HomeMy WebLinkAboutResolution - 2013-R0050 - Approve Investment Policy And Investment Strategy - 01/31/2013Resolution N0. 2013-R0050
January 31, 2013
Item No. 5.3
RESOLUTION
WHEREAS, the City Council has reviewed and approved the City of Lubbock's
Investment Policy and Investment Strategy and finds that it complies with the Public
Funds Investment Act (Chapter 2256 of the Texas Government Code) and the Public
Funds Collateral Act (Chapter 2257 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 recommended by the Audit and Investment Committee in the attached
document entitled "City of Lubbock, Texas, Investment Policy and Investment Strategy"
which is hereby incorporated in the 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 on January 31, 2013
ACROBE(KRTSON, MAYOR
ATTEST:
Rebe a Garza, City Secret
APPROVED AS TO CONTENT:
tl�ho-Awy-"� -
Pamela Moon, Executive Director of Finance
APPROVE_p AS TO FORM:
Chad Weaver, Assistant City Attorney
RES.Investment Policy Approval 1.8.13
City of Lubbock, TX
Finance Department
Investment Policy and Investment Strategy
Policy
The Chief Fin.,..eial OffieerExecutive 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
K4 Enterprise Funds (excluding WTMPA)
Internal Service Funds
Agency Funds
Non fi r, of EnIer-pinise Fufids (exeludi g Tr-ansit
The Bond Funds Portfolio includes bond proceeds recorded in Capital Projects. 14inds an Enterprise Fund -sand
Internal Service Funds, while the Operating Portfolio includes all other resources in Capita, Preject s:,..,ds an
EFite prse Funds as well as all theother funds listed.
Objectives
The City's principal investment objectives are listed in order of priority:
A. 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 the
Texas Government Code)
B. Safety: Preservation of capital and the protection of investment principal.
C. Liquidity: Maintenance of sufficient liquidity to meet anticipated disbursements and cash flows.
D. Diversification: Maintenance of diversity in market sector and maturity to minimize market risk in a particular
sector.
E. Yield: Attainment of a market rate of return equal to or higher than the performance measure established by the
Chief Executive Director of Finance, or Designee.
Page 1 of 14
Responsibility and Control
Delectation of Authori
The ultimate responsibility and authority for investment transactions involving the City resides with the Ch -ie€
Executive Director of Finance, or Designee. The Chief FiHancial Office Executive Director of
Finance, or Designee, has delegated the investment function to the Senior Financial Analyst, or Designee, and all are
designated as Investment Officers. (2256.005(f)) The Senior Financial Analyst, or Designee is charged with
executing the day-to-day investment functions for the City following the guidance and recommendations of the City's
Audit and Investment Committee.
Audit and Investment Committee
The City will utilize the Audit and Investment Committee to assist in monitoring the performance and structure of the
City's investments. The Audit and Investment 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 Audit and Investment Committee no less than quarterly and
verified by the City's independent auditor at least annually. The Audit and Investment Committee shall discuss
investment reports, investment strategies, and investment and banking procedures.
Investment Advisors
The Chief Finmeial OffieerExecutive Director of Finance, or Designee, may in his/her discretion, with Council
approval, appoint one or more investment advisors, registered with the Securities and Exchange Commission under
the Investment Advisors 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 advisor shall demonstrate to the Audit and
Investment Committee knowledge of cash management and experience in managing public funds. Selection of any
investment advisor shall be based upon their expertise in public cash management. An appointed investment advisor
may be granted 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's
independent auditor will perform a compliance audit of management controls on investments and adherence to
investment policies annually.
In accordance with the Act (2256.005 and 2256.008), the Investment Officers shall attend 10 hours of investment
training within 12 months of assuming duties and 10 hours not less than once in a two-year period that begins on the
first day of the City's fiscal year and consists of the two consecutive fiscal years after that date. The investment
training session shall be provided by an independent source approved by the Audit and Investment Committee.
Training must include education in investment controls, security risks, strategy risks, market risks, and
diversification of investment portfolio in order to ensure the quality and capability of investment management in
compliance with the Act.
