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C7D-Amend City�s Investment Policy Add Israeli Bonds As Authorized InvestmentsCOMMISSION ITEM SUMMARY Condensed Title: A Resolution of the Mayor and City Commission of the City of Miami Beach, Florida, amending the City's investment policy and procedures, as adopted by Resolution No. 95- 21726 and amended by Resolutions No. 97-22315 and No. 2007-26602 by adding Israeli bonds as authorized investments, adding maximum percentage per issuer and replacing the investment committee with the investment advisor. Key Intended Outcome Supported: Improve the City's overall financial health and maintain overall bond rating. Supporting Data (Surveys, Environmental Scan, etc.): As required by the Florida Legislature, Florida Statutes 218.415. · Issue: I Should the Mayor and City Commission approve the Resolution? Item Summary/Recommendation: The Administration recommends that the Mayor and City Commission amend the City's Investment Policy and Procedures, as adopted by Resolution No. 95-21726 and amended by Resolutions No. 97-22315 and No. 2007-26602 by adding Israeli bonds as authorized investments, adding maximum percentage per issuer and replacing the investment committee with the investment advisor. Adviso Board Recommendation: Financial Information: Amount Account Approved Source of Funds: N/A OBPI Total Ci Clerk's Office Le islative Trackin Patricia Walker, Chief Financial Officer Si n-Offs: Department Director JMG T:\AGENDA\2012\January 11\Regular\lnvestment Policy Change FY12-Summary Memo.docx (9 MIAMIBEACH 117 AGENDA ITEM C. 7 [) DATE /-// -12... ~ MIAMI BEACH City of Miami Beach, 1700 Convention Center Drive, Miami Beach, Florida 33139, www.miamibeachfl.gov TO: FROM: DATE: SUBJECT: COMMISSION MEMORANDUM Mayor Matti Bower and Members of the City Commission Jorge M. Gonzalez, City Manager ex January 11, 2012 u A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, AMENDING THE CITY'S INVESTMENT POLICY AND PROCEDURES, AS ADOPTED BY RESOLUTION NO. 95-21726 AND AMENDED BY RESOLUTIONS NO. 97-22315 AND NO. 2007-26602 BY ADDING ISRAELI BONDS AS AUTHORIZED INVESTMENTS, ADDING MAXIMUM PERCENTAGE PER ISSUER AND REPLACING THE INVESTMENT COMMITTEE WITH THE INVESTMENT ADVISOR. ADMINISTRATION RECOMMENDATION Adopt the Resolution. KEY INTENDED OUTCOME SUPPORTED Improve the City's overall financial health and maintain overall bond rating. BACKGROUND On November 18, 1987, the City passed and adopted Ordinance No. 87-2588 which amended the Code of the City of Miami Beach by creating Chapter 18A entitled "Investment of Surplus Funds." This Chapter authorized the City to invest and reinvest any surplus public funds in such investments as US Government obligations, banker's acceptances, certificate of deposits, obligations issued by any state or territory of the United States, and other types of investment instruments. On September 16, 1992, the City amended Ordinance No. 87-2588 by passing and adopting Ordinance No.92-2793 which added commercial paper rated A-1 and P-1 from Moody's and Standard & Poor's as another allowable investment. The City again amended Chapter 18A on March 15, 1997 by passing and adopting Ordinance No. 97-3074 which added corporate notes and bonds, money markets and mutual funds, fixed income mutual funds, mortgage-backed securities, external managed investment funds, and interest rate swaps agreements to the list of allowable investments instruments. 118 Commission Memorandum Investment Policy January 11, 2012 Page 2 of 3 The City's Investment Policy and Procedures were officially adopted in writing on September 27, 1995 with the passage and adoption of Resolution No. 95-21726. This was a result of the passing of Chapter 218.415 of the Florida Statutes that required the adoption of a formal written investment policy by local governments. On March 5, 1997, the City passed and adopted Resolution No. 97-22315 which adopted the percentages of the City's funds which may be invested in each investment category. The last amendment to the Investment Policy was done in 2007 by the request of then Mayor David Dermer who wanted to add certain investments that the City should not invest in. He wanted to incorporate the State's "Protecting Florida's Investment Act" to the City's policy. This Act prohibited the investment of public funds managed by the City in any "Scrutinized Companies" with active business operations in Sudan or Iran, as listed by the State Board of Administration (SBA) on a quarterly basis. Thus, this Act was incorporated into the City's Investment Policy by the adoption and passage of Resolution No. 2007-26602 on July 11, 2007. ANALYSIS The State of Florida, in the passing of Chapter 218.415, has allowed the investment in Israeli bonds. Chapter 218.415( 16) specifically states that "(t)hose units of local government electing to adopt a written investment policy ... may by resolution invest and reinvest any surplus public funds in