HomeMy WebLinkAboutItem No. 08 - Approve City Investment Policy for FY 2020-21
Consent Calendar
City of San Bernardino
Request for Council Action
Date: June 17, 2020
To: Honorable Mayor and City Council Members
From: Teri Ledoux, City Manager
By:Paul Espinoza, Finance Director
Subject: Approve City Investment Policy for FY 2020/21
Recommendation
Adopt Resolution No. 2020-124 of the Mayor and City Council of the City of San
Bernardino, California, approving the City Investment Policy for FY 2020/21.
Background
State law requires that all municipalities have an investment policy approved by its
governing board and that it reapprove that policy on an annual basis. On November 6,
2019, the Mayor and City Council adopted Resolution No. 2019-317 approving the
current investment policy for FY 2019/20.
Discussion
The Finance Department is responsible for submitting the annual Investment Policy for
Policy Certification designation. This certification recognizes that the City of San
meets the program requirements within 18 different topic areas deemed to be best
practices for investment policies.
The policy for FY 2020/21 continues to focus on the items of paramount importance for
the safety of principal, sufficient liquidity of the investment pool to ensure that cash is
readily available as needed to meet the Cit
market rate of return is obtained after the requirements of safety and liquidity have been
met.
The purpose of the Investment Policy is to establish cash management and investment
guidelines for the investmen
each investment transaction and the entire portfolio, which must comply with Sections
53600 through 53683 of the Government Code and all other applicable laws and
regulations.
The changes to the Investment Policy proposed for Fiscal Year 2020/21 involve clean-
up language for clarification purposes only. There is no new legislation that would
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continued compliance with state law.
2020-2025 Strategic Targets and Goals
Strategic Target No. 1: Financial Stability by Implementing, maintaining and updating a
fiscal accountability plan. The annual approval is a requirement of state law as it
pertains to managing the investment of City funds and provides guidance to the Finance
Director to execute this Charter-designated responsibility.
Fiscal Impact
The proposed action has no specific fiscal impact. It authorizes continued investment of
in annual investment income given the current interest rate environment. Interest
earnings have been anticipated in the adopted FY 2020/21 Operating Budget.
Conclusion
Adopt Resolution No. 2020-124 of the Mayor and City Council of the City of San
Bernardino, California, approving the City Investment Policy for FY 2020/21.
Attachments
Attachment 1 Resolution 2020-124- Investment Policy
Ward: N/A
Synopsis of Previous Council Actions:
November 6, 2019 Resolution 2019-317 was adopted approving the 2019/20
Investment Policy.
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RESOLUTION NO. 2020-124
RESOLUTION OF THE MAYOR AND CITY COUNCIL OF
THE CITY OF SAN BERNARDINO, CALIFORNIA
APPROVING AN INVESTMENT POLICY FOR FY 2020/21
WHEREAS, the City of San Bernardino has an existing investment policy consistent
with state law and sound financial management practices; and
WHEREAS, state law requires that the managing board of any municipality within the
state review and reapprove the investment policy on an annual basis; and
WHEREAS the Director of Finance has reviewed the 2019/20 investment policy adopted
November 6, 2019, and is recommending minor changes to the proposed policy attached hereto
; and
WHEREAS, such policy is presented to the Mayor and City Council for its review and
approval for Fiscal Year 2020/21 and is consistent with state law.
BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF
SAN BERNARDINO AS FOLLOWS:
SECTION 1. The above recitals are true and correct and are incorporated herein by this
reference.
SECTION 2. The Mayor and City Council hereby adopts the "Investment Policy for
Fiscal Year 2020/21," attached hereto as Exhibit "A" and incorporated herein by this reference.
SECTION 3. The City Council finds this Resolution is not subject to the California
Environmental Quality Act (CEQA) in that the activity is covered by the general rule that CEQA
applies only to projects which have the potential for causing a significant effect on the
environment. Where it can be seen with certainty, as in this case, that there is no possibility that
the activity in question may have a significant effect on the environment, the activity is not
subject to CEQA.
SECTION 4. Severability. If any provision of this Resolution or the application thereof
to any person or circumstance is held invalid, such invalidity shall not affect other provisions or
applications, and to this end the provisions of this Resolution are declared to be severable.
SECTION 5. Effective Date. This Resolution shall become effective immediately.
APPROVED and ADOPTED by the City Council and signed by the Mayor and attested
by the Acting City Clerk this 17th day of June 2020.
John Valdivia, Mayor
City of San Bernardino
Resolution No. 2020-124
Attest:
Genoveva Rocha, CMC, Acting City Clerk
Approved as to form:
Sonia Carvalho, City Attorney
Resolution No. 2020-124
CERTIFICATION
STATE OF CALIFORNIA )
COUNTY OF SAN BERNARDINO) ss
CITY OF SAN BERNARDINO )
I, Genoveva Rocha, CMC, Acting City Clerk, hereby certify that the attached is a true
copy of Resolution No. 2020-___, adopted at a regular meeting held on the ___ day of _______
2020 by the following vote:
Council Members: AYES NAYS ABSTAIN ABSENT
SANCHEZ _____ _____ _______ _______
IBARRA _____ _____ _______ _______
FIGUEROA _____ _____ _______ _______
SHORETT _____ _____ _______ _______
NICKEL _____ _____ _______ _______
RICHARD _____ _____ _______ _______
MULVIHILL _____ _____ _______ _______
WITNESS my hand and official seal of the City of San Bernardino this ___ day of
____________ 2020.
Genoveva Rocha, CMC, Acting City Clerk
CITY OF
SAN BERNARDINO
Investment Policy
Fiscal Year 2020-2021
Adopted June 17, 2020
Paul Espinoza
Director of Finance
Exhibit A
I. PURPOSE
To establish guidelines for the prudent investment of public funds in a manner that will
protect City funds, meet daily cash flow expenditures, and comply with all federal, state,
and local laws and ordinances governing the investment of public funds.