Page 2 of 14
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 but excluding mortgage backed securities. (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,
including obligations that are fully guaranteed or insured by the Federal Deposit Insurance Corporation or by the
explicit full faith and credit of the United States. (2256.009(a)4))
• Obligations of states (other than Texas), agencies, counties, cities, and other political subdivisions of any state
rated not less than A or its equivalent by at least one nationally recognized investment rating firm.
(2256.009(a)(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
City (2256.0010)
• Fully collateralized repurchase agreements with a defined termination date; and secured by a combination of
cash and obligations authorized by the Act (Section 2256.009(a)); such securities being purchased or held must
be 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
Texas. 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)0
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.0
• 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 (with stable or positive outlook), or an equivalent rating by at least two nationally recognized
credit rating agencies, or; rated not less than A-1 or P-1 or an equivalent by one nationally recognized rating
agency plus fully secured by an irrevocable letter of credit issued by a domestic bank (2256.013). Investment in
commercial paper should be diversified by issuer and industry sector. Constant monitoring of the commercial
paper is critical to foresee any changes in credit quality.B
• 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(c)). The investment officers shall review and
understand the fund's prospectus and statement of additional information to determine: portfolio composition;
risk characteristics; duration and weighted average maturity; reputation and experience of the investment
company; total expense ratio; philosophy; strategies and portfolio policies; and, if the fund is rated by a
nationally recognized rating agency.H
Page 3 of 14
• Constant dollar, investment pools rated not less than AAA or an equivalent rating by at least one nationally
recognized rating service and authorized by the City Council and as further defined by the Act, which invests in
eligible securities as authorized by this subchapter (2256.016).
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 (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.
• 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).
Existing Investments
The Investment Officer is not required to liquidate investments that were authorized investments at the time of
purchase (2256.017).
Effect of Loss of Required Ratine
An investment that requires a minimum rating does not qualify as an authorized investment during the period the
investment does not have a minimum rating. The Investment Officer shall take all prudent measures that are
consistent with the City's investment policy to liquidate the investment(s) that does not have the minimum rating
(2256.021). In accordance with Section (2256.005(b)), the Investment Officer shall monitor rating changes in
current investments by keeping a monthly record of ratings issued by three nationally recognized rating agencies.
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 Audit and
Investment 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
70% 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
Page 4 of 14
Investment Pools
In accordance with the Act (2256.016) investment pools must be continuously rated no lower than AAA or
equivalent, 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.
• An annual audited financial statement.
• The yield and expense ratio of the pool, including a statement regarding how yield is calculated.
• 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 should be limited to no more than 5% of the total assets in the pool.
Investment Strategy
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))
(1) 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.
Page 5 of 14
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°'o 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.°
Cash Flow
A cash flow analysis shall be reviewed and updated no less than semi-annually. 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 Audit and
Investment Committee amendments to the above definition. The Investment officers will not invest in derivatives_
without annroval from both the Committee and Citv Council.
Manaeement Stvle
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.
Page 6 of 14
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 Audit and Investment 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.
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).
6. Comply with the Federal Reserve Bank of New York's capital adequacy guidelines. A compliance certificate
will be required.K
The Investment Officer, or investment advisor, 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.
All investment transactions must be competitively transacted and executed with broker/dealers or financial
institutions that have been authorized by the City.K The City will obtain at least 3 competitive offers. Exception:
New issues will not be required to be competitively transacted as all broker/dealers would show the same price and
yield.
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
Page 7 of 14
financial condition of financial institutions where certificates of deposit are held and report quarterly to the Audit and
Investment Committee.
Collateralization of Public Deposits
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.A'o 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).A,e
Collateral shall always be held by an independent third party with whom the City of Lubbock has a current custodial
agreement. This should be evidenced by a written agreement in an effort to satisfy the Uniform Commercial Code
(UCC) requirement for control.A 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, and the replacement collateral is received
prior to the release of original collateral.A
The collateral agreement must be:
• In writing
• Approved by the board of directors of the depository or its loan committee; and,
• Continuously, for the time of its execution, an official record of the depository institution.A
Safekeenine of Securities
All securities owned by the City shall be held in City designated third party safekeeping. All trades executed by a
dealer will settle Delivery vs. Payment through the City's safekeeping agent.
