Student Accounts Office.
In order for a student living in University housing to receive a refund from Housing and Residence Life, room keys must be returned to the appropriate office.
If a student is receiving financial aid when called to active duty, financial aid must be repaid according to federal and state guidelines before a refund will be issued by the University.
B. Early Exam Option
A student who is required to report for military duty not earlier than four calendar weeks prior to the date a semester ends as stated in the official University catalog (or after completion of at least 75% of the enrollment period in a non-standard semester) may, when authorized by the instructor, take the final exam early and be given full credit for all courses that have an average grade of C or better. Students are not eligible for refunds for courses in which they receive credit.
C. Incomplete Grade Option
A student who is required to report for military duty prior to the completion of a term may take a grade of incomplete in a course and complete it upon release from active duty. Course completion may be accomplished by independent study or by retaking the course without payment of tuition and fees. Under federal financial aid policies, a course that is retaken in this manner may not be counted towards a student’s enrollment load. An eligible student who receives an incomplete for any course is not entitled to a refund of tuition or fees paid.
Returning to UNCG Within the Same Term
A student called for active duty and subsequently released within the time frame to re-enroll during the semester of withdrawal may pursue re-enrollment within the same term. The University will make every effort to accommodate the request. Individual contacts with faculty involved will determine appropriateness of returning to a course.
Returning to UNCG at the Start of a New Term
A student voluntarily or involuntarily called for active military duty in the Armed Services, Armed Services Reserve, or the National Guard who wants to return to the University may be required to submit an application for readmission to Undergraduate Admissions or The Graduate School.
The returning student is eligible to have the application fee waived if:
- 1. The student selects the option to pay by check during the application process.
- 2. The student notifies the UNCG VA Certifying Official of the intent to return and provides a copy of orders confirming dates of call to active duty.
The re-enrolled student is technically ineligible to participate in early registration for the term of re-enrollment; however, the University will arrange a priority window to assist the student in returning with appropriate classes that are applicable towards the field of study.
Students who completely withdraw from their summer courses will be handled with the same refund policy that applies to the regular academic year.
Part II: Policy for Students Who Drop Course Hours
Regular Term Courses
The refund policy applies to complete withdrawals from UNCG. If a student simply reduces their course load after the Late Registration and Schedule Adjustment period (refer to the University Academic Calendar), NO refund or reduction of charges whatsoever will be credited to the student’s account. However, if the drop in hours occurs before the end of the Late Registration and Schedule Adjustment period, the student is entitled to a full refund for the hours dropped. If this change results in the creation of a student account credit balance, a check will be generated and mailed to the student’s campus box or local mailing address or, if the student has chosen the option, direct deposited.
Part of Term Courses
For courses that begin after the semester starting date (refer to the University’s Parts of Term Calendar), a full refund will be issued for a course dropped by the third calendar day from the class start date (class start date being day one) if the class meets a minimum of 30 sessions. For classes meeting less than 30 sessions, the date for full refund will be calculated as completion of 10% of the sessions. For example, the drop date for full refund would be the second day of class for a class that only meets 20 sessions. If this change results in the creation of a student account credit balance, a check will be generated and mailed to the student’s campus box or local mailing address or, if the student has chosen the option, direct deposited. This applies to a drop in hours only and not a complete withdrawal.
Summer Session Courses
If students reduce the number of their credit hours during a summer session, they should then refer to the last day for tuition refund for a drop in credit hours chart listed in the Summer Session Calendar published on Summer Session’s website.
Part III: University Refund Appeals Committee
The University Refund Appeals Committee considers appeals from any student who wishes to submit an appeal in writing. Cases are referred to the committee when a student feels that the University’s refund policies do not address particular circumstances. The Refund Committee will not review appeals that are more than one year old. If the original appeal is denied, the student has the right to re-appeal as long as they can provide new documentation with the re-appeal. If the second appeal is denied and the student feels it deserves further consideration, the third appeal would be referred to the Vice Chancellor of Finance and Administration. Appeal forms may be obtained in the Cashiers and Student Accounts Office.
