If a family investment committee approves a transaction but the bank mandate requires different signatories, review both before proceeding. Approval of an investment and authority to send a bank instruction are different parts of the control process.
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The family office should be able to identify the decision-maker, legal account holder, transaction limits and authorised instruction route for the particular investment.
Collect the current versions
Retrieve the committee terms, board delegation, investment mandate and bank instructions. Check dates, amendments and the entities covered. An old mandate stored in a shared folder may no longer match the bank’s records.
Review the company constitution where company authority is involved, using the actual adopted document. ACRA’s constitution guidance explains its governing role.
Example: the committee limit exceeds the bank limit
The committee approves an investment within its stated mandate, but the bank requires two signatories above a lower transaction limit. Staff should follow the lawful approval and instruction requirements, not split the transaction merely to avoid the bank’s control.
Create a decision-to-instruction matrix
- Entity and account involved.
- Investment type and amount.
- Who approves the investment.
- Reserved matters or higher approval required.
- Who may sign or transmit the instruction.
- Evidence the institution needs before acting.
Identify conflicts explicitly. Do not collapse every power into a column labelled “principal” if different documents assign different roles.
Check the legal and contractual boundaries
A committee may have advisory responsibilities rather than authority to bind the fund. A bank signatory may be able to transmit an instruction without having discretion to choose the investment. Review the actual documents with legal advisers.
If a delegation or mandate needs amendment, complete the proper process and institutional acceptance. A board discussion does not prove that the bank has received and implemented a new signing instruction.
Preserve the transaction trail
Keep the investment proposal, relevant approval, instruction and institution confirmation together. The trail should explain who decided, who transmitted and what was executed. Resolve any difference between the approved investment and the final transaction.
Where an instruction was sent without the expected authority, preserve the facts and seek advice promptly. Do not retrospectively create minutes suggesting approval existed when it did not.
Review the matrix when roles change
Update the review when a director, committee member or signatory leaves, or when an account or entity changes. Test a routine instruction through the proper channel before relying on the arrangement for an urgent transaction.
Make the practical process available to authorised staff while keeping sensitive account information restricted.
Does being a bank signatory mean someone can choose investments?
Not automatically. Check the decision-making and instruction powers separately.
Can a committee approval override the bank mandate?
Do not assume it does. Reconcile the applicable documents and institution requirements.
Related family-office and company guidance
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