Securities purchased by the City shall be held in a segregated account. Collateral pledged to the City securing
Certificates of Deposit shall be held in joint custody at the Federal Reserve Bank. It is the intent of the City that all
securities be perfected in the name of the City.
Securities held in custody for the City shall be independently audited on an annual basis to verify investment
holdings.
Delivery versus Payment
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. That is, funds shall not be wired or paid until verification has
been made that the collateral was received by the Trustee. The collateral shall be held in the name of the City. The
Trustee's records shall assure the notation of the City's ownership of or explicit claim on the securities. The original
copy of all safekeeping receipts shall be delivered to the City.
Page 8of14
Same Day Funds Settlement Procedures
All new issues will be made depository book -entry eligible, and principal and interest will be paid to the depository
by fiscal agents in same-day funds on the payment date. For all existing issues, payments of principal and interest
will be made to depositories by the fiscal agents in same-day funds on the payment date.
Each depository should pay bondholders in same-day funds on the payment date. On, or prior to the morning of the
payment date, CUSIP number identification and dollar amount notifications will be sent to each depository using
automated communications.1
Reporting
Investment reports shall be prepared monthly and be signed and submitted by the Investment Officers, in a timely
manner. These reports will be submitted to the City Manager and City Council. 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 advisors, or internally. A written
record shall be maintained of all bids and offerings for securities transactions in order to insure that the City receives
competitive pricing. An independent auditor will review monthly investment reports on an annual basis, as required
by the Act.F
Changes in Statutes, Ordinances or Procedures
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 Audit and Investment
Committee and recommended to the City Council when appropriate.
Performance Review
The Audit and Investment 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 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, or other benchmark as approved by the Audit and Investment Committee. 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, employees, and Audit and Investment Committee Members involved in the investment process
shall refrain from personal business activity that could conflict with proper execution of the investment program, or
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which could impair their ability to make impartial investment decisions. Employees and investment officials shall
disclose to the City Manager and the Texas Ethics Commission, 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. A disclosure
statement with the Texas Ethics Commission and the City Manager will also be filed if an Investment Officer,
employee, or Audit and Investment Committee Member is related within the third degree by consanguinity or within
the second degree by affinity, as determined under Chapter 573, to an individual seeking to sell an investment to the
City. 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 Audit and 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 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 Audit and Investment Committee
will review the Investment Policy and Investment Strategies annually. The Audit and Investment Committee shall
forward modifications to the Policy or a resolution stating there are no changes to the City Council annually for City
Council action.
Page 10 of 14
Notes to the Investment Policy and Investment Strategy
Government Financial Officers Association (GFOA) Recommended Investment Practices
ACollateralization of Public Deposits (1984, 1987, 1993, and 2000)
BCommercial Paper (2001)
Diversification of Investments in a Portfolio (1997, 2002)
DMaturities of Investments in a Portfolio (1997, 2002)
EFrequency of Purchased Securities Valuation in Repurchase Agreements (1999, 2003)
FMark-to-Market Practices for State and Local Government Investment Portfolios and Investment Pools
(1995, 2000, 2003)
Repurchase Agreements & Reverse Repurchase Agreements (1986, 1995, 1998, 2000, 2003)
"Use of Various Types of Mutual Funds by Public Cash Managers (2003)
'Selection of Investment Advisors for Non -Pension Fund Assets (2003)
Same -Day Funds Settlement Procedures (2003)
KGovernmental Relationships with Securities Dealers (2003)
Use of Cash Flow Forecasts in Operations (2005)
Additional GFOA Recommended Investment Practices that are not applicable to the City of Lubbock's Investment
Portfolio
Market Risk (Volatility) Ratings (1995)
Master Trust and Custodial Bank Security Lending Programs (1995)
Security Lending Programs - Master Trust, Custodial and Safekeeping Considerations (1995, 2002)
Use of Derivatives by State and Local Governments for Cash Operating and Reserve Portfolios (1994,
2002)
Authoritv/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 #200 1 -R047 I /November 8, 2001
City Council Resolution #2003-R0065/February 13, 2003
City Council Resolution #2003-R0474/October 23, 2003
City Council Resolution #2004- R0560/November 18, 2004
City Council Resolution #2005- R0478/October 13, 2005
City Council Resolution #2007- R0242/June 14, 2007
City Council Resolution #2007- R0402/August, 23, 2007
City Council Resolution #2008-R0113/April 10, 2008
City Council Resolution #2009-R0138/April 9, 2009
City Council Resolution #2010-R0159/April 8, 2010
City Council Resolution #2011-R0135/April 14, 2011
City Council Resolution #2012-R0033/January 26, 2012
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Glossary
AGENCIES: Federal agency securities and/or
Government-sponsored enterprises.