their control or possession in: .... (f) rated or unrated bonds, notes, or instruments backed by the full faith and credit of the government of Israel." Due to the State allowing investments in Israeli bonds, the City recommends the addition of Israeli bonds to the list of authorized investments in the City's Investment Policy and Procedure. In addition, we recommend the removal of Section L-lnvestment Committee from the Investment Policy and replacing it with Investment Advisor. The City has for several years now had Cutwater Investor Services Corp. ("Cutwater") (formally known as MBIA Municipal Investors Services Corporation) as its Investment Advisor. They have provided the City with numerous investment opportunities especially in a market of declining interest rates. They also had the foresight of advising us not to investment in the Florida Local Government Investment Pool which froze all deposits/withdrawals in November 2007 that resulted in many governments from retrieving 100% of their investments. Cutwater continuously works with the City Administration to refine our investment strategies and assist us in insuring the fiscally responsible and prudent investment of all City funds. They have recently made recommendations to modify the City's Policy that will assist us in maintaining a strong portfolio of investments as well as update the language and terminology to conform the policy to current government industry best practices. Cutwater has recommended the addition of a maximum percentage per issuer for each type of investment which will reduce the risk of over-investing in any one particular issuer. The City's Investment Policy has been reviewed by our Investment Advisors and the City, and we have made other minor changes to bring it into a more current status. The revised Investment Policy and Procedures are included herein as Exhibit A. 119 Commission Memorandum Investment Policy January 11, 2012 Page 3 of 3 At the December 6, 2011, meeting of the Finance and Citywide Projects Committee, the Committee voted to recommend approval of the proposed revisions to the City's Investment Policy and Procedures and that the Policy be updated, at a maximum, every five years to more accurately reflect conditions in the market. CONCLUSION The Administration recommends that the Mayor and City Commission amend the City's Investment Policy and Procedures, as adopted by Resolution No. 95-21726 and amended by Resolutions No. 97-22315 and No. 2007-26602 by adding Israeli bonds as authorized investments, adding maximum percentage per issuer and replacing the investment committee with the investment advisor. JMG/PDW 120 RESOLUTION NO.----- A RESOLUTION OF THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, AMENDING THE CITY'S INVESTMENT POLICY AND PROCEDURES, AS ADOPTED BY RESOLUTION NO. 95-21726 AND AMENDED BY RESOLUTIONS NO. 97-22315 AND NO. 2007-26602 BY ADDING ISRAELI BONDS AS AUTHORIZED INVESTMENTS, ADDING MAXIMUM PERCENTAGE PER ISSUER AND REPLACING THE INVESTMENT COMMITTEE WITH THE INVESTMENT ADVISOR. WHEREAS, the City of Miami Beach has followed investment policies and procedures established by the Finance Department, as presented to the Mayor and Commission in 1985, as an informational item; and WHEREAS, effective October 1, 1995, all local governmental entities in the State of Florida were required to adopt an investment policy as required by Chapter 218.415 of the Florida Statutes; and WHEREAS, the Mayor and City Commission adopted Resolution No. 95-21726 on September 27, 1995, which adopted said policy for the City of Miami Beach; and WHEREAS, the Mayor and City Commission adopted Resolution No. 97-22315 on March 5, 1997, which increased the number of authorized investments options and added the percentage of the City's funds which may be invested in said additional categories; and WHEREAS, the Mayor and City Commission adopted Resolution No. 2007- 26602 on July 11, 2007, which incorporated in the City's Investment Policy the State's "Protecting Florida's Investment Act", prohibiting the investment of public funds managed by the City in any "Scrutinized Companies" with active business operations in Sudan or Iran, as listed by the State Board of Administration (SBA) on a quarterly basis; and WHEREAS, the Mayor and City Commission have determined that Israeli Bonds be added to the list of authorized investment options in addition to adding a maximum percentage by issuer and replacing the investment committee with the investment advisor. NOW, THEREFORE, BE IT DULY RESOLVED THAT THE MAYOR AND CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, that the amended City of Miami Beach Investment Policy and Procedure, attached hereto and incorporated herein as exhibit "A", be approved and adopted by the Mayor and City Commission. PASSED and ADOPTED this -----day of _____ .2012. MAYOR ATTEST: APPROVED AS TO FORM & LANGUAGE CITY CLERK 121 '" CUTION "J.. .... (L- \,.. J Date EXHIBIT A CITY OF MIAMI BEACH INVESTMENT POLICY AND PROCEDURE CITY OF MIAMI BEACH INVESTMENT POLICY AND PROCEDURE 122 SUBJECT CITY OF MIAMI BEACH INVESTMENT POLICY AND PROCEDURE TABLE OF CONTENTS Background ............................................................................................ . General Overview .................................................................................... . Investment Objectives .............................................................................. . Investment Ethics..................................................................................... 2 Investment Process.................................................................................. 2 Authorized Investment............................................................................... 3 Prohibited Investments............................................................................. .. 6 Maturity & Liquidity Requirements.................. .. . .. . .. . .. . .. .. .. .. . .. . .. . .. .. .. .. . .. . .. . .. .. 7 Portfolio Composition................................................................................ 7 Custodial Account.................. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Master Repurchase Agreement.................. .. . .. .. .. .. . .. . .. . .. . .. . .. .. .. .. . .. . .. . .. . .. . .. ... 8 Investment Transaction Authority.................................... .. .. .. .. .. .. .. .. .. .. . .. . .. .. .. 8 Internal Controls........................................................................................ 8 Investment GommitteeAdvisor... ........... ... ... ......... ... ... ... ... ...... ... ......... ... ... ... ... ... ...... .... 9 Investment Reporting................................................................................. 10 Recordkeeping and Performance Measurement.............................................. 10 Pension Investments................................................................................. 11 Bond Funds............................................................................................. 11 123 I. Background The Florida Legislature passed CS/SB 2090 (CS/HB 1795) on May 4, 1995. Among other provisions of this legislation each local government entities required to create, adopt and maintain comprehensive investment policies, incorporating fourteen required elements. The City has operated under investment guidelines adopted by Resolution 95-21726 on September 27 1995. Due to the amendment of City Code Section 18A-1, these policies have been amended accordingly. II. General Overview The City of Miami Beach has established policies relating to the investment of excess funds. Excess funds are defined as funds not required to meet short term expenditures of the City. Excess funds are placed in two general categories of investments. The first category is "cash management investments". Cash management investments are defined as investments whose terms are less than five~ years. Those funds placed in cash management investments include all daily operating fundsoapital projects fw:IEI&, debt service funds and various deposits. The second category is "long termfl city investments". Long term city investments are investments whose terms are five...af more than one years. The policy governing long term city investments is set forth below after the description of cash management investment policy. Ill. Cash Management Investment Policy Short term expenditures are defined as all daily operating expenditures excluding payroll and debt service which are invested based on their payment cycle. For short term expenditures, the City maintains an overnight ft.~nds sweep a continuous investment program. a Municipal NOW account. collateralized by P:full P:faith and credit instruments of the U.S. Government and its Agencies . held by the State of Florida, with the City designated as collateral beneficiary. The City complies with the State of Florida "Public Deposits Law" Chapter 280 Florida Statutes. Chapter 280 insures the City against investment principal loss on certificates of deposits and demand deposits in excess of $.:1-0250,000 per institution. FDIC insurance covers demand deposits up to $.:1-0250,000 per institution. The City will utilize only financial institutions qualified under Chapter 280, a listing of which is received by the City and reviewed on a quarterly basis. The City also complies with Chapter 280 by filing all required reports annually with the State. This investment policy shall be reviewed no longer than five (5) years from the last review date or at the time of any significant accounting pronouncement or change in the City's market treasury services. 