HomeMy WebLinkAbout06-1219 01-24-2006RESOLUTION NO. 06 -1219
A RESOLUTION AMENDING THE INVESTMENT POLICY
FOR FUNDS FOR THE CITY OF EULESS AND
PROVIDING AN EFFECTIVE DATE.
WHEREAS, the City Council desires to amend the Investment Policy to provide
for revisions proposed by the Investment Committee.
NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF EULESS,
TEXAS:
SECTION 1
THAT the City Council has reviewed the attached Investment Policy for the City
of Euless, and the policies and strategies contained therein, and hereby adopts the
attached Investment Policy as the City's Investment Policy, which attached Investment
Policy is incorporated in this resolution and made part of the same as if written word for
word herein.
SECTION 2
THAT all ordinances, or parts of ordinances in force with provisions of this
resolution became effective which are inconsistent or in conflict with the terms or
provisions contained in this resolution are hereby repealed to the extent of any such
conflict only. The non - conflicting sections, sentences, paragraphs, and phrases shall
remain in full force and effect.
SECTION 3
THAT this resolution shall become effective immediately upon its passage and
approval.
APPROVED AND ADOPTED at a regular meeting of the Euless City Council on
the 24th day of January, 2006, by a vote of 6 ayes, 0 nays, and o
abstentions.
APPROVED:
77-ra'l /&°w
ATTEST:
MC, City Secretary
DATE: June 26, 1990
REV: January 24, 2006
RE: Investment Policy
CITY OF EULESS
FISCAL POLICY
PREPARED BY:Finance Department
REVIEWED BY:City Manager
APPROVED BY:City Council
I. SCOPE
This investment policy applies to the investment activities of the Government of the
City of Euless, Texas. This policy serves to satisfy the statutory requirements of
defining and adopting a formal investment policy. The policy and strategy shall be
reviewed annually by the Investment Committee and any modifications must be approved
by the Investment Committee and forwarded to City Council for final approval. The
City Council must adopt a written instrument by rule, order, ordinance, or
resolution stating that it has reviewed the investment policy and investment
strategies. Any changes made to either the policy or strategies will be recorded in
this written instrument. This Investment Policy, as approved, is in compliance with
Chapter 2256 of the Government Code, also known as "The Public Funds Investment
Act ".
FUNDS INCLUDED All financial assets of all funds, including the General Fund and
any other accounts of the City not specifically excluded in these policy guidelines
are included. These funds, as well as funds that may be created from time -to -time,
shall be administered in accordance with the provisions of these policies. All
funds will be pooled for investment purposes. The strategy developed for this
pooled fund group will address the varying needs, goals, and objectives of each
fund.
FUNDS EXCLUDED None.
II. OBJECTIVES AND STRATEGY
COMPLIANCE The City must adopt rules and designate staff to manage local funds and
submit related reports per Chapter 2256 of the Texas Government Code. All
investments made on behalf of the City must comply with the "Public Funds Investment
Act" and all federal, state, and local statutes, rules, or regulations. In
conjunction with the comprehensive annual financial audit and report, the City will
perform, or have performed, a compliance audit of management controls on investments
and adherence to the City's approved investment policy.
SAFETY The primary objective of the City's investment activity is the preservation
of capital in the overall portfolio.
LIQUIDITY The City's investment portfolio will remain sufficiently liquid to enable
the City to meet operating requirements that might be reasonably anticipated.
Liquidity shall be achieved by matching investment maturities with forecasted cash
flow requirements and by investing in securities with active secondary markets.
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YIELD The City's cash management portfolio shall be designed with the objective of
regularly exceeding the average rate of return on three -month U.S. Treasury Bills,
or the average Federal Reserve Discount whichever is higher. The investment program
shall seek to augment returns above this threshold consistent with risk limitations
identified herein and prudent investment principles.
Funds held for future capital projects shall be invested in securities that
reasonably can be expected to produce enough income to offset inflationary
construction cost increases.
RISK OF LOSS All participants in the investment process shall seek to act
responsibly as custodians of the public trust. Investment officials shall avoid any
transaction that might impair public confidence in the City's ability to govern
effectively.