ASKED: The price at which securities are offered.
BANKERS' ACCEPTANCE (BA): A draft or bill
or exchange accepted by a bank or trust company.
The accepting institution guarantees payment of the
bill, as well as the issuer.
BROKER: A broker brings buyers and sellers
together for a commission.
CERTIFICATE OF DEPOSIT (CD): A time
deposit with a specific maturity evidenced by a
certificate. Large -denomination CD's are typically
negotiable.
COLLATERAL: Securities, evidence of deposit or
other property, which a borrower pledges to secure
repayment of a loan. Also refers to securities pledged
by a bank to secure deposits of public monies.
COMPREHENSIVE ANNUAL FINANCIAL
REPORT (CAFR): The official annual report for
the City of Lubbock, Texas. It includes combined
financial statements for all fund types and account
groups as well as combining financial statements, as
applicable, and footnotes prepared in conformity with
GAAP. It also includes supporting schedules
necessary to demonstrate compliance with finance -
related legal and contractual provisions, extensive
introductory material, and a detailed Statistical and
Supplemental Information Section.
COUPON: (a) The annual rate of interest that a
bond's issuer promises to pay the bondholder on the
bond's face value. (b) A certificate attached to a
bond evidencing interest due on a payment date.
DEALER: A dealer, as opposed to a broker, acts as
a principal in all transactions, buying and selling for
his own account.
DEBENTURE: A bond secured only by the general
credit of the issuer.
DELIVERY VERSUS PAYMENT: There are two
methods of delivery of securities: delivery versus
payment and delivery versus receipt. Delivery versus
payment is delivery of securities with an exchange of
money for the securities. Delivery versus receipt is
delivery of securities with an exchange of a signed
receipt for the securities.
DERIVATIVES: (1) Financial instruments whose
return profile is linked to, or derived from the
movement of one or more underlying index or
security, and may include a leveraging factor, or (2)
financial contracts based upon notional amounts
whose value is derived from an underlying index or
security (interest rates, foreign exchange rates,
equities or commodities).
DISCOUNT: The difference between the cost price
of a security and its maturity when quoted at lower
than face value. A security selling below original
offering price shortly after sale also is considered to
be at a discount.
DISCOUNT SECURITIES: Non-interest bearing
money market instruments that are issued a discount
and redeemed at maturity for full face value, e.g.,
U.S. Treasury Bills.
DIVERSIFICATION: Dividing investment funds
among securities offering independent returns.
FEDERAL DEPOSIT INSURANCE
CORPORATION (FDIC): A federal agency that
insures bank deposits, currently up to $250,000 per
deposit until December 31, 2013.
FEDERAL FUNDS RATE: The rate of interest at
which Fed funds are traded. This rate is currently
pegged by the Federal Reserve through open market
operations.
FEDERAL RESERVE SYSTEM: The central bank
of the United States created by Congress and
consisting of a seven member Board of Governors in
Washington, D.C., 12 regional banks and about 5,700
commercial banks that are members of the system.
LIQUIDITY: A liquid asset is one that can be
converted easily and rapidly into cash without a
substantial loss of value. In the money market, a
security is said to be liquid if the spread between bid
and asked prices is narrow and reasonable size can be
done at those quotes.
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LOCAL GOVERNMENT INVESTMENT POOL
(LGIP): The aggregate of all funds from political
subdivisions that are placed in the custody of the
State Treasurer for investment and reinvestment.
MARKET VALUE: The price at which a security is
trading and could presumably be purchased or sold.