124 A. Investment Objectives The City of Miami Beach's investment objectives are set forth below in order of importance: 1. Safety of capital 2. Return en Liquidity of capital 3. Liquidity ofReturn on capital Investment returns are important and can make a significant contribution to the City's operations and capital projects. Therefore, every effort is made to select the most advantageous investment vehicle and term of investment to maximize earnings. However, safety and liquidity, in that order, take precedence over the return. In this regard, the City has delineated, through ordinance, certain permissible types of investments, with a view to meeting the criteria se-t_out above. B. Investment Ethics The City of Miami Beach selects all investments by means of a bidding process. In no case does the City invest funds or place idle funds in financial institutions as compensating or courtesy balances. The standard of prudence to be applied by the investment officer shall be 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 derived." The "prudent person" rule shall be applied in the context of managing the overall portfolio. The investment officer and staff, acting in accordance with the written procedures and exercising due diligence, shall not be held personally responsible for a specific security's credit risk or market price changes, provided that these deviations are reported immediately and that appropriate action is taken to control adverse developments. C. Investment Process The formal bidding process for investment instruments consists of the following procedures (Steps #1 through #4 are performed by Investment Advisor): 1. M.M.aintain a bid list of approximately five major financial institutions qualified under Chapter 280 and two major brokerage firms. This bid list is adjusted periodically to 125 delete bidders who are non-responsive or non-competitive over a period of time, replacing such institution(s) with other qualified institutions which have expressed an interest to bid on City funds. Qualified institutions are defined as financial institutions governed by Chapter 280 of the Florida Statutes with a branch location in Miami-Dade County, Florida. Brokerage houses must maintain an office in Miami-Dade County, Florida and are selected based on the amount of equity in the firm, number of years the firm has been in operation and reputation. 2. Place telephone calls requesting a bid from each institution on the bid list either on the day of the transaction or the afternoon immediately preceding the transaction date. 3. Receive and note all bids on a standard form designated for this purpose and retain on file for each transaction. 4. Select the highest winning bid 5. Transfer funds in exchange for evidentiary receipt from winning bidder. The purpose of this process is to ~ prevent influence being experienced by either City personnel or the financial institution in the selection of the institution chosen for the purchase of City investments. D. Authorized Investments The City has established a list of authorized types of investments. The authorized cash management investments are descried in Chapter 18A of the City Code and are further limited as follows: 1. Time Deposits Duration N/A Maximum % of Portfolio 100% Maximum per Issuer 25% Ma*iffl~Ffl % ef GeffleiAee .~sset GFG~JE! ~GG% 2. Certificates of Deposit Duration 1-3 yrs 126 3. Maximum % of Portfolio Maximum per Issuer Maximum % of combined Asset Group U. S. Treasury Bills Duration 100% 25% 100% N/A Maximum % of Portfolio 100% Maximum % of Combined Asset Group 100% 4. U. S. Treasury Notes Duration Maximum % of Portfolio Maximum % of Combined .A.sset Group 0-7 yrs 100% 100% 5. U.S. Government Agency and Instrumentality Securities Duration 0-7 yrs Maximum % of Portfolio 50% Combined Asset Group 50% Maximum per Issuer 40% Maximum% of 6. Rated or unrated bonds. notes. or instruments backed by the full faith and credit of the government of Israel. Duration 0-7 yrs ~M~a~x~im~u~m~~~o~o~f~P~o~rt~fo~li~o~ _____________ 5% ~M~a~x~im~u~m~p~e~r~ls~s~u~e~r _________________ 5% eZ. Obligations issued by any state or territory of the United States, which are fully insured or rated in one of the two highest rating categories by both Moody's Investors Service, Inc. and Standard and Poor's Corporation or their successors. 7§. Duration 7-10 yrs Maximum % of Portfolio Maximum per Issuer Maximum % of Combined /\sset Group Fixed Term Repurchase Agreements Duration Maximum % of Portfolio Maximum per Issuer Maximum % of Combined /',sset Group Overnight Repurchase Agreements 50% 10% 50% 0-3 yrs 20% 25% 100% 127 Duration N/A Maximum % of Portfolio 100% Maximum Qer Issuer 25% Maximum % of Combined Asset Group N/A 109. Bankers Acceptances Duration N/A Maximum % of Portfolio 20% Maximum Qer Issuer 20% Maximum % of Combined Asset Group 30% 110. Commercial Paper with a rating of A-1 or P-1 only, rated by Moody's or Standard & Poor's Duration N/A Maximum % of Portfolio 20% Maximum Qer Issuer 1 0% Maximum % of Combined Asset Group 30% 1 ~.:t. Corporate notes, corporate bonds, medium term notes, Yankee notes, and Yanke9" oowith temms of one year or less rated by 2 of 3 designated rating agencies in one of the l'.vo highest rating categoriesas follows: Maturity Maximum % of Portfolio.:t Maximum per Issuer 0-21%_m 20% 5% Maximum % of Combined Asset Group~ a. Moody's AA3 higher b. Standard & Poor's AA-or higher c. Fitch AA-or higher 12~. Corporate notes, corporate bonds, medium team-term notes, Yankee notes, and Yankee OOfiEI& with terms Gf-in excess of one year with a maximum of 5.0 years rated by 2 of 3 designated rating agencies as follows: in one of the two highest rating categories. Duration d-7 ..1:§ yrs Maximum% of Portfolio 20% Maximum Qer Issuer 5% Maximum % of combined Asset Group 30% a. Moody's AA3 higher b. Standard & Poor's AA-or higher c Fitch AA-or higher 128 Formatt_t!