1. Fiduciary Responsibility: It Affects Us All
Sam ketcher
Business manager
College of the ozarks

2. Fiduciary Responsibility: It Affects Us All
Managing FSA program funds is a school-wide responsibility.
FSA program funds are provided to the school, and all offices at a school must work together to ensure successful program management.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

3. Fiduciary Responsibility: It Affects Us All
A school’s FSA program management generally takes place in three functional areas:
the Office of the Chief Executive (CEO, President, or Chancellor, etc.),
the Chief Financial Aid Officer, and
the Chief Business Officer.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

4. Fiduciary Responsibility: It Affects Us All
THE CEO’S OFFICE
Ultimate responsibility for a school’s FSA programs resides with the school’s CEO.
Although authority and responsibility are delegated to other offices, the leadership and support of the CEO are crucial to successfully administering FSA programs.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

5. Fiduciary Responsibility: It Affects Us All
THE FINANCIAL AID OFFICE
The Financial Aid Office is usually assigned most of the responsibility for administering FSA programs; however, the role of the FA Office in the institution’s fiscal operations is limited.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

6. Fiduciary Responsibility: It Affects Us All
THE BUSINESS OFFICE
Administering the accounting, recordkeeping, and reporting functions related to the school’s use of federal and other funds.
Strong internal controls and sound business and financial management practices are keys to the success of these operations and delivering funds to students.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

7. Fiduciary Responsibility: It Affects Us All
FIDUCIARY RESPONSIBILITY – WHAT IS IT?
34 CFR (a): the institution “acts in the nature of a fiduciary in the administration of the Title IV, HEA programs…the institution…must at all times act with the competency and integrity necessary to qualify as a fiduciary.”
Are we competent? Probably not in the eyes of some students/parents! But conferences and training are good ways to increase our competency.
Are we acting with integrity? Can be challenging. The truth does not have versions.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

8. Fiduciary Responsibility: It Affects Us All
Fiduciary: a person to whom property or power is entrusted for the benefit of others.
One, often in a position of authority, who obligates himself or herself to act on behalf of another (as in managing money or property) and assumes a duty to act in good faith and with care, candor, and loyalty in fulfilling the obligation.
With great power comes great responsibility.
HEAVY STUFF! We all have a level of both authority and power over the students we serve, and some of us have more authority and power than others. Power/responsibility….Spider Man, but goes much further back than that.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

9. Fiduciary Responsibility: It Affects Us All
A fiduciary's responsibilities or duties are both ethical and legal.
The highest legal duty of one party to another, it also involves being bound ethically to act in the other's best interests.
The fiduciary is expected to manage the assets for the benefit of the other person rather than for his or her own profit.
The fiduciary duty is greater than my personal duty to my own funds. In other words, has a fiduciary, I must be more diligent with someone else’s money than I am with my own.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

10. Fiduciary Responsibility: It Affects Us All
BU BASIC REQUIREMENTS
Safeguard and segregate FSA funds. Absent a separate bank account, the school must ensure that its accounting records clearly reflect that it segregates FSA funds. (“Federal Funds” must be in the name of the account.)
Ensure FSA funds are used for intended purposes.
Ensure that the functions of authorizing and disbursing FSA funds remain separate (separation of duties).
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

11. Fiduciary Responsibility: It Affects Us All
BU BASIC REQUIREMENTS
Maintain records of the eligibility of each Title IV aid recipient and the amount and date of each posting or return of aid
Return funds on student’s behalf to loan programs
Return to ED funds that cannot be used as intended
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

12. Fiduciary Responsibility: It Affects Us All
BU BASIC REQUIREMENTS
Monthly reconciliation REQUIRED for Direct Loans, TEACH, FWS, and SEOG.
Request funds via G5.
Assist in completing FISAP.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

13. Fiduciary Responsibility: It Affects Us All
FA BASIC REQUIREMENTS
Advise and counsel students and parents
Develop written policies and procedures
Provide consumer information
Determine students’ eligibility
Make financial aid awards
Adhere to the principle of separation of functions
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

14. Fiduciary Responsibility: It Affects Us All
FA BASIC REQUIREMENTS
SAP
Keep current on changes in laws and regulations.
Calculate the return of Title IV funds.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

15. Fiduciary Responsibility: It Affects Us All
FA BASIC REQUIREMENTS
Reconcile to ensure:
all payments have been made,
return of FSA funds have been accounted for, and
expenditures have been reported.
Coordinate submission of FISAP.
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

16. Fiduciary Responsibility: It Affects Us All
POTENTIAL PITFALLS/DIFFICULTIES
Failure in internal control/basic requirements (Danger of Fraud)
Separation of duties
Reconciliation
Failure to maintain adequate records/accounting system
Not knowing the requirements (No excuse)
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

17. Fiduciary Responsibility: It Affects Us All
POTENTIAL PITFALLS/DIFFICULTIES
Lack of communication/support between offices.
Size of institution
“Silo” effect
Personalities
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

18. Fiduciary Responsibility: It Affects Us All
POTENTIAL PITFALLS/DIFFICULTIES
No action on prior findings
Abusing power/authority
Institutional budget challenges (All of us!)
Fear (Personalities again!)
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

19. Fiduciary Responsibility: It Affects Us All
TOOLS
Regular training
FSA Assessment Tool
NASFAA Self-Evaluation Guide
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

20. Fiduciary Responsibility: It Affects Us All
TOOLS
Peer Evaluation
Review FSA Top Ten Audit/Program Review Findings
Act with the competency and integrity necessary to qualify as a fiduciary
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

21. Fiduciary Responsibility: It Affects Us All
REFERENCES / HELP
FSA Handbook Vol IV
G5 Help Desk – 6 Eastern Time
Who is Responsible Fin Aid or BU.pdf (easily found online)
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

22. Fiduciary Responsibility: It Affects Us All
THE REGULATIONS
34 CFR 668, Subpart K -Financial management systems
34 CFR (c)(1) -Checks and balances
34 CFR (a) -Checks and balances
34 CFR (a) -Checks and balances
34 CFR (a) -Checks and balances
34 CFR (c)(2)-Separating of functions
November 7, 2017
MASFAP Conference I Celebrating our past, inspiring our future.

23. Fiduciary Responsibility: It Affects Us All
Sam ketcher
Business manager
College of the ozarks