STRATEGY The strategy for all pooled funds is to assure that cash flows are matched
with projected needs and assume adequate liquidity and safety. This may be
accomplished by purchasing high quality securities in a laddered structure or
utilizing an investment pool. Furthermore the following purposes are also
considered when investing:
-Funds for Capital Improvement Projects or special purposes should allow for
flexibility and unanticipated project outlays by having a portion of their
investments in highly liquid securities. The stated final maturity dates of
securities held should not exceed the estimated project completion date. A
weighted average maturity of 365 days or less will be maintained and
calculated by using the stated final maturity of each security.
-Funds for Debt Service should assure liquidity adequate to cover the debt
service obligation on the required payment date. Surplus funds outside the
debt service dates will remain within the investment and fiscal policies.
-Debt Service Reserves, Operating Reserves, Emergency and Contingecy funds
will have the ability to generate a dependable revenue stream to the
appropriate fund from securities with a low degree of volatility. Such
securities will tend to hold their value during economic cycles. The stated
final maturity dates of securities held should not exceed five years.
- Operating funds will be structured in such a way as to minimize volatility
during economic cycles. This may be accomplished by purchasing high quality
short -term securities which will compliment each other in a laddered maturity
schedule. The weighted average maturity on these funds will remain within the
6 to 9 month range and calculated by using the stated final maturity date of
each security.
III. INVESTMENT COMMITTEE
MEMBERS There is hereby created an Investment Committee, consisting of the City
Manager or his designee, the Deputy City Manager, the Assistant City Manager, the
Finance Administrator and the Mayor or Mayor's designee. The Finance Administrator
shall schedule a meeting of the Investment Committee at least quarterly to determine
general strategies and to monitor results and shall call a special meeting of the
Investment Committee within 24 hours of notification of any significant events
related to the City's portfolio including a downgrade in the investment rating. All
prudent measures will be taken to liquidate an investment whose rating has been
downgraded to less than the required minimum rating. The Investment Committee shall
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be authorized to invite advisors to the meetings as needed including, but not
limited to, the City Attorney, the City Council, or outside advisors.
SCOPE The Investment Committee shall include in its deliberations such topics as:
performance reports, economic outlook, portfolio diversification, maturity
structure, potential risk to the City's funds, authorized brokers and dealers, and
the target rate of return on the investment portfolio.
PROCEDURES The Investment Committee shall provide for minutes of its meetings. Any
two members of the Investment Committee may request a special meeting, and three
members shall constitute a quorum. The Investment Committee shall establish its own
rules of procedures.
IV. RESPONSIBILITY AND CONTROL
DELEGATION Management responsibility for the Investment Program is hereby delegated
to the "Investment Officers ", who shall establish written procedures for the
operation of the Investment Program, consistent with this Investment Policy. Such
procedures shall include explicit delegation of authority to persons responsible for
investment transactions.
SUBORDINATES The Assistant City Manager and the Finance Administrator are hereby
designated as "Investment Officers ", responsible for the investment of the city's
funds, pursuant to the Public Funds Investment Act Section 2256.005 Subsection F.
No person shall engage in an investment transaction except as provided under the
terms of this policy and the procedures established by the "Investment Officers ".
Authority granted to a person to invest the funds on behalf of the City shall remain
in effect until rescinded by the City or until the person resigns from or is
terminated by the City. The "Investment Officers" shall be responsible for all
transactions undertaken and shall establish a system of controls to regulate the
activities of subordinate investment officials. The investment officers, and the
persons authorized to execute investment transactions shall receive at least 10
hours of investment training relating to their investment responsibilities, as
described by the Public Funds Investment Act, at least once every 2 years. This
training must be provided by an independent source which has been approved by the
investment committee. At least one training session must be completed by the
investment officer within twelve months of assuming their duties. The training must
include, but is not limited to, education in investment controls, security risks,
strategy risks, market risks, diversification, and compliance with the Public Funds
Investment Act.
