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NATCA National Executive Board Guidelines On Locals’ Utilization of Mobile Platforms

The NEB recently adopted guidelines governing the use by locals of mobile payment apps (such as Venmo or Cash App) as the means to reimburse members for appropriate union-related expenses, rather than traditional reimbursement by means of a paper check. Adoption of these guidelines was in response to the recognition that many members now primarily or solely utilize mobile payment apps for their banking. The guidelines will be incorporated in NATCA’s Expense Reimbursement Policy.  Before utilizing mobile payment apps for reimbursement, locals must: (1) notify their regional Finance Committee member and (2) participate in a remote training via telephone conference call with the National Office.  The policy is the following:

WHEREAS, NATCA locals have expressed interest in using mobile platforms such as Venmo, Square, PayPal, Zelle, and the Cash App, among others (collectively, “mobile payment apps”), in order to reimburse costs properly incurred on behalf of the local, and NATCA members have noted a preference for receiving reimbursements through mobile payment apps; and

WHEREAS, federal laws and regulations govern the use and record-keeping of a union’s finances, and prescribe criminal and civil penalties for statutory violations, and locals are required to comply with said laws as well as NATCA governing documents and internal policies; and

WHEREAS without strict oversight by locals, the use of mobile payment apps could lead to violation of said laws and policies;

THEREFORE, be it resolved, as follows:

(1) Locals are prohibited from using mobile payment apps for any purpose other than member reimbursement, which is outlined below.

(2) Locals may not receive payments on mobile payment apps.

(3) Locals must have more than one member in order to use mobile payment apps.

(4) Account information for all mobile payment apps shall be shared between all officers whose names are on the local’s bank account. The log-in information to all mobile payment apps must be turned over along with other passwords at the time of officer transition. New officers must then reset the account password and share the new password only with the relevant new officers.

(a) All email addresses associated with the account must be NATCA email accounts, whether set up for the local (e.g.: LocalABC@natca.net), an individual office (e.g.: ABCFacRep@natca.net), or an individual officer (e.g.:jdoe@natca.net). It is preferred that locals use an account set up for the local to which multiple officers have access. Under no circumstances may the email associated with the account be the personal non-NATCA email address of a local officer or member.

(b) The name of the account must be in the following format: “NATCA Local [Facility ID].” Under no circumstances may the account name be the name of an individual local officer or member. Similarly, should the mobile payment app require a profile image, the image must be of the NATCA logo or the local’s identifier, not an individual associated with the local.

(c) Should the mobile payment app have a privacy setting, the local shall have the account set to private.

(5) Any NATCA local wishing to use mobile payment apps to reimburse members for costs appropriately incurred on behalf of the local must comply with all existing record keeping requirements, including but not limited to federal statutes and regulations, the NATCA Constitution and Standing Rules, NATCA Finance Committee guidelines, and the Local Financial Policy.

(6) Locals are prohibited from making reimbursement payments without a receipt and shall not make payments in advance of spending.

(7) Locals must document mobile payment app reimbursements as follows:

(a) All requests for reimbursement must be submitted by the member on a voucher form, along with the itemized receipts for the charges.

(b) On the voucher form, the member must include the member’s username on the mobile payment app selected by the local as the app through which reimbursements shall be made. The local cannot reimburse the member via mobile payment app without both pieces of information provided on the voucher.

(c) Prior to making a payment, two appropriate officers must sign off on the voucher, just as with check reimbursement requests.

(d) The memo section of the mobile payment app payment form must include the reason for reimbursement and the voucher number.

(e) Once the reimbursement has been sent, an appropriate local officer must:

(i) print the e-mailed acknowledgement of payment sent by the mobile payment app,

(ii) note on the document the name of the person who submitted the payment in the app (the “payer”), and

(iii) obtain the signatures of all those who approved the payment. Each record must have a minimum of two (2) signatures. [See attachment.]

(f) Mobile payment records shall be maintained in accordance with NATCA’s Document Retention Policy.

(g) Individuals who have access to the local’s mobile payment app account shall not make payments to their personal accounts. A reimbursement to an individual with account access must be made by a different party and documented in accordance with the requirements outlined above.

(8) The local’s treasurer should continue regular review of all bank statements to ensure charges posted from mobile payment apps are accurate and consistent with reimbursements approved by the local.

(9) NATCA locals who wish to reimburse members using mobile payment apps must notify their regional Finance Committee member prior to the first use of such apps. After a local notifies their Finance Committee member, the local must participate in one teleconference training conducted monthly by the National Office before the local can begin using mobile payment apps. One (1) year after this notification, the Finance Committee shall review the finances and mobile payment app uses of the local to ensure that the mobile payments made have been properly approved and documented.