Franklin Pierce University

“In September 2023, the University became aware of fraudulent wire transfer activity occurring on one of its financial accounts committed by anonymous third parties who fraudulently posed as representatives of the University's financial institution. The total amount involved in the fraudulent activity was approximately $957,000. The fraudulent activity was subsequently investigated by applicable Federal and State law enforcement authorities. As a result of this activity, the University took several corrective measures. New user IDs were created for all active University employees with appropriate access to online banking. A two-step authentication process via user's mobile device was created for online banking access. A three-step (three employee) approval process was created for all outgoing ACH/wires. An outgoing ACH/wire exposure risk limit was created. Email/alert notifications for outgoing ACH/wires and positive pay discrepancy are distributed to employees in the University's Finance & Accounting Department. The Bank has also set three specific liaisons with the University; i.e. the University will only be contacted by those specific bank employees. Lastly, with any large ACH/wires and/or discrepancies, the University will be contacted by one of the liaison employees to verify the transaction for accuracy.”

“The minutes are maintained for all full board meetings but are not maintained for the executive sessions.”

“The 990 is reviewed by the CFO, President and the Audit Committee. A draft of the 990 is provided to the entire board of directors prior to filing and they are informed of the planned file date so that any concerns can be communicated prior to filing. The finalized and filed 990 is provided to the entire board after filing.”

“A list of vendors who are paid over $5,000 annually are provided to all Trustees, Officers and key managers and directors. They are required to check the list and sign a document indicating any conflicts of interest. The organization's policy is reviewed annually by the Audit committee. Potential conflicts noted are reviewed annually to determine if action is necessary.”

“The Executive Committee, acting without individuals who have a conflict of interest, will annually review total compensation data compiled by independent organizations such as CUPA, The Chronicle of Higher Education or an independent compensation consulting firm. Franklin Pierce considers comparative data for similarly qualified individuals in functionally comparable positions at similarly situated institutions. It's within the Committee's purview to engage with Human Resources to compile the most relevant data.”

“Franklin Pierce University makes its governing documents, conflict of interest policy and financial statements available to the public upon request.”

“Section 1.263(a)-3(n) Election: Franklin Pierce University 40 University Drive Rindge, NH 03461 EIN 02-0263136 Franklin Pierce University is electing to capitalize repair and maintenance costs under Regulation Section 1.263(a)-3(n).”