Kimberly A. Reed
The general criteria for determining “handling” include:
- Physical contact with cash, checks or similar property;
- Power to transfer funds from the plan to oneself or to a third party;
- Power to negotiate plan property (e.g., mortgages, title to land and buildings or securities);
- Disbursement authority or authority to direct disbursement;
- Authority to sign checks or other negotiable
- Supervisory or decision-making responsibility over
activities that require bonding.
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