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HomeMy WebLinkAboutResolution - 2004-R0560 - Resolution Approving Lubbock Investment Policy And Investment Strategy - 11_18_2004Resolution No. 2004-RO560 November 18. 2004 Item No. 24 RESOLUTION WHEREAS, on August 25, 1995, the City Council of the City of Lubbock adopted Resolution #4933 which established an investment policy for the City of Lubbock; and WHEREAS, on December 18, 1997, the City Council of the City of Lubbock adopted Resolution #5728 which revised the City's investment policy so as to comply with changes to the Public Funds Investment Act (Chapter 2256 of the Texas Government Code); and WHEREAS, on May 28, 1998, the City Council of the City of Lubbock adopted Resolution #5867 which revised the City's investment policy so as to amend current practices and strategies and clarify current provisions, which revisions comply with the Public Funds Investment Act (Chapter 2256 of the Texas Government Code); and WHEREAS, on November 4, 1999, the City Council of the City of Lubbock adopted Resolution #6600 which revised the City's investment policy so as to make minor "housekeeping" changes and bring the current investment policy into compliance with House Bill 3009; and WHEREAS, on November 27, 2000, the City Council of the City of Lubbock adopted Resolution #2000-R0418, which revised the City's investment policy so as to amend current practices and strategies and clarify current provisions, which revisions comply with the Public Funds Investment Act (chapter 2256 of the Texas Government Code); and WHEREAS, on November 8, 2001, the City Council of the City of Lubbock adopted Resolution 92001-R0471, which revised the City's investment policy so as to amend current practices and strategies and clarify current provisions, which revisions comply with the Public Funds Investment Act (Ch. 2256 of the Texas Government Code); and WHEREAS, on February 13, 2003, the City Council of the City of Lubbock adopted Resolution #2003-R0065, which revised the City's investment policy so as to amend current practices and strategies and clarify current provisions, which revisions comply with the Public Funds Investment Act (Chapter 2256 of the Texas Government Code); and WHEREAS, on October 23, 2003, the City Council of the City of Lubbock adopted Resolution #2003-R0474, which revised the City's investment policy so as to amend current practices and strategies, which revisions comply with the Public Funds Investment Act (Chapter 2256 of the Texas Government Code); and WHEREAS, the City Council has reviewed and approved the City of Lubbock Texas Investment Policy and Investment Strategy and desires to make certain changes thereto so as to amend current practices, which revisions comply with the Public Funds Investment Act (Chapter 2256 of the Texas Government Code) and the Public Funds Collateral Act (Chapter 2256 of the Texas Government Code); NOW THEREFORE; BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF LUBBOCK: THAT the City of Lubbock investment policy and investment strategy, as reviewed and amended in the attached document entitled "City of Lubbock, Texas, Investment Policy and Investment Strategy" which is hereby incorporated in this Resolution as if fully set forth, BE approved and adopted for the City of Lubbock, Texas, and shall be included in the minutes of the Council. Passed by the City Council this 18th day of ATTEST: Rebe ca Garza, City Secretary APPROVED AS TO CONTENT: — - --. A �a4a�- - LeA& Dumbauld CFO / Assistant City Manager APPROVED AS TO FORM: k-hn M. Knight Assistant City Attorney ke/ Iccdocs/[nvesbmntPolicy-2005.res November 8, 2004 November 2004. M , Cm1p6 p,1GAL, MAYOR City of Lubbock, Texas, Investment Policy Resolution No. 2004-RO560November 18, 2004 Item No. 24 CITY OF LUBBOCK, TEXAS Investment Policy and Investment Strategy POLICY The Managing Director of Finance, or Designee, of the City of Lubbock, Texas, is charged with the responsibility to prudently and properly manage any and all funds of the City. Time and demand deposits must be fully collateralized and all transactions appropriately authorized. The following investment policy addresses the procedures, controls, and practices, which must be exercised to ensure sound fiscal management. The statutory foundation for this Policy is the Public Funds Investment Act (the "Act", Texas Government Code 2256) and the Public Funds Collateral Act, (Texas Government Code 2257.) SCOPE This policy shall apply to the investment of all financial assets and all funds of the City of Lubbock (hereinafter referred to as the "City") over which it exercises financial control. In order to effectively make use of the City's cash resources, all moneys, with the exception of certain bond proceeds which must be segregated and accounted for separately ("Bond Funds"), shall be pooled into one investment account ("Operating Funds"). The investment income derived from this account shall be distributed to the various City funds in accordance with the existing City Policy. These funds are accounted for in the City of Lubbock Comprehensive Annual Financial Report (CAFR) and include: General Fund Special Revenue Funds Debt Service Funds Capital Projects Funds Enterprise Funds Internal Service Fund Trust & Agency Funds The Bond Funds Portfolio includes bond proceeds recorded in Capital Project Funds and Enterprise Funds, while the Operating Portfolio includes all other resources in Capital Project Funds and Enterprise Funds as well as all other funds listed. OBJECTIVES The City's principal investment objectives are listed in order of priority: A. SAFETY: Preservation of capital and the protection of investment principal. To attain this objective, diversification