Sections II and III


Individuals other than faculty/staff may have special relationships with the University (e.g., retirees or persons supplying independent contractor services). University faculty/staff should use care to be sure that decisions to purchase or enter into other contractual situations with these individuals are made in the best interest of the University. Faculty/staff should use care to protect the University from the appearance of impropriety, as well as actual impropriety. In addition, proper University contracting policy must be followed.


A. Guidelines
Faculty/staff who want to sell University-authorized 403(b) retirement options to other University employees may do so as long as there is compliance with the reporting requirements and limitations outlined in Section B below. Contracts may be made only with insurance companies and mutual funds on the approved list maintained by Human Resources, Benefits Section.
B. Reporting Requirements and Limitations
  1. The faculty/staff must demonstrate that he/she operates an ongoing pre-existing business according to the following criteria:

    1. The business must have been a licensed security dealer for at least one year prior to doing 403(b) business with University employees.

    2. The faculty/staff's investment business cannot generate 50 percent or more of its gross annual sales from 403(b) sales to University employees.

  2. The faculty/staff must complete a Financial Disclosure Statement and submit it to the Purchasing Department before he/she is eligible to do 403(b) business with University employees. A disclosure statement must be resubmitted annually to remain eligible.

  3. The faculty/staff may not sell 403(b) securities or services to members of her/his own department/unit or to the persons he/she supervises.

  4. No 403(b) contracts may be made through a faculty/staff's business for four years after that faculty/staff member has been involved in the selection of and/or monitoring of the investment options.
C. Exceptions
The President or designee may approve exceptions to this Policy, which involve University faculty/staff. Faculty/staff must process their request for an exception through their appropriate vice president. Exceptions involving the President must be approved by the Finance Committee of the Board of Trustees. Approval of all exceptions must be in writing and include a disclosure of the parties to the transaction, the subject matter of the transaction, and reasons for the exception. If approved, the signed exception must be forwarded to the Purchasing Department.