~' .. !ndent: Hanging: 0.5'' . [---·-·----, Formatted: Indent: Hanging: 0.5'' I 1 ~-Money market mutual/trust funds which substantially conform with this policy as follows: • Duration N/A Maximum % of Portfolio Maximum per Issuer 100% 50% Maximum % of combined /\sset Group 100% a. State of Florida Local Government Surplus Funds Trust Fund b. Mutual/trust funds sponsored by the Florida League of Cities c. Private money market mutual funds backed entirely by "Full Faith and Credit" U.S. Government Securities not to exceed 25% d. Intergovernmental investment pools rated "AAAm" authorized pursuant to Florida State Statutes. 163.01, F.S. 14§. Fixed income mutual funds sponsored by the Florida League of Cities which substantially conform with this policy as follows: Duration N/A Maximum % of Portfolio 25% Maximum per Issuer 25% Maximum % of combined Asset Group 25% 1a§. Mortgage-backed securities collateralized by first mortgages (or deeds of trust) and• asset-backed securities collateralized by consumer or business receivables with a maximum duration of 3.0 years at time of purchase and structured as either collateralized mortgage obligations or unstructured pass-through securities and rated by 2 of 3 designated rating agencies as follows: Group 50% Maturity Maximum % of Portfolio Maximum per Issuer a. b. c. Moody's Standard & Poor's Fitch 3-5 yrs 15% 20%Maximum % of combined 1\sset AAA3 higher AA-or higher AA-or higher 1eZ. Externally managed funds requiring specific approval by Commission with investment§. • limited to City policy and rating criteria" 129 [Fc;;;----------, Formatted: Indent: Hanging: 0.5'' ; r----------------------------------------------.---- l Formatted: Indent: Hanging: 0.5" -----·---------~----~----·--· --·'. Duration Maximum % of Portfolio 1~-7 yrs 100:W% 20% Maximum % of combined /\sset Group 17~. Interest rate Swap agreements between the City and a counter party to pay/receive a- fixed interest rate payment in exchange for a variable rate payment over a specified term with the requirement that all "Swap" agreements be approved by City Commission prior to execution. Duration N/A Maximum % of Portfolio 10% Maximum % of combined 1\sset Group 20% All repurchase agreements are fully collateralized and the collateral is held in the City's name by a third party custodian. Repurchase agreements must be collateralized at minimum mark-to- market value of 102% in U.S. Government securities. Derivatives (defined as a financial instrument the value of which depends on, or is derived from the value of one or more underlying assets or index of asset values) shall be utilized only if specifically authorized as part of the investment plan and the Finance DirectorChief Financial Officer or his designee has sufficient understanding/expertise to invest in derivatives. All proposed derivative investments (including "SWAPS") will be analyzed by the City's Financial Advisor and will be presented to the Finance and Citywide Projects Committee and the City commission for approval. Repurchase Agreements (an agreement between an investor and a security dealer whereby dealer agrees to buy back the security at a specified price in the future) will be limited to transactions in which the proceeds will be used to provide liquidity. Any investment which is not issued in "Book Entry Only" form is physically held by the City in a secure vaulted area and surrendered only when invested funds and earnings are received by the City at maturity. E. Prohibited Investments Funds to be invested in cash management investments may not be invested in the following: Common Stock Private Placements Preferred Stock Convertible Bonds Venture Capital Options and Futures Warrants Unregistered or Restricted Stock Margin Trading Limited Partnerships Oil and Gas Wells 10 or PO strips or inverse floater mortgage backed securities 130 Foreign Exchange Commodities Short Selling Real Estate Any Inverse Floating Rate Securities _in a~diti()n t() thE! a!)ove prohibited investments, funds should not be invested in any scrutinized· companies with active business operations in Sudan or Iran as listed by the State Board of Administration (SBA) on a quarterly basis, which is outlined in the Protecting Florida's Investment Act (F.S. 215.442 and 215.473). F. Maturity and Liquidity Requirements The City selects investments whose terms compliment the need to make the majority expenditures set forth below. 