Questions? Contact the Cashiers and Student Accounts Office
151 Mossman Building, Campus * PO Box 26170, Greensboro, NC 27402-6170
336-334-5831 (phone) | 1-877-286-8250 (toll-free) | 336-334-4178 (fax) | firstname.lastname@example.org (e-mail)
The University of North Carolina at Greensboro operates in a decentralized manner in managing its financial resources to achieve a prudent, effective and efficient utilization. Financial resources are entrusted to leaders at a number of levels which include the Chancellor, Provost, Vice Chancellors, Vice Provost, Deans, Associate Provosts, Associate Vice Chancellors, Assistant Vice Chancellors, Directors, Department Heads, and Principal Investigators. The leadership of each division is responsible for the resource allocation within their division and the monitoring of the utilization thereof.
Individuals who are at the Department Head level or above (or who are Principal Investigators on Contracts or Grants) and who are entrusted with financial resources are responsible for the use of such resources in a prudent, effective and efficient manner to the benefit of UNCG and in compliance with federal, state and university rules and regulations. These individuals with authority over a fund or funds are the Fund Owners and are personally responsible for all transactions within those funds. The Fund Owner may grant Signature Authority to another individual(s) for administrative efficiency, but the Fund Owner is still held accountable for the funds.
Most of the financial and administrative processes are automated with transactions handled by a number of authorized individuals within an area depending on the organization, the nature of the systems and the transactions. In many cases, the explicit authorization of the Fund Owner is not a required step in the automated process for a specific transaction. When there is not an explicit authorization in place in advance of the processing of a transaction, subsequent oversight is required to verify the propriety of the transactions as an appropriate use of the specific fund.
Thus, it is required of each Fund Owner (Principal Investigator, Department Head or above) to review his or her monthly fund reports in detail on a timely basis. If errors or questionable items are discovered on these monthly reports, it is expected that the Fund Owner will take corrective actions within 10 days after receiving notification that the reports are available for viewing on e~Print.
The reports which are available for review are as follows:
- ♦ FYRWFDST
A fund statement which provides summary information related to budget, accounting and open commitment activity.
- ♦ FYRWFMTD
A report of month-to-date transactions which provides detail information related to budget, accounting and for the current month period.
- ♦ FYRWFYTD
A report of year-to-date transactions which provides cumulative detail information related to budget, accounting and commitment activity for the fiscal year through the most recently completed monthly period.
- ♦ FYRWFCOM
A report of open commitments which provides detail information related to open requisitions, purchase orders and encumbrances as of a specific date.
See Procedure 11 on how to access the correct e~Print repository to review the monthly fund reports.
- 1. Prudent utilization of debt to provide a low cost source of capital to fund capital projects and other strategic initiatives in order to achieve the University’s mission and strategic objectives.
- 2. Management of the University’s overall debt level in order to provide appropriate access to capital and to maintain a credit rating deemed acceptable by the Board. The minimum acceptable underlying rating for a University issue is the single “A” category by the major rating agencies.
- 3. Management of the University debt portfolio by balancing the goal of attaining the lowest cost of capital with the goal of minimizing interest rate risk.
- 4. Management of outstanding debt over time to achieve a low cost of capital and to take advantage of interest rate cycles and refunding opportunities.
- 5. Assure projects financed have a feasible plan of repayment.
B. Legal Authority for Financings
University financings will conform to the authority granted by North Carolina and Federal laws.
- 1. General Revenue Bonds
The Board of Governors of the University of North Carolina is authorized under Chapter 116 of the General Statutes of North Carolina as amended, to issue, subject to the approval of the Director of Budget, at one time or from time to time, special obligation bonds of the Board, for the purpose of paying all or any part of the cost of acquiring, constructing or providing one or more capital facilities at UNCG or refunding any bonds issued under any provision of any Article of Chapter 116 for the benefit of UNCG.