QUARTERLY REPORTS The Finance Administrator shall submit quarterly an investment
report that summarizes recent market conditions, economic developments and
anticipated investment conditions to management and City Council. The report shall
summarize the investment strategies employed in the most recent quarter, describe
the portfolio in terms of investment securities, maturities, risk characteristics
and other features. The report shall be in compliance with the Public Funds
Investment Act and shall contain a summary statement, prepared in compliance with
generally accepted accounting principles, of each pooled fund group that states the
beginning market value for the reporting period, additions and changes to the market
value during the period, and the ending market value for the period and the fully
accrued interest for the reporting period. It shall also state the book value,
market value and maturity date for each separately invested asset at the beginning
and end of the reporting period by type of asset and fund type invested. The
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reports must state the compliance of the City's investment portfolio as it relates
to the City's investment strategies and the "Public Funds Investment Act ". The
report shall explain the quarter's total investment return and compare the return
with budgetary expectations. The report shall include an appendix that discloses
all transactions during the past quarter. All reports will be prepared jointly by
all investment officers and signed by each. The reports prepared by the investment
officers shall be formally reviewed, at least annually, by an independent auditor,
and the results of this review will be reported to the City Council by that Auditor.
ANNUAL REPORTS Within 120 days of the end of the fiscal year, the Assistant City
Manager shall present a comprehensive annual report on the Investment Program and
investment activity. The annual report shall include twelve -month and quarterly
comparison returns, and shall suggest improvements that might be made in the
investment program.
MONITORING OF MARKET PRICE OF INVESTMENTS The investment officer shall determine
the market value of each investment at least quarterly and at a time as close as
practicable to the closing of the reporting period for investments. Such values
shall be included on the investment reports. The following methods shall be used:
A. Certificates of deposits shall be valued at their face value plus any accrued
but unpaid interest.
B. Shares in money market mutual funds and investment pools shall be valued at
par plus any accrued but unpaid interest.
C. Other investment securities may be valued in any of the following ways:
1. the lower of two bids obtained from securities broker /dealers for
such security;
2. the average of the bid and asked prices for such investment security
as published in the Wall Street Journal;
3. the bid price published by any nationally recognized security pricing
service.
PRUDENCE Investments shall be made with the exercise of due 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 own capital as well as
the probable income to be derived. Standard of prudence shall be "prudent person"
and shall be applied in the context of managing an overall portfolio. Investment
officers acting in accordance with written procedures and the investment policy and
exercising due diligence shall be relieved of personal responsibility for an
individual 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.
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.
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DISCLOSURE Employees and Investment Officials shall disclose to the City Manager,
City Council, and the Texas Ethics Commission any personal business relationship
with a business organization offering to engage in an investment transaction with
the City of Euless, and shall further disclose any large personal financial or
investment positions that could be related to the performance of the City's
portfolio. Investment officers who are related within the second degree by affinity
or consanguinity to an individual seeking to sell an investment to the City shall
also disclose such relationship. Employees and investment officers shall
subordinate their personal investment transactions to those of this jurisdiction,
particularly with regard to the timing of purchases and sales. For the purpose of
this section, an investment officer has personal business relationship with a
business organization if:
A. The investment officer owns 10 percent or more of the voting stock or shares
of the business organization or owns $5,000 or more of the fair market value
of the business organization;
B. Funds received by the investment officer from the business organization exceed
10 percent of the investment officer's gross income for the previous year; or
C. The investment officer has acquired from the business organization during the
previous year investments with a book value of $2,500 or more for the
personal account of the investment officer.
V. AUTHORIZED AND SUITABLE INVESTMENT SECURITIES
ACTIVE PORTFOLIO MANAGEMENT The City intends to pursue an active versus a passive
portfolio management philosophy. That is, securities may be sold before they mature
if market conditions present an opportunity for the City to benefit from the trade.
ELIGIBLE INVESTMENTS (permitted by Chapter 2256) Assets of funds of the government
of the City of Euless may be invested in:
A. Obligation of the United States or its agencies and instrumentalities (except
for mortgage pass- through securities);
B. Fully insured or collateralized* certificates of deposits issued by a
depository institution that has its main office or branch office in Texas
which is guaranteed or insured by the Federal Deposit Insurance Corporation or
its successor or the National Credit Union Share Insurance Fund or its
successor, and secured by obligations that are described in the Tex. Gov't.