1. Biweekly Payrolls 2. Periodic Debt Service Payments 3. Capital Project Needs For each expenditure event, investments are selected whose maturities occur at a date close to the date that funds will be needed. Investments also are selected based on the highest yield for the particular type of investment. In the case of capital projects, in which the exact date that expenditures will need to be made is unknown, the City selects several investments with varying maturities so that monies are available each month to cover all capital expenditures. Any unused capital investment funds are then placed in investments of one year or more to maximize return potential. /\s mentioned earlier, the City maintains an overnight investment program of approximately $9,000,000, which provides ft:Jnds needed to cover daily operating expenses, exclt:Jding items #'s 1 a aeove. Interest yields on these investments are competitive thot:Jgh somewhat lower than longer term instrt:Jments. G. Portfolio Composition Diversity of investment types is highly desirable. To promote diversity, no security or individual cusip shall exceed 5% of the City funds. Such diversity is necessary in cases where securities are traded frequently and not held to maturity and where volatile securities are traded. H. Custodial Account 131 All City investments, except for swap agreements, must be held in an independent custodial account within the trust department of a major financial institution with a branch located in Miami-Dade County, Florida. The custodian will not be utilized to buy or sell investments for the City. All City investments must be registered in the City's name in book entry form evidenced by transaction tickets maintained by the custodian with a copy provided to the City. Physical possession of securities by the City should be avoided. The investment held by the custodian must be reconciled monthly to the City's general ledger. The City will carry investments at cost but will maintain a record of portfolio market value each month. However, investments are recorded at fair value in the annual financial statements in accordance with GASB Statement #31. I. Treasury Management Services Master Repurchase Agreement A "Treasury Management Services Master RepurohasAgreemenf' has been developed, reviewed and accepted by the City and is part of the contract established with the City's main depository bank. This agreement is a standard Public Securities Association ("PSA") form agreement offering all recommended protection to the City. This agreement is scheduled to be in effect for the duration of the contract with the City's main depository. J. Investment Transaction Authority The Finance OireoterChief Financial Officer has designated the Treasury Manager as the individual responsible for managing the City's investments. The Treasury Manager discusses investments with upcoming maturities with the Assistant Finance Director and the Fffian.Ge GireotefChief Financial Officer if! there is a question as to new maturity target dates or type of investment vehicle to be used. Based on these discussions, the Treasury Manager executes the transaction and completes an "Investment Transaction Report" for each investment transaction. Funds related to each investment are transferred according to authorized funds transfer procedures and limits established under the provisions of the City's contract with its main depository bank. K. Internal Controls The City has established a number of internal controls to prevent loss of funds by fraud, employee error, misrepresentation by third parties, or imprudent actions by employees of the City. The internal controls are as follows: 132 1. Investment transactions authority is limited to specific persons within the Finance Department. 2. Wire transfer of funds authority is restricted to specific individuals with specific dollar limits within the Finance Department. All non-repeat type wire transfers require confirmation authorization by a second individual specified in wire authority documents executed with the City's main depository. 3. All investment transactions require the approval of the Treasury Manager in consultation with the Assistant Finance Director or Chief Financial Officer. 4. A monthly report is prepared by the Assistant finanse Direstarlnvestment Advisor and distributed to the finanse DirestarTreasury Manager early in the subsequent month for review. In addition a Financial Analyst in the Finance Department receives a copy of this report and reconciles these investments with the City's general ledger on a monthly basis. 5. An Jl.ssaunt Clerk IIA Financial Analyst Ill in the Finance Department reconciles the City's general depository account on a monthly basis by comparing the City's general ledger with the applicable bank account statements. The reconciliation of the general depository account would reveal any difference in investment transaction recording and the actual movement of funds. 