Signature Authority and Delegation Policy

The College has an obligation to be a responsible steward of the resources entrusted to it. The purpose of this policy is to safeguard College resources and to minimize the College’s financial, legal, operational, and compliance risks by establishing the authority and responsibility of College employees with regard to activities that legally bind the College or obligate the College to commit financial or other institutional resources to any third party. Signature authority provided under this policy may be contingent upon completion of training designated by the Chief Financial Officer and General Counsel.

For purposes of this Policy, “contract” means an agreement between the College and one or more third parties that is binding and enforceable, such as an agreement under which the College purchases, leases, or acquires goods, services, or personal property or obligates College time and/or resources, including, but not limited to, funding, personnel, office, laboratory and classroom facilities and equipment. For purposes of this Policy, “contract” does not include employment agreements, MOUs, or other agreements that are explicitly not legally binding.

1. Contracts must be in writing and must be signed by a person authorized to bind the College pursuant to this policy.

2. Officers of the College (the president, vice presidents and deans) are authorized to sign contracts on behalf of the College that have a total expected value less than $50,000 and a term of three years or less. Only the President, Chief Financial Officer (CFO), or General Counsel/Chief of Staff (or their successors or designees) are authorized to sign contracts with a value equal to or exceeding $50,000 or with a term greater than three years.

3. Deans and vice presidents may further delegate authority for signing contracts to other employees in their department, up to an expected value of $25,000, and for a term of one year or less. Any such subdelegation is to be in writing, and is to describe any limitations on the types of contracts that such persons are authorized to sign.

4. Deans and vice presidents must provide the CFO and General Counsel (GC) with a list of all persons delegated authority to sign contracts in their department (including any limitations on such authority), and promptly provide notice of any changes to the list.

5. Persons with authority to sign contracts are required to complete a training program designated by the CFO and GC prior to signing contracts..

6. Notwithstanding other provisions of this Policy, the Assistant Vice President for Sponsored Projects and Research Compliance, CFO, or Associate Vice President for Business and Finance (or their successors or designees) are authorized to sign, approve, or submit federal and other governmental grants, agreements, proposals, and applications.

7. Legal review is required for any contract with an expected value in excess of $100,000 (other than sponsored project agreements).

8. The following contracts require review by the CFO and GC regardless of dollar value or length of term:
   • Contracts with parties outside of the US or with a Native American tribe
   • Construction contracts
   • Information Technology contracts, including contracts for the development or acquisition of software meeting the following conditions:
     • Technology that needs to integrate with our campus infrastructure, network, or shared services
     • Technology that stores or utilizes institutional data, or data that falls under applicable governmental regulations (i.e., FERPA)
     • Services that require Single Sign On or authentication using college data
     • Anything that would require IT support to deploy, maintain or service over time
   • Contracts involving any interest in real property
   • Contracts with banks or other financial institutions
   • Contracts involving the collection of funds, credit card transactions, or other similar financial transactions
   • Contracts that convey any right or interest in College intellectual property
   • Nondisclosure agreements
   • Contracts involving sensitive or confidential information (i.e., medical information, student records, etc.), such as Business Associate Agreements
   • Any agreement conferring a naming right
   • Any agreement creating an obligation for the College greater than three years (other than sponsored project agreements or related agreements (material transfer agreements, subawards, etc.))

9. Only the President, GC or CFO may sign an agreement settling a disputed legal claim.

Questions regarding this policy should be directed to the CFO or GC.