- 2. Energy Savings Performance Contracts
UNCG has the power, pursuant to Chapter 142, Article 8 of the General Statutes of North Carolina, to enter into installment financing contracts to finance the purchase of personal property, including equipment for energy savings projects. For energy savings projects, approval is required by the Office of State Budget and Management, the State Treasurer, the State Energy Office, and the Council of State.
- 3.Interest Rate Swaps
Interest rate swaps and other derivative products are authorized under Chapter 159 of the General Statutes of North Carolina. In general, interest rate swaps are utilized to reduce the cost and/or risk of existing or planned University debt. By using swaps in a prudent manner, the University can take advantage of market opportunities to reduce debt service cost and/or interest rate risk. The use of swaps must be tied directly to University debt instruments. Swaps may not be utilized for speculative purposes.
C. Assignment of Responsibilities
- 1. The University takes a comprehensive team approach relative to managing debt. The “Debt Management Team” consists of the Vice Chancellor for Finance and Administration (VC – Finance and Administration), the Associate Vice Chancellor for Finance (AVC – Finance), the Director of Financial Planning & Budgets (Budget Director), the University Controller (Controller), the Bond Legal Counsel (Bond Counsel), and the Financial Advisor.
- 2. The VC – Finance and Administration participates in the executive level capital planning for all University Facilities. For Self-liquidating Capital Projects, the VC – Finance and Administration coordinates through the Associate Vice Chancellor for Facilities, the development and periodic updating of the self-liquidating capital projects multi-year plan, which is the basis for defining the debt needs.
- 3. The AVC – Finance works closely with the VC – Finance and Administration and the Budget Director in the selection of the primary advisors on debt. These primary advisors are the Bond Counsel and the Financial Advisor, who are engaged for a period of years, upon approval by the Vice President for Finance of the University of North Carolina. It is the AVC – Finance’s role to work with the Financial Advisor and assess debt capacity based on the current outstanding debt and any planned issues, including the multi-year Self-Liquidating Capital Projects plan. If it is determined that the University will reach its debt capacity from issuing debt on the proposed projects, then priorities and timing will be addressed with the VC – Finance and Administration and the project owners to best meet the overall needs of the University. During the year, the Associate Vice Chancellor for Finance meets periodically with the Financial Advisor and/or Bond Counsel other members of the Management Team to discuss debt needs, opportunities and options, including any upcoming debt issues and/or refundings. If action is warranted, the entire team is pulled together to decide upon the merits and, if justified, to define a plan to accomplish the debt issuance, refunding, swap, liquidation or other initiative.
- 4. It is the Budget Director’s primary role to assemble the project description and required financial and statistical information, review the official statements and to do the reporting required by the SEC (NRMSIR).
- 5. It is the role of the Financial Advisor and Bond Counsel to recommend the approach and financing instrument to best meet the needs of the University and to coordinate the RFP and selection of financial institutions and/or underwriters. The Bond Counsel secures the most favorable terms and covenants, and coordinates the preparation of legal documents with input and review by the Debt Management Team. The Financial Advisor coordinates the preparation of the details of the financing and insurance or other credit enhancements. The Financial Advisor also coordinates review and rating by the appropriate rating agencies.
- 6. It is the Controller’s primary role to coordinate receipt and distribution of proceeds, payments to fiscal agents, allocations of debt service payments to project owners, arbitrage calculations and reporting, and financial reporting.
D. Debt Management Strategies
- 1. Fixed versus variable rate allocation
The University will assess prevailing market interest rates and the current debt mix to determine whether to issue fixed or variable rate debt. Variable rate debt can provide a lower cost of capital, but introduces additional risks. To limit this risk, variable rate debt will be no more than 40% of the overall debt outstanding. Variable rate exposure may be achieved directly through debt issuance or indirectly by entering into an interest rate swap contract.