Code Sec. 2256.009(a) that has a market vaue of not less that the principal
amount of the certificates but excluding those mortgage backed securities as
described by Tex. Gov't Code Sec. 2256.009(b);
C. Fully collateralized* repurchase agreements having a defined termination date.
(Repurchase agreement" means a simultaneous agreement to buy, hold for a
specified time, and sell back at a future date obligations described by
Section V. A. of this Policy, at a market value at the time the funds are
disbursed of not less than the principal amount of the funds disbursed. The
term refers to direct security repurchase agreement and a reverse security
repurchase agreement.) These investments must be in accordance with a master
repurchase agreement approved by the Investment Committee; *(see definition of
collateral, Section VII).
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D. Investment Pools with a weighted average maturity of 90 days or less. The
pool must enter into a contract approved (by resolution) by the City Council
to provide services to the city. The pool must be continuously rated no lower
than AAA or AAA -m or at an equivalent rating by at least one nationally
recognized rating service. A public funds investment pool created to function
as a money market mutual fund must mark its portfolio to market daily and, to
the extent reasonably possible, stabilize at a $1 net asset value. The pool
must provide to the investment officer or authorized representative of the
entity an offering circular or other similar disclosure instrument that
contains, at a minimum, the following information:
1. the types and percentage breakdown of securities in which the pool is
invested;
2. the maximum average dollar- weighted maturity allowed, based on the
stated maturity date, of the pool;
3. the maximum stated maturity date any investment security within the
portfolio has;
4. the objectives of the pool;
5. the size of the pool;
6. the names of the members of the advisory board of the pool and the
dates their terms expire;
7. the custodian bank that will safekeep the pool's assets;
8. whether the intent of the pool is to maintain a net asset value of
one dollar and the risk of market price fluctuation;
9. whether the only source of payment is the assets of the pool at
market value or whether there is a secondary source of payment, such
as insurance or guarantees, and a description of the secodary source
of payment;
10. the name and address of the independent auditor of the pool;
11. the requirements to be satisfied for an entity to deposit funds in
and withdraw funds from the pool and any deadlines or other operating
policies required for the entity to invest funds in and withdraw
funds from the pool; and
12 the performance history of the pool, including yield, average dollar
weighted maturities, and expense ratios.
To maintain eligibility to receive funds from and invest funds on behalf of an
entity under this chapter, an investment pool must furnish to the investment
officer or other authorized representative of the entity:
1. investment transaction confirmations; and
2. a monthly report that contains, at a minimum, the following
information:
a. the types and percentage breakdown of securities in which the
pool is invested;
b. the current average dollar- weighted maturity, based on the
stated maturity date, of the pool;
c. the current percentage of the pool's portfolio in investments
that have stated maturites of more than one year;
d. the book value versus the market value of the pool's portfolio,
using amortized cost valuation;
e. the size of the pool;
f. the number of participants in the pool;
g. the custodian bank that is safekeeping the assets of the pool;
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h. a listing of daily transaction activity of the entity
participating in the pool
i. the yield and expense ratio of the pool;
j. the portfolio managers of the pool; and
k. any changes or addenda to the offering circular.
E. No load money market mutual fund, registered with and regulated by the
Securities Exchange Commission, which has a dollar weighted average portfolio
maturity of 90 days or less whose assets consist exclusively of the assets
described in section A -C and whose investment objectives includes the
maintenance of a stable net asset value of $1 for each share. Each fund must
provide the City with a prospectus and other information required by the
Securites Exchange Act of 1934 or the Investment Advisor Act of 1940.
F. Other such securities or obligations as approved by City Council upon
recommendation of the Investment Committee. No securities will be purchased
which have a potential for price volatility that is inappropriate for the City
and incompatible with its investment strategies. This includes, but is not
limited to, certain collateralized* mortgage obligations, such as principal
and interest only securities, inverse floaters, capped and mismatched
floaters, and structures notes and range notes.
LENGTH OF INVESTMENTS Except for monies of Reserve funds, Emergency funds,
Contingency funds and construction funds, the City of Euless shall invest in
instruments whose maturities do not exceed two (2) years at the time of purchase.
For the General Fund, Water & Sewer Utility Fund, and any other operating funds, the
weighted average maturity of each fund's portfolio will remain within the 6 to 9
month range.
