Effective Date: April 24, 2025
Purpose
The purpose of this policy is to establish clear guidelines for expenditure authorization within the Canadian Bar Association, ensuring efficient financial management, alignment with organizational materiality thresholds, prevention of contract splitting, and appropriate oversight of financial transactions.
Policy statement
This policy aims to:
- Ensure transparency and accountability in financial decision-making.
- Prevent contract splitting or transaction aggregation to bypass approval thresholds.
- Maintain effective oversight for expenditures with significant financial impact.
The Financial Signing Authority Policy applies to the authorization of contracts and the approval of payments, including (but not limited to) cheques, electronic fund transfers (EFTs), wire transfers and credit card payments.
Authorized signatories
The following are the authorized signatories for the CBA:
Board:
- President
- Vice-President
- Chair of the Finance Committee
Staff:
- Chief Executive Officer
- Chief Financial Officer
- Executive Director, Advocacy
- Additional Directors as determined by the Chief Executive Officer
All payments require two signatures or approvals.
Approval limits
Approval thresholds for budgeted and unbudgeted expenditures are as follows:
Budgeted Expenditures
| Expenditure Amount | Authorization Required |
|---|---|
| Up to $10,000 | Director authorization |
| $10,001 to $35,000 | Deputy CEO and CFO |
| $35,001 to $250,000 | CEO authorization |
| Over $250,000 | President, Vice-President, or Finance Chair |
Unbudgeted Expenditures
| Expenditure Amount | Authorization Required |
|---|---|
| Up to $17,500 | Deputy CEO and CFO |
| $17,501 to $50,000 | CEO |
| Over $50,000 | President, Vice-President, or Finance Chair |
Contract splitting and transaction aggregation
To maintain the integrity of financial oversight:
- Prohibition of Contract Splitting: Related transactions or payments must not be divided to avoid exceeding approval thresholds.
- Transaction Aggregation: All related expenditures will be aggregated to determine the appropriate authorization level.
Digital authorization
- Digital Signatures: All electronic approvals should, where available technology exists, utilize secure digital signature technology to enhance accountability and streamline processes.
- Email Approvals: Email approvals are permissible in the absence available digital signature technology; staff must take reasonable steps to ensure emails are authentic and to preserve an audit trail.
Procedures
- Request Submission: All expenditure requests must be submitted with appropriate documentation, including justification and budget alignment.
- Approval Process:
- The approving authority must verify compliance with this policy and confirm the availability of funds.
- Approvals must be documented and retained for audit purposes.
- Monitoring: The Finance Department will monitor compliance with approval thresholds and report deviations to the Finance Committee.
Responsibilities
- Directors and Senior Management: Ensure adherence to approval limits within their teams.
- Finance Department:
- Oversee implementation and compliance with this policy.
- Conduct regular audits to identify and address non-compliance.
- Board of Directors: Provide oversight for high-value financial decisions and ensure alignment with organizational goals.
Review and amendments
This policy will be reviewed annually by the Finance Committee to ensure alignment with organizational needs and regulatory requirements. Amendments will be approved by the Board.
Conclusion
This Expenditure Authorization Policy establishes a robust framework for financial decision-making, ensuring that expenditures are authorized appropriately, align with the organization’s materiality threshold, and receive adequate oversight. Compliance with this policy is mandatory for all staff and Board members.