is required in order that potential losses on individual securities do not exceed the income generated from the remainder of the portfolio. B. LIQUIDITY: Maintenance of sufficient liquidity to meet anticipated disbursements and cash flows. C. YIELD: Attainment of a market rate of return equal to or higher than the performance measure established by the Managing Director of Finance, or Designee. D. COMPLIANCE with all Federal, State, and other legal requirements (includes but is not limited to Chapter 2256 "Public Funds Investment Act, as amended and Chapter 2257 "Public Funds Collateral Act, as amended, of Vernon's Texas Civil Statutes) City of Lubbock, Texas, Investment Policy RESPONSIBILITY AND CONTROL Deleeation of Authori The ultimate responsibility and authority for investment transactions involving the City resides with the Managing Director of Finance, or Designee. The Managing Director of Finance, or Designee, has delegated the investment function to the Cash & Debt Manager, or Designee, and all are designated as Investment Officers. (2256.005(f)) The Cash & Debt Manager, or Designee is charged with executing the day-to-day investment functions for the City following the guidance and recommendations of the City's Investment Review Committee. Investment Review Committee The City will establish an Investment Review Committee to assist in monitoring the performance and structure of the City's investments. The Investment Review Committee shall be composed of the Managing Director of Finance, or Designee, the Cash & Debt Manager, and three other persons specifically designated by the City Manager. The Investment Review Committee shall be responsible for the investment strategy decisions, activities, and the establishment of written procedures for the investment operations consistent with this policy. Monitoring of the portfolio shall be performed by the Investment Review Committee no less than quarterly and verified by the City's independent auditor at least annually. The City Council will receive the quarterly reports from the Committee. The Investment Review Committee shall discuss investment reports, investment strategies,, and investment and banking procedures. Investment Advisers The Managing Director of Finance, or Designee, may in his/her discretion, with Council approval, appoint one or more investment advisers, registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940 (15 U.S.C. Section 80b-1 et seq.), to assist in the management of a portion of the City's assets. To be eligible for consideration, an investment adviser shall demonstrate to the Investment Review Committee knowledge of cash management as well as familiarity and experience in managing public funds. Selection of any investment adviser shall be based upon their expertise in public cash management. An appointed investment adviser may be granted limited investment discretion within the guidelines of this Investment Policy with regard to the City's assets placed under its management. A contract made under authority of the Act may not be for a term longer than two years on the original contract term. A renewal or extension of the contract must be made by the City Council by order, ordinance or resolution. (2256.003) Prudence The standard of prudence to be used for managing the City's assets is the "prudent person" rule (2256.006), which states, "Investments shall be made with judgment and care --under circumstances then prevailing --which persons of prudence, discretion and intelligence exercise in the management of their own affairs, not for speculation, but for investment, considering the probable safety of their capital as well as the probable income to be derived." Investment officers acting in accordance with written procedures and exercising due diligence, shall not be held personally liable for a specific security's credit risk or market price changes, provided deviations from expectations are reported in a timely fashion and appropriate action is taken to control adverse developments. The City will perform a compliance audit of management controls on investments and adherence to investment policies annually. In accordance with the Act (2256.008), the Investment Officers shall attend 10 hours of investment training within 12 months of assuming duties and 10 hours within every succeeding two years. The investment training session shall be provided by an independent source approved by the Investment Review Committee. Training must include City of Lubbock, Texas, Investment Policy education in investment controls, security risks, strategy risks, market risks, diversification of investment portfolio, and compliance with theAct. INVESTMENT PORTFOLIO Authorized Investments The following are authorized investments for the City and all are authorized and further defined by the Act: • Obligations of the United States or its agencies and instrumentalities, which have a liquid market with a readily determinable market value. (2256.009(1)) • Direct obligations of this state or its agencies and instrumentalities (2256.009(2)) • Other obligations, the principal and interest of which are unconditionally guaranteed or insured by, or backed by the full faith and credit of, this state or the United States or their respective agencies and instrumentalities (2256.009(4)) • Obligations of states, agencies, counties, cities, and other political subdivisions of any state rated as to investment quality by a nationally recognized investment rating firm not less than A or its equivalent (2256.009(5)) • Fully collateralized certificates of deposit issued by a state or national bank doing business in Texas and guaranteed, or insured by the Federal Deposit Insurance Corporation or its successor, secured