HomeMy WebLinkAboutResolution - 2001-R0471 - Investment Policy And Strategy Revisions - 11/08/2001Resolution No. 2001-RO471
November 8, 2001
Item No. 23
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 45728 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, 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 and strategies and clarify current provisions, which revisions comply
with the Public Funds Investment Act (Chapter 2256 of the Texas Government Code); NOW
THEREFORE,
IT IS HEREBY 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 8th day of November 2001.
WINDY SITT N, MAYOR
ATTEST:
Cqg
Rebecca Garza, City Secretary
APPROVED AS TO CONTENT:
of Fi
APPROVED AS TO
Assistant City Attorney
JMK:cp Cityatt/John/InvestmentPolicy-3. Res & ccdocs
October 29, 2001
Resolution No. 2001-RO471
City of Lubbock, Texas, Investment Policy
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. These funds must be fully collateralized and
appropriately authorized. The following investment policy addresses the methods, procedures, and practices which
must be exercised to ensure sound fiscal management.
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 ("Consolidated 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 Consolidated 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. The Cash & Debt Manager is charged with executing the day -today
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 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 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 Managing Director of Finance, or Designee, and to
the Cash & Debt Manager 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 Sec. 2256.003 of the PFIA 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.
Prudence
The standard of prudence to be used for managing the City's assets is the "prudent person" rule, 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 responsible 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 Section 2256 Public Funds Investment Act, as amended, the Managing Director of Finance,
and the Cash & Debt Manager shall attend an investment training session no less often than once every two fiscal
years commencing September 1, 1997 and shall receive not less than 10 hours of instruction relating to investment
responsibilities. The investment training session shall be provided by an independent source approved by the
City of Lubbock, Texas, Investment Policy
Investment Review Committee. Training must include education in investment controls, security risks, strategy
risks, market risks, diversification of investment portfolio, and compliance with the PFIA.
INVESTMENT PORTFOLIO
Eligible Investments
The following are eligible investments for City of Lubbock and all are authorized by V.T.C.A., Government Code,
Section 2256 (the Public Funds Investment Act) as amended:
• Obligations of the United States or its agencies and instrumentalities, which have a liquid market with a
readily determinable market value.
• Direct obligations of this state or its agencies and instrumentalities
• 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
• 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
• Certificates of deposit issued by a state or national bank deviled— doing business in this state 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
• Repurchase agreements with a defined termination date; and secured by obligations authorized by V.T.C.A.,
Government Code, Section 2256.009(a)(1); and pledged to the City, held in the City's name, and deposited at
the time the investment is made with the City or with a 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.
• 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
• 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
• 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
• AAA -rated, constant dollar, investment pools authorized by the City's governing body and as defined by
Public Funds Investment Act 2256, which invests in eligible securities as authorized by this subchapter
The following investments are prohibited by V.T.C.A., Government Code, Section 2256:
Obligations 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 (IO'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.
City of Lubbock, Texas, Investment Policy
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
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 must be continuously rated no lower than AAA, with a weighted average maturity of <90 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.
• Information related to the fund's eligibility for accepting bond proceeds.
Investments in a qualifying Investment Pool (in accordance with 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.
4
City of Lubbock, Texas, Investment Policy
(1) Operating Funds and Commingled Pools Containing Operating Funds:
Investment strategies for operating funds, or Consolidated Fund, have as their 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 consolidated fund 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 2 years or less based on the stated final maturity
dates of each security in its consolidated fund. The City shall at all times maintain at least 10% of its consolidated
investment portfolio in instruments maturing in 120 days or less.
(2) Debt Service Funds
Investment strategies for debt service funds shall have as the primary objective the assurance of investment
liquidity adequate to cover the debt service obligation on the required payment date. Securities purchased shall not
have a stated final maturity date which exceeds the debt service payment date.
(3) Debt Service Reserve Funds
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.
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
Investment strategies 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.
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.