6. Each month, the Assistant finanse DirestarFinancial Analyst Ill and the Treasury Manager reconciles investments reflected in the custodial statements with the City's records. 7. Each year both internal auditors and the City's external auditors review existing internal controls as well as investment transactions by examining data on a random basis. L. Investment CommitteeAdvisor The City engages the services of an investment advisor with regard to the management of its investment program. Investment Advisors shall be registered with the Securities Exchange Commission under the Investment Advisors Act of 1940. Advisors shall be selected usmg the City's authorized purchasing procedures for selection of professional services and shall be 133 subject to the provisions of this Investment Pol1cy. Under no circumstances shall the advisor take custody of any City funds or securities. /\n investment committee will be established to exercise oversight responsibility concerning types of investments and maturity of investments. The Committee •Nill consist of the follov:ing individuals: ---F-inance Directof-Or his/her designee Chairman of the Capital Improvements/Finance Committee City Manager-ef-h.is/her Designee City's Financial /\dvisor Five members of the local banking/investment community The committee will meet at least quarterly to discuss investment objectives, terms and choice of investment alternatives ror the ~:~pcoming quarter. The Committee will assist in establishing tirnelines for expenditure of capital project funds and for investment of any extraordinary rece$1 ~eview portfolio perrormance for the previsions quarter and composition of the investment~ M. Investment Reporting As discussed previously, the Finance Department maintains several types of information and reports on investments. The records relating to investments are as follows: 1. Investment Transaction Report - A recording/approval form for each investment transaction, regarding both active and matured investments. This form also indicates all bids obtained where applicable. 2. Investment bid sheet, where applicable, for each investment. 3. Investment be§-Monthly Statement-a document listing, in chronological maturity order, pertinent information on each investment. 4. Investments by Banks/F1:1nas report generatea monthly ana reconciled 'l':ith tho City's general leelgerlnvestment monthly statement is reconciled with the City's general lodger. 5. Annual summary of average investment returns (which are included in the monthly Investments Statements) which is subjected to external audit for reasonableness of average stated yield for the fiscal year. 134 N. Recordkeeping and Performance Measurement Comprehensive records of each investment transaction are maintained in the Finance Department. These records include bid sheets where applicable, investment transaction reports, investment bank advices, the aAfl!lal-monthly investment ~statements, and a quarterly compilation of total returns for the preceding fiscal quarter by City fund type (e.g., General Fund, Capital Projects, Enterprise, Internal Service). Annually, the City's external auditors review the calculation of investment yields prepared by the Finance Department for comparison to indices and comparative data maintained by the external auditors. They then determine the reasonableness of the average yield calculated by the Finance Department. If no problem is indicated, the Finance Department then compares its average annual yield to yields of surrounding local governments when such information becomes available. While yield is not the primary concern of the City's investment manager, it should be noted that the City has consistently enjoyed an average yield competitive with other major local governmental entities while assuming lower risk. 0. Pension Investments The City does not manage the cash or investments of the City's fGI,ff-two pension systems. Each pension system has elected or appointed members to its pension Board of Trustees who exercise oversight over money managers engaged to manage pension fund investments in accordance with policies and guidelines established by each pension system. The Boards, therefore, have oversight authority over investments for pension systems and the City does not actively participate in this process. P. Bond Funds Notwithstanding anything to the contrary contained in City Code Chapter 18A or these investment guidelines the provisions pertaining to investment of monies under all ordinances, resolutions, trust indentures and agreements adopted or entered into by the City in connection with bonds issued by the City or other dept incurred by the City will control and supersede the provisions herein contained with respect to the investment of such monies. 135 THIS PAGE INTENTIONALLY LEFT BLANK 136