by obligations authorized by this subchapter, or secured in any other manner and amount provided by law for deposits of the investing entity (2256.0010) • Fully collateralized repurchase agreements with a defined termination date; and secured by obligations authorized by the Act (Section 2256.009(a)(1)); such collateral pledged to the City, held in the City's name, and deposited at the time the investment is made with the City or with an independent third party selected and approved by the City. Repurchase agreements must be purchased through a primary government securities dealer, as defined by the Federal Reserve, or a bank doing business in this state. The term of any reverse repurchase agreements may not exceed 90 days after the date the reverse security repurchase agreement is delivered. Money received by the City under the terms of a reverse security repurchase agreement shall be used to acquire additional authorized investments, but the term of the authorized investments acquired must mature not later than the expiration date stated in the reverse security repurchase agreement. (2256.011) • Bankers' acceptances with a stated maturity of 270 days or fewer from the date of its issuance; and liquidated in full at maturity; and eligible for collateral for borrowing from a Federal Reserve Bank; and accepted by a bank organized and existing under the laws of the United States or any state, if the short-term obligations of the bank, or of a bank holding company of which the bank is the largest subsidiary, are rated not less than A-1 or P-1 or an equivalent rating by at least one nationally recognized credit rating agency (2256.012) • Commercial paper with a stated maturity of 270 days or fewer from the date of its issuance, and rated not less than A-1 or P-1 or an equivalent rating by at least two nationally recognized credit rating agencies (2256.013) • No-load money market mutual funds regulated by the Securities and Exchange Commission, and with a dollar - weighted average stated maturity of 90 days or fewer, and whose investment objectives include the maintenance of a stable net asset value of $1 for each share (2256.014(a)) • AAA -rated, constant dollar, investment pools authorized by the City Council and as further defined by the Act, which invests in eligible securities as authorized by this subchapter (2256.016) City of Lubbock, Texas, Investment Policy The following investments are prohibited by the Act (2256.009(b)): • An obligation whose payment represents the coupon payments on the outstanding principal balance of the underlying mortgage -backed security collateral and pays no principal, i.e. interest -only collateralized mortgage obligations (10's). • Obligations whose payment represents the principal stream of cash flow from the underlying mortgage -backed security collateral and bears no interest, i.e. principal -only collateralized mortgage obligations (PO's). • Collateralized mortgage obligations that have a stated final maturity date of greater than 10 years. • Collateralized mortgage obligations the interest rate of which is determined by an index that adjusts opposite to the changes in a market index, i.e. CMO inverse floaters. • Investment in the aggregate of more than 80 percent of the entity's monthly average fund balance, excluding bond proceeds and reserves and other funds held for debt service, in money market mutual funds or mutual funds; investment in the aggregate of more than 15 percent of its monthly average fund balance, excluding bond proceeds and reserves and other funds held for debt service, in mutual funds; investment of any portion of bond proceeds, reserves, and funds held for debt service, in mutual funds; and investment of its funds or funds under its control, including bond proceeds and reserves and other funds held for debt service, in any one mutual fund in an amount that exceeds 10 percent of the total assets of the mutual fund (2256.014) Investment Diversification It is the intent of the City to diversify the investment instruments within the portfolio to avoid incurring unreasonable risks inherent in over -investing in specific instruments, individual financial institutions or maturities. The asset allocation in the portfolio should, however, be flexible depending upon the outlook for the economy and the securities markets. When conditions warrant, the guidelines below may be exceeded by approval of the Investment Review Committee. The City may invest to the following limits as a percentage of its total portfolio: 100% in United States Treasury Obligations 50% in Certificates of Deposit 80% in Federal Instrumentalities or Agencies 30% in Repurchase Agreements collateralized by Federal Instrumentalities, or 100% in Repurchase Agreements collateralized by United States Treasury Obligations 25% in Commercial Paper (no more than 10% in any one issuer) 20% in Banker's Acceptances Investment Pools In accordance with the Act (2256,016) investment pools must be continuously rated no lower than AAA, with a weighted average maturity of less than 60 days. The pool must have an advisory board. A thorough investigation of the pool is required prior to investing, and on a continual basis, as due diligence, and shall include but is not limited to, the following topics: • A description of eligible investment securities, and a written statement of investment policy and objectives. • A description of interest calculations, method of distribution, and treatment of gains and losses. • A description of the method used to safeguard securities (including the settlement processes), and the frequency and method by which securities are priced. • The frequency of audit of the program. • A description of eligible participants along with allowable frequency and size of deposits and withdrawals. • A schedule for receiving statements and portfolio listings. • The policy under which reserves, retained earnings, etc, may be utilized by the pool. • A fee schedule, and when and how it is assessed. 