MASTER REPURCHASE AGREEMENT: A
written contract covering all future transactions
between the parties to repurchase—reverse
repurchase agreements that establishes each party's
rights in the transactions. A master agreement will
often specify, among other things, the right of the
buyer -lender to liquidate the underlying securities in
the even of default by the seller -borrower.
MATURITY: The date upon which the principal or
stated value of an investment becomes due and
payable.
MONEY MARKET: The market in which short-
term debt instruments (bills, commercial paper,
bankers' acceptances, etc.) are issued and traded.
OPEN MARKET OPERATIONS: Purchases and
sales of government and certain other securities in the
open market by the New York Federal Reserve Bank
as directed by the FOMC in order to influence the
volume of money and credit in the economy.
Purchases inject reserves into the bank system and
stimulate growth of money and credit; sales have the
opposite effect. Open market operations are the
Federal Reserve's most important and most flexible
monetary policy tool.
PORTFOLIO: Collection of securities held by an
investor.
PRIMARY DEALER: A group of government
securities dealers who submit daily reports of market
activity and positions and monthly financial
statements to the Federal Reserve Bank of New York
and are subject to its informal oversight. Primary
dealers include Securities and Exchange Commission
(SEC) -registered securities, broker-dealers, banks,
and a few unregulated funis.
PRUDENT PERSON RULE: An investment
standard. In some states the law requires that a
fiduciary, such as a trustee, may invest money only in
a list of securities selected by the custody state—the
so-called legal list. In other states the trustee may
invest in a security if it is one which would be bought
by a prudent person of discretion and intelligence
who is seeking a reasonable income and preservation
of capital.
QUALIFIED PUBLIC DEPOSITORIES: A
financial institution which does not claim exemption
from the payment of any sales or compensating use or
ad valorem taxes under the laws of this state, which
has segregated for the benefit of the commission
eligible collateral having a value of not less than its
maximum liability and which has been approved by
the Public Deposit Protection Commission to hold
public deposits.
RATE OF RETURN: The yield obtainable on a
security based on its purchase price or its current
market price. This may be the amortized yield to
maturity on a bond the current income return.
REPURCHASE AGREEMENT (RP OR REPO):
A holder of securities sells these securities to an
investor with an agreement to repurchase them at a
fixed price on a fixed date. The security "buyer" in
effect lends the "seller" money for the period of he
agreement, and the terms of the agreement are
structured to compensate him for this. Dealers use
RP extensively to finance their positions. Exception:
When the Fed is said to be doing RP, it is lending
money, that is, increasing bank reserves.
SAFEKEEPING: A service to customers rendered
by banks for a fee whereby securities and valuables of
all types and descriptions are held in the bank's vaults
for protection.
SECURITIES & EXCHANGE COMMISSION:
Agency created by Congress to protect investors in
securities transactions by administering securities
legislation.
SEC RULE 15C3-1: See Uniform Net Capital Rule.
TREASURY BILLS: A non-interest bearing
discount security issued by the U.S. Treasury to
finance the national debt. Most bills are issued to
mature in three months, six months, or one year.
TREASURY BONDS: Long-term coupon -bearing
U.S. Treasury securities issued as direct obligations
of the U.S. Government and having initial maturities
of more than 10 years.
TREASURY NOTES: Medium-term coupon -
bearing U.S. Treasury securities issued as direct
obligations of the U.S. Government and having initial
maturities from two to 10 years.
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UNIFORM NET CAPITAL RULE: Securities and
Exchange Commission requirement that member
firms as well as nonmember broker-dealers in
securities maintain a maximum ratio of indebtedness
to liquid capital of 15 to 1; also called net capital rule
and net capital ratio. Indebtedness covers all money
owed to a firm, including margin loans and
commitments to purchase securities, one reason new
public issues are spread among members of
underwriting syndicates. Liquid capital includes cash
and assets easily converted into cash.
YIELD: The rate of annual income return on an
investment, expressed as a percentage. (a) INCOME
YIELD is obtained by dividing the current dollar
income by the current market p ice for the security.
(b) NET YIELD or YIELD TO MATURITY is the
current income yield minus any premium above par
or plus any discount from par in the purchase price,
with the adjustment spread over the period from the
date of purchase to the date of maturity of the bond.
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