II. POLICY & ADOPTION
It shall be the policy of the City of San Bernardino to annually review and adopt an
Investment Policy by resolution of the City Council. This Policy applies to all financial
assets and funds held by the City of San Bernardino and the Successor Agency to the San
Bernardino Redevelopment Agency. The funds covered by this policy include:
*General Fund
*Special Revenue Funds
*Capital Project Funds
*Proprietary Funds
*Other funds that may be created
Any modifications to the Policy must be approved by the City Council.
III. PROCEDURES
The Director of Finance shall annually review the City’s Investment Policy, and
incorporate any changes in state law, recommendations from the City’s Investment
Advisor, recommendations from the various national and state organizations of
municipal finance officers, or other changes recommended by City staff. The revised
Investment Policy shall be presented to the City Council for review and approval.
(A)Responsibilities
No person may engage in investment activities except as provided under the terms of
this Policy and the procedures established by the Director of Finance.
1. Responsibilities of the City Council
The City Council shall annually consider and adopt a written Investment
Policy. As provided in this Policy, the Council shall receive quarterly
Investment Reports.
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Exhibit A
2. Responsibilities of the Director of Finance
The Director of Finance is appointed by and serves at the pleasure of the City
Manager and is subject to his/her direction and supervision. The Director of
Finance is charged with responsibility for the conduct of all Finance
Department operations. The City Charter places the “City Treasurer”
responsibilities amongst the duties of the Director of Finance. That individual
is charged with responsibility for carrying out all investment actions.He/she
may delegate the day-to-day investment activities to theirdesignee(s) but
not the responsibility for the overall investment program. If authorized by
the City Council, the Director of Finance may also utilize the services of an
external investment advisor to assist with the investment program.
The Director of Finance, through supporting staff members, is responsible to
manage all public funds and securities belonging to or under the control of
the City and the Successor Agency, including the deposit and investment of
those funds in accordance with principles of sound treasury management
and applicable laws and ordinances. Appropriate internal controls designed
to ensure that assets of the City are protected from loss, theft, or misuse,
including but not limited to separation of duties and multiple approvers for
transactions, shall be maintained at all times in order to safeguard the City’s
assets.
3. Responsibilities of the City’s Investment Advisor (if applicable)
The City may engage in the services of outside professionals for evaluation
and advice regarding the City’s investment program. An authorized
Investment Advisor may provide investment management services, which
may also include facilitating trade executions under the direction of the
Director of Finance or designee. Any Investment Advisor shall be registered
by the Securities and Exchange Commission and licensed to do business in
the State of California. An authorized Investment Advisor shall invest the
City’s funds in investments that are in compliance with this policy and
provide accurate and timely reports of its investment activities to City staff.
The Investment Advisor shall never take possession of the City’s funds or
assets.
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Exhibit A
4. Internal Controls
The Director of Finance is responsible for establishing and maintaining an
internal control structure designed to ensure that the assets of the City are
protected from loss, theft, fraud or misuse.
The City’s external independent auditing firmshall perform an annual
analysis and review of internal controls, account activity and compliance with
policies and procedures.
(B)Prudent Investor Rule
The standard of prudence to be used by the Director of Finance shall be the
“prudent investor” standard. This shall be applied in the context of managing an
overall portfolio.
The “Prudent Investor Rule” provides, pursuant to California Government Code
Section 53600.3, that 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. The Director of Finance and any designee of the
Director of Finance, as 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 to the
City Council in a timely fashion and appropriate action is taken to control adverse
developments.
(C) Ethics and Conflicts of Interest
In addition to state and local statutes relating to conflicts of interest, all persons
involved in the investment process shall refrain from personal business activity
that conflicts with proper execution of the investment program or impairs their
ability to make impartial investment decisions. Employees and investment
officers are required to annually file applicable financial disclosures as required
for “public officials who manage public investments” by the Fair Political
Practices Commission (FPPC) and are subject to California law relative to conflicts
of interest.
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Exhibit A
(D) Level of Investment
The City strives to maintain the level of investment of all investable cash as near
to 100 percent as possible through current and projected cash flow
management.The Director of Financeshall maintain a system to monitor and
forecast revenues and expenditures so that City funds can be invested to the
fullest extent possible while providing sufficient liquidity to meet the City’s
reasonably anticipated cash flow requirements. Maturities of investments will be
selected to provide necessary liquidity, manage interest rate risk, and optimize
earnings. Because of inherent difficulties in accurately forecasting cash flow
requirements, a portion of the portfolio should be continuously invested in
readily available funds.
(E) Investment Objectives
The City seeks safety and liquidity in all of its investments followed by yield.
Safety, liquidity, and yield are defined as follows:