4 City of Lubbock, Texas, Investment Policy Information related to the fund's eligibility for accepting bond proceeds. Investments in a qualifying Investment Pool (in accordance with City Resolution dated May 28, 1992) should be limited to no more than 5% of the total assets in the pool. Investment Strate The City of Lubbock maintains portfolios, which utilize four specific investment strategy considerations, designed to address the unique characteristics of the fund groups represented in the investment portfolios. The policies detailed below are subject to an annual review to occur prior to the annual City Council action regarding the Investment Policy. (2256.005(d)) Operating Funds and Commingled Pools Containing Operating Funds The investment strategy for the portfolio containing operating funds, the Operating Portfolio, has as its primary objective to assure that anticipated cash flows are matched with adequate investment liquidity. Investment maturities shall be matched against liabilities including debt service requirements. The secondary objective of the Operating Portfolio is to create a portfolio structure, which will experience minimal volatility during economic cycles. This will be accomplished by purchasing high quality, short- to medium -term securities, which will complement each other in a laddered maturity structure. The City shall maintain a dollar -weighted average maturity of two (2) years or less based on the stated final maturity dates of each security in its Operating Portfolio. The City shall at all times maintain at least 10% of its operating investment portfolio in instruments maturing in 120 days or less. (2) Debt Service Funds The investment strategy for debt service funds shall have as the primary objective the assurance of investment liquidity adequate to cover each succeeding debt service obligation on the required payment date. Securities purchased shall not have a stated final maturity date which exceeds any unfunded debt service payment date. The maximum weighted average maturity shall not exceed one (1) year. (3) Debt Service Reserve Funds The investment strategies for debt service reserve funds shall have as the primary objective the ability to generate a dependable revenue stream to the appropriate debt service fund from securities with a low degree of volatility. Except as may be required by the bond ordinance specific to an individual issue, securities should be of high quality with short- to intermediate -term maturities. The maximum weighted average maturity shall not exceed one (1) year. Volatility shall be further controlled through the purchase of securities carrying the highest coupon available within the desired maturity and quality range using a laddered maturity structure. Such securities will tend to hold their value during economic cycles. (4) Bond Funds The investment strategy for bond funds will have as their primary objective to assure that anticipated cash flows are matched with adequate investment liquidity. These portfolios should include at least 10% in highly liquid securities to allow for flexibility and unanticipated project outlays. The stated final maturity dates of securities held shall not exceed the estimated project completion date. The maximum weighted average maturity shall not exceed two (2) years. 5 City of Lubbock, Texas, Investment Policy A cash flow analysis shall be reviewed and updated no less than semi-annually, in connection with revised budget and proposed budget reviews. This cash flow analysis is the basis for matching liabilities or obligations with security maturities as outlined in the strategies previously listed. Maximum Maturity The maximum maturity of any individual security the City may invest in shall be 5 years. Derivatives A derivative is any security whose cash flow characteristics (coupon, redemption amount, or stated and estimated maturity) depend upon one or more indices or that has embedded futures or options. They can be linked to different market sectors or interest rate scenarios including: 1) increasing or decreasing interest rates, 2) U.S. Treasury yield curve, 3) foreign yield curves, 4) relationship between two different yield curves, 5) foreign exchange rates 6) equity price movements, and 7) commodity price movements. The City shall define a derivative for purposes of investment as any mortgaged backed security to eliminate possible extension, volatility and reinvestment risk. The City will not invest in any mortgage -backed securities (MBS) whether a straight pass -through mortgage backed or further derived mortgage backed security (CMO). The City shall not define United States Agency and Instrumentality debentures as derivatives. Debentures have a defined maturity date, which cannot extend regardless of their structure. These will be restricted to a maximum maturity of three (3) years. Floating rate debentures may only float on the U.S. Treasury rates and not exceed one (1) year in maturity. The Investment Officers will monitor the development of new financial instruments and may present to the Investment Review Committee amendments to the above definition. Other Investment Guidelines and Controls All investment transactions must be executed with broker/dealers and financial institutions that have been authorized by the City and each transaction must be competitively transacted with at least three authorized broker/dealers or financial institutions. In addition, before any repurchase agreements