Consideration of the Revised and Restated CRA Financial Policies and Procedures Manual and the Revised and Restated CRA Cash and Investment Policy

Both policies were previously presented to the CRA Board on June 9, 2026. Since that meeting the Manual has been reviewed by CRA legal counsel, and the Agency’s online banking practices have been reviewed by CRA outside counsel against the requirements of the Agency’s depository agreements. Both documents have been further revised in response to those reviews and to direction from the Executive Director, and are returned to the Board for approval. All revisions are reflected in the accompanying change log.

The revisions since June 9 fall into seven categories:

• Position title and delegation of authority. The Finance Assistant position is now identified throughout as "Finance Assistant/Designee by Finance Director or Exec. Director," reflecting that the Agency operates a single-position finance function and that a designee may act with the written authorization of either officer. This change appears in 45 locations, including the Separation of Duties Matrix.
• Wire transfer authority. Wire transfer initiation and approval have been realigned so that the Separation of Duties Matrix, the Wire Transfer Policy in Section VI-A, and the debt service wire procedures in Section VI-E all state the same rule. Wire transfers are initiated by the Finance Assistant or designee and approved by the Finance Director or Executive Director. No individual may both initiate and approve the same transaction.
• Check signature threshold. The threshold above which a check requires a CRA Board Member signature has been raised from $901, unchanged since its adoption in 2006, to $75,000. The new threshold aligns with the point at which the CRA Procurement Policy requires Board approval to commit funds, so that expenditures reaching that level have already received Board authorization and been routed through the purchase order process. The requirement of two signatures on every check, and the requirement that one signatory be a Board Member at or above the threshold, are unchanged.
• ACH and electronic funds transfer. The prior Manual contained no policy governing ACH or electronic funds transfer activity, although ACH is a primary means by which the Agency both pays and collects. A new subsection establishes authorization requirements, payee and customer authorization, documentation, and fraud prevention controls, and expressly authorizes the Finance Director to approve ACH payees, ACH customers and individual ACH transactions.
• Online banking security. A new subsection addresses online banking access and security, responding to provisions in the Agency’s depository agreements that condition access to institution online banking platforms on the Agency maintaining a written security policy. It covers authorized users and entitlements, credentials and multifactor authentication, access revocation on separation, account monitoring through real-time institution alerts reviewed daily, and device security by reference to the CRA Acceptable Use of Information Technology Policy.
• Integration with the Cash and Investment Policy. The Manual previously listed a Cash and Investment Policy in its table of contents but contained no corresponding section. A new Section V incorporates the separately adopted Cash and Investment Policy by reference, attaches it as Appendix M, and states the delegation of investment authority, the approvals retained by the Board, the reporting requirements, and the order of control in the event of conflict. Related provisions were added addressing continuing education under F.S. 218.415(14), the independent auditor’s compliance report under F.S. 218.415(22), and the allocation of investment income among funds. The Cash and Investment Policy was revised in parallel so that its quarterly and annual reporting deadlines match the Manual’s closing and audit cycles.
• Section VII has been retitled "Closing Procedures," the year placeholders on the title page have been completed, an ambiguous appendix citation in Section 8.2 has been clarified, and both documents now carry a title-page document control block identifying the baseline and revised versions.

No fiscal impact from adoption of the policies themselves.

1. Approve the Revised and Restated Financial Policies and Procedures Manual and the Revised and Restated Cash and Investment Policy as presented.

2. Approve the policies with modifications directed by the Board.

3. Do not approve the policies as presented.

4. Other options as determined by the Board.