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 have 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.
City of Lubbock, Texas, Investment Policy
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 can not 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 Cash & Debt Manager will monitor the development of new financial instruments and may present to the
Investment Review Committee amendments to the above definition.
Other Investment Guidelines
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 Cash & Debt Manager 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 Managing Director of Finance, or Designee, or the Investment Adviser feels that the sale of the security is in
the best long-term interest of the City. Supporting documentations shall be maintained by the Cash & Debt
Manager 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 PFIA Chapter 2256, as amended, the City shall maintain a list of authorized broker/dealers and
financial institutions whiehinstitutions, which are approved by the IRCm;es....a„* neN e., C.,,,,utittee for
investment purposes. It shall be the policy of the City to purchase securities only from those authorized
institutions and firms. The IRC will and to review the list at least annually.
To be eligible for authorization, each broker/dealer or financial institution shall:
1, must -complete and submit to the City a Broker/Dealer Questionnaire whie Questionnaire, which includes the
firm's most recent financial statements.
2. i awe eh bfeke• ` eale' mus 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 members of the FDIC (Financial Institutions only) in or -def W be eligible fe
m►ther
4.--- a ...... ay mel-de<be a "primary" dealers or regional dealers that qualifyies 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).
City of Lubbock, Texas, Investment Policy
The Cash & Debt Manager 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.
and the Mamging Direetor- of Finance, or- Designee, shall ce a cem.—,. -I,- *
elmnswe fmm, of prospective
depesitefiesr
The supervising officer shall agree to 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 proposals. In selecting depositories, the credit -worthiness of institutions shall be
considered, and the Managing Director of Finance, or Designee, 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 C.D.'s in accordance with Public
Funds Investment Act 2256 as amended. The City of Lubbock will have a written agreement with any financial
institution with whom the City of Lubbock has time or demand deposits. The Cash & Debt Manager shall monitor
the financial condition of financial institutions where Certificates of Deposit are held and report quarterly to the
Investment Review Committee.
Collateralization/Safekeebin
Collateralization requirements are governed by Chapter 2257 COLLATERAL FOR PUBLIC FUNDS.
Collateralization will be required on three types of investments: depository bank balances, certificates of deposit
and repurchase agreements. In order to anticipate market changes and provide a level of security for all funds, the
collateralization 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 enly-those investments approved in this policy f f im,es*ment by **
City of r ubbe a policy and mortgage-backed securities as defined in Chapter 2257.002 of the Texas Public
Funds Collateral Act. The maturity of the collateral security shall be no longer than 5 years for CD's or 10 years
for repurchase agreements. Market value of the collateral shall be priced at least daily for repurchase agreements
and monthly for seeufities:time and demand deposits (including mortgage-backed securities).
Collateral will 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 with prior approval of the City and is followed
by the delivery of a safekeeping receipt to the City of Lubbock.
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
7
City of Lubbock, Texas, Investment Policy
member financial institution designated as the City's depository. The trust department of the institution designated
as depository will be considered to be a third parry for the purposes of safekeeping securities.
Securities purchased by the City that are wirable 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 submitted to the Managing Director of
Finance, or Designee, 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.
Within a reasonable time after the end of each quarter, the Cash & Debt Manager shall prepare and submit to the
Managing Director of Finance, or Designee, 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 and the Public Funds Investment Act as amended, and Generally
Accepted Accounting Principles. 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 Public Funds Investments Act 2256, as amended.
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.
The Managing Director of Finance, or Designee, or his/her appointee, 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.
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City of Lubbock, Texas, Investment Policy
ETHICS AND CONFLICTS OF INTEREST
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 Managing Director of Finance, or
Designee, 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 Managing Director of Finance, or Designee, shall establish a system of internal controls, which shall be
documented in writing. The internal controls shall be reviewed by the investment 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 governing body 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. The Investment Policy and Investment
Strategies will be reviewed annually by the Investment Review Committee. 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