shall be executed with an authorized broker/dealer or financial institution, a Master Repurchase Agreement must be signed between the City and that broker/dealer or financial institution. The Investment Officer shall maintain a file of all executed Master Repurchase Agreements. The City seeks an active, rather than passive, management of its portfolio assets. Assets may be sold at a loss only if the Investment Officers feel that the sale of the security is in the best long-term interest of the City. Supporting documentation shall be maintained by the Investment Officer for all sales of securities in which there is a book loss or where a security is sold in order to simultaneously purchase another security. AUTHORIZED FINANCIAL BROKER/DEALERS AND INSTITUTIONS As defined by the Act (2256.005(k)) the City shall maintain a list of authorized broker/dealers and financial institutions, which are approved by the Investment Review Committee for investment purposes. It shall be the policy of the City to purchase securities only from those authorized institutions and firms. The Committee will review and approve the list at least annually. City of Lubbock, Texas, Investment Policy To be eligible for authorization, each broker/dealer or financial institution shall: 1. Complete and submit to the City a Broker/Dealer Questionnaire, which includes the firm's most recent financial statements. 2. Provide a written instrument certifying that they have received and thoroughly reviewed the City's investment policy and have implemented reasonable procedures and controls and understand the parameters set by the City of Lubbock. 3. Be a member of the FDIC (Financial Institutions only) 4. Be a "primary" dealer or regional dealer that qualifies under Securities & Exchange Commission Rule 150-1 (uniform net capital rule). All broker/dealers must submit: (a) audited financial reports (b) proof of National Association of Security Dealers certification, and (c) proof of state registration (Broker/Dealers only). 5. Provide competitive offers, resulting in the sale of a security, to the City. If there are no sales from a particular broker/dealer over a 12-month period, this broker/dealer will be removed from the approved broker/dealer listing (Broker/Dealers only). The Investment Officer shall maintain a file of all Broker/Dealer Questionnaires. Broker/dealers and other financial institutions will be selected on the basis of their expertise in cash management and their ability to provide service to the City's account. The Investment Officers shall exercise due diligence in monitoring the activities of other officers and subordinate staff members engaged in transactions with the City. Employees of any firm or financial institution offering securities or investments to the City of Lubbock shall be trained in the precautions appropriate to public -sector investments and shall be required to familiarize themselves with the City's investment objectives, policies and constraints. In the advent of a material adverse change in the financial condition of the firm or financial institution, the City will be informed immediately by telephone and in writing. Selection of Financial Institutions Depositories shall be selected through the city's banking services procurement process, which shall include a formal request for application. In selecting depositories, the services available, service costs, and credit -worthiness of institutions shall be considered, and the Investment Officers, shall conduct a comprehensive review of prospective depositories' credit characteristics and financial history. The City shall select financial institutions from which the City may purchase certificates of deposit in accordance with the Act and this Policy. The City of Lubbock will have a written depository agreement with any financial institution with whom the City of Lubbock has time or demand deposits. The Investment Officer shall monitor the financial condition of financial institutions where certificates of deposit are held and report quarterly to the Investment Review Committee. Collateralization/SafekeMing Collateralization requirements are governed by Texas Government Code Chapter 2257 Public Funds Collateral Act. Collateralization will be required on three types of investments: time deposits, demand deposits, and repurchase agreements. In order to anticipate market changes and provide a level of security for all funds, the required minimum collateral level will be 102% of market value of principal and accrued interest monitored and maintained by the financial institution. The City of Lubbock chooses to limit collateral to the following: Underlying collateral shall be composed of those investments approved in this policy and mortgage -backed securities as defined in Texas Government Code Chapter 2257.002. The maturity of the collateral security shall be no longer than a 30-year stated final maturity. Market value of the collateral shall be priced at least daily for repurchase agreements and monthly for time and demand deposits (including mortgage -backed securities). City of Lubbock, Texas, Investment Policy Collateral shall always be held by an independent third party with whom the City of Lubbock has a current custodial agreement. A safekeeping receipt must be supplied to the City of Lubbock for any transaction involving sales/purchases/maturities of securities and/or underlying collateral, which the City of Lubbock will retain. The right of collateral substitution is granted provided the substitution has prior approval of the City and is followed by the delivery of an original safekeeping receipt to the City of Lubbock. Delivery versus Pavment All security transactions, including collateral for repurchase