Assets held from bond proceeds may be invested in maturities with a final stated
maturity greater than (2) years based on estimated project completion dates. Assets
held in the General Obligation Interest & Sinking Fund may be invested in maturities
which provide liquidity adequate to cover the debt service payment dates. Assets
held in the General Emergency, General Contigency, Water & Sewer Emergency, and the
Short -term Motor Vehicle Reserve Funds may be invested in maturities not exceeding
five (5) years.
An average remaining maturity of 365 days or less shall be maintained on bond
proceeds subject to arbitrage rebate restrictions, and the total portfolio average
remaining shall not exceed one year.
DIVERSIFICATION It is the policy of the City of Euless to diversify its investment
portfolios. Assets held in the common investment portfolio shall be diversified to
eliminate the risk of loss resulting from one concentration of assets in a specific
maturity, a specific issuer or a specific class of securities. Diversification
strategies shall be determined and revised periodically by the Investment Committee.
In establishing specific diversification strategies, the following general policies
and constraints shall apply:
A. Portfolio maturities shall be staggered in a way that protects interest
income from the volatility of interest rates that avoids undue
concentration of assets in a specific maturity sector. Securities shall
be selected which provide for stability of income and reasonable
liquidity.
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B. The Investment Committee shall establish strategies and guidelines for the
percentage of the total portfolio that may be invested in securities other
than repurchase agreements, treasury bills, or insured and collateralized*
certificates of deposit. The Investment Committee shall conduct a
quarterly review of these guidelines, and shall evaluate the probability
of market and default risk in various investment sectors as part of its
considerations. *(see definition of collateral, Section vii)
C. The investment officer will obtain at least three competitive bids from
approved brokers on our broker /dealer list before making an investment
transaction. In the event of a tie, the choice will be made by a
cumulative and objective manner.
ARBITRAGE Although steps have been taken to distribute bond issuance annually in
amounts not to exceed $5 million dollar increments, if this process does not occur,
the City of Euless will fall under arbitrage regulations.
The Tax Reform Act of 1986 provided limitations restricting the City's investing of
tax - exempt General Obligation Bond proceeds and debt service income. New arbitrage
rebate provisions require that the City compute earnings on investment from each
issue of bonds on an annual basis to determine if a rebate is required. To
determine the City's arbitrage position, the City is required to perform specific
calculations relative to the actual yield earned on the investment of the funds and
the yield that could have been earned if the funds had been invested at a rate equal
to the yield on the bonds sold by the City. The rebate provision states that
periodically (not less than once every five years, and not later than sixty days
after maturity of the bonds), the City is required to pay the U.S. Treasury a
rebate of excess earnings based on the City being in a positive arbitrage position.
The Tax Reform restrictions require extreme precision in the monitoring and
recording facets of investments as a whole, and particularly as relates to yields
and computations so as to insure compliance. Failure to comply can dictate that the
bonds become taxable, retroactively from the date of issuance.
The City's investment position relative to the new arbitrage restrictions is the
continued pursuit of maximizing yield on applicable investments while insuring the
safety of capital and liquidity. It is a fiscally sound position to continue
maximization of yield and rebate excess earnings, if necessary.
VI. SELECTION OF BANKS AND DEALERS
BIDDING PROCESS Periodically, a Depository shall be selected through the City's
banking services procurement process, which shall include a formal request for
proposal (RFP) issued in even years. In selecting depositories, the credit
worthiness of institutions shall be considered, and the Finance Administrator shall
conduct a comprehensive review of prospective depositories credit characteristics
and financial history.
INSURABILITY Banks and Savings & Loan Associations seeking to establish eligibility
for the City's competitive investment program, shall submit financial statements,
evidence of federal insurance and other information as required by the Assistant
City Manager.
PRIMARY DEALERS & APPROVED LISTS For brokers and dealers of government securities,
the Investment Committee shall select only those dealers reporting to the Market
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Reports Division of the Federal Reserve Bank of New York, also known as the "primary
government securities dealers," unless a comprehensive credit and capitalization
analysis reveals that other firms are adequately financed to conduct public
business. All brokers and dealers must be authorized by the Investment Committee,
as analyzed by a Broker Questionnaire. Investment Officers shall not conduct
business with any firm with whom public entities have sustained losses on
investments or whose name has been removed from an approved list by the Investment
Committee. At least annually, the investment committee will review, revise and
adopt a list of qualified brokers that are authorized to engage in investment
transactions with the City.