- 2. Methods of Sale
The University will consider various methods of sale. Negotiated and competitive sales will be considered on an individual transaction basis. Issue size and complexity will be factors in determining which method of sale to pursue. A retail sales approach may be implemented if deemed appropriate for the particular transaction.
- 3. Purchase of Insurance or Credit Enhancement
The University will evaluate insurance and credit enhancement opportunities and utilize them if they are deemed cost effective.
- 4. Refunding Targets
The University will monitor its debt portfolio for refunding and/or restructuring opportunities. Advance refunding transactions must weigh the current opportunity against possible future refunding opportunities. In general, for a stand-alone refunding, the University will enter into a transaction that produces greater than 3% net present value savings, with this threshold higher for those transactions with a long escrow, such as advance refundings. The savings threshold can be less for refundings combined with new issues or other refundings, or for business reasons such as freeing up a reserve fund.
- 5. Selection of Underwriters and Participants on the Selling Team
The University will utilize a request for proposal process to select senior and co-managing underwriters for University debt issuance. The University will reserve the right to utilize a competitive process for any debt issue.
- 6. Efficiency of Issuance
The University will combine capital projects within a reasonable time horizon into a single issuance to save costs, to the extent that it is feasible. For small issues even after combining, the University of North Carolina bond pool will be utilized if the timing meets UNCG’s needs and it is cost effective and efficient for UNCG. For larger issues, the bond pool will be utilized if significant cost savings can be realized as well as being efficient and timely for UNCG. Stand alone issues will be utilized when in the best interest of UNCG upon approval of the Vice President for Finance.
- 7. Integrity of Revenue Streams
The revenue system (housing & dining, or parking, or student fees, etc.) for each self-liquidating capital project must stand on its own bottom line, supported by a revenue stream that can fully liquidate the debt over the amortization period in a fiscally sound manner. Debt service costs will be allocated to the capital project owners in proportion to the projects participation in the borrowing.
- 8. Debt Service Leveling and Reserve for Variable Rate Debt Fluctuations
The University will allocate debt service costs on capital projects funded with variable rate debt to the capital project owners on a fixed rate basis, effective at the time of issue, over the course of the amortization period. The differences between the allocation and the actual debt service will be placed in a reserve and returned to the project owners at the end of the amortization period. This is effectively an internal hedge to protect business operations from wide fluctuation in variable rates over the life of the debt with a leveling factor. Interest income will be allocated to the reserve.
E. Debt Compliance and Reporting
- 1. Continuing Disclosure Compliance
The University will meet the ongoing disclosure requirements in accordance with SEC Rule 15c2-12 (NRMSIR). The University will submit all reporting required with respect to outstanding bonds or certificates of participation to which such Rule is applicable.
- 2.Arbitrage Rebate Compliance
The University will comply with arbitrage requirements on invested tax-exempt bond proceeds. Arbitrage calculations will be performed as needed.
Tax-Exempt Debt and Build American Bond
Post-Issuance Compliance Policies and Procedures
- ♦ Part I. Purpose
- ♦ Part II. Responsibility of University Officials
- ♦ Part III. Closing of Debt Issuances
- ♦ Part IV. Use of Debt Proceeds
- ♦ Part V. Special Provisions Applicable to Build America Bonds
- ♦ Part VI. Arbitrage Limitations Imposed on Debt Issuances
- ♦ Part VII. Accounting for Debt Proceeds
- ♦ Part VIII. Recordkeeping
- ♦ Part IX. Voluntary Closing Agreement Program
- ♦ Part X. Continuing Education
- ♦ Exhibit A. Revenue Procedure 97-13 – Management Contract Safeharbors →
- ♦ Exhibit B. Internal Revenue Service Recordkeeping Frequently Asked Questions (FAQs) →
- ♦ Exhibit C. Internal Revenue Service Tax Compliance Guide →
- ♦ Exhibit D. Internal Revenue Service Notice 2008-31 – Voluntary Closing Agreement Program →