agreements, entered into by the City of Lubbock shall be conducted on a delivery -versus -payment (DVP) basis, and held in third party safekeeping by a Federal Reserve member financial institution designated as a City depository. The trust department of the institution designated as depository will be considered to be a third party for the purposes of safekeeping securities. Securities purchased by the City that are wireable via the Federal Reserve System shall be held by the City's depository bank in their Customer Account (02). Collateral pledged to the City securing Certificates of Deposit shall be held in joint custody at the Federal Reserve Bank (07). It is the intent of the City that all securities be perfected in the name of the City. Reporting Investment reports shall be prepared on a quarterly and annual basis and be signed and submitted by the Investment Officers, in a timely manner. A written record shall be maintained of all bids and offerings for securities transactions in order to insure that the City receives competitive pricing. The Investment Review Committee will meet no less than quarterly to review the investment activity. The quarterly reports should include listings of all the investments held by the City, the current market valuation of the investments, transactions summaries, and performance results and in full compliance with the Act. Within a reasonable time after the end of each quarter, the Investment Officers shall prepare and submit to the City Manager, and City Council a written report of the quarter's investment activity. This report must be signed by each official member of the Investment Review Committee. This report shall describe in detail the investment position of the City, disclose the market value and book value of each fund group as well as each separate investment, and state the maturity date of each security and accrued interest for the reporting period. It must also express the compliance of the portfolio to the investment strategy contained in the City's Investment Policy, the Act, and Generally Accepted Accounting Principles (GAAP). Market pricing information is obtained through the use of appropriate software available either externally such as through investment advisers, or internally. An independent auditor will review quarterly investment reports on an annual basis, as required by the Act. CHANGES IN STATUTES, ORDINANCES OR PROCEDURE This policy is designed to operate within the restrictions set forth in applicable State of Texas and Federal laws and statutes, but it does not permit all activity allowed by those laws. Changes to state or federal laws, which restrict a permitted activity under this policy, shall be incorporated into this policy immediately upon becoming law. Changes to state or federal laws, which do not further restrict this policy, shall be reviewed by the Investment Review Committee and recommended to the City Council when appropriate. PERFORMANCE REVIEW The Investment Review Committee shall meet no less than quarterly to review the portfolio's adherence to appropriate risk levels and to compare the portfolio's total return to the established investment objectives and goals. City of Lubbock, Texas, Investment Policy The Investment Officers shall periodically establish a benchmark yield for the City's investments, which shall be equal to the average yield on the United States Treasury security, which most closely corresponds to the portfolio's actual weighted average maturity. When comparing the performance of the City's portfolio, all fees and expenses involved with managing the portfolio should be included in the computation of the portfolio's rate of return. ETHICS AND CONFLICTS OF INTEREST Investment Officers, officers and employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. Employees and investment officials shall disclose to the City Manager, any material financial interests in financial institutions that conduct business within this City, and they shall further disclose any large personal financial/investment positions that could be related to the performance of this City's portfolio. Employees and officers shall subordinate their personal investment transactions to those of the City particularly with regard to the timing of purchases and sales. INTERNAL CONTROLS The Investment Officers shall establish a system of internal controls, which shall be documented in writing. The internal controls shall be reviewed by the Investment Review Committee and with the independent auditor on an annual basis. The controls shall be designed to prevent losses of public funds arising from fraud, employee error, misrepresentation by third parties, unanticipated market changes, or imprudent actions by employees and officers of the City. POLICY REVISIONS The City Council shall adopt a written instrument by rule, order, ordinance, or resolution stating that it has reviewed the investment policy and investment strategies and that the written instrument so adopted shall record any changes made to either the investment policy or investment strategies (2256.005(e)). The Investment Review Committee will review the Investment Policy and Investment Strategies annually. The Investment Review Committee shall forward modifications to the Policy or a resolution stating there are no changes to the City Council annually for City Council action. AUTHORITY/DATE ISSUED: City Council Resolution # 5728/December 18, 1997 City Council Resolution # 5867/May 28, 1998 City Council Resolution #6600/November 4, 1999 City Council Resolution #2000-R0418/November 27, 2000 City Council Resolution #2001-R047I November 8, 2001 City Council Resolution #2003-R0065/February 13, 2003 City Council Resolution #2003-R0474/October 23, 2003