COMPLIANCE A written copy of the investment policy will be presented to any
investment pool or business organization offering to engage in an investment
transaction with the City. A qualified representative (as described by section
2256.002, subdivision 10 of the Texas Government Code) of such business organization
shall execute a written instrument, in a form acceptable to both the city and the
organization, certifying that they have received and reviewed a written copy of the
City's investment policy. The firm must acknowledge that it has implemented
reasonable internal procedures and controls in an effort to preclude investment
transactions conducted between the City and the organization that are not authorized
by the City's investment policy, except to the extent that this authorization is
dependent on an analysis of the makeup of the City's entire portfolio or requires an
interpretation of subjective investment standards. The investment officer of the
City may not acquire or otherwise obtain any authorized investment described in the
City's investment policy from a person who has not delivered such instrument. This
instrument does not, at any time, relieve the City of the responsibility of
monitoring all investment transactions to determine if they are in compliance with
this policy.
VII. SAFEKEEPING AND CUSTODY
INSURANCE OR COLLATERAL All deposits and investments of City funds other than
direct purchases of U.S. Treasuries or U.S. Agencies shall be secured by pledged
collateral with a market value equal to no less than 105% of the deposits or
investments less any amount insured by the FDIC or FSLIC. Evidence of the pledged
collateral shall be maintained by the Finance Administrator or a third party
financial institution. Repurchase agreements shall be documented by a specific
agreement noting the collateral pledged in each agreement. Collateral shall be
reviewed monthly to assure the market value of the securities pledged equals or
exceeds the related bank balances.
SAFEKEEPING AGREEMENT All safekeeping arrangements shall be in accordance with a
Safekeeping Agreement approved by the Investment Committee which clearly defines the
procedural steps for gaining access to the collateral should the City of Euless
determine that the City's funds are in jeopardy. The safekeeping institution, or
Trustee, shall be the Federal Reserve Bank or an institution not affiliated with the
firm pledging the collateral. The safekeeping agreement shall include the
signatures of the City of Euless, the firm pledging the collateral, and the Trustee.
COLLATERAL DEFINED The City of Euless shall accept only the following securities as
collateral:
A. FDIC and FSLIC insurance coverage.
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B. United States Treasuries & Agencies.
C. Texas State, City, County, School, or Road District bonds with a remaining
maturity of ten (10) years or less with an investment grade bond rating
from Moody's Investors Services (Baa and above) and Standard & Poor's
Corporation (BBB and above).
D. Other securities as approved by the Investment Committee.
SUBJECT TO AUDIT All collateral shall be subject to inspection and audit by the
Assistant City Manger, or designee, as well as, the City's independent auditors.
DELIVERY VS. PAYMENT Treasury Bills, Notes & Bonds and Government Agencies'
Securities, and all other investment transactions, except investment pools and
mutual funds, shall be purchased using the delivery versus payment method. 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 or held on behalf 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.
VIII. MANAGEMENT AND INTERNAL CONTROLS
The Assistant City Manager, or designee, shall establish a system of internal
controls which shall be reviewed by an independent auditor. The controls shall be
designed to prevent losses of public funds arising from fraud, employee error,
misrepresentation by third parties, unanticipated changes in financial markets, or
imprudent actions by employees or Investment Officers of the City.
Controls and managerial emphasis deemed most important that shall be employed where
practical are:
A. Control of collusion
B. Separation of duties
C. Separation of transaction authority from Accounting and Record- keeping
D. Custodian safekeeping receipts records management
E. Avoidance of bearer -form securities
F. Clear delegation of authority
G. Documentation of investment bidding events
H. Written confirmation of telephone transactions
I. Reconcilements and comparisons of security receipts with the investment
subsidiary records
J. Compliance with investment policies
K. Accurate and timely reports
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L. Validation of investment maturity decisions with supporting cash flow
data.
M. Adequate training and development of Investment Officials
N. Verification of all interest income and security purchase and sell
computations
O. Review of financial conditions of all brokers, dealers, and depository
institutions
P. Staying informed about market conditions, changes and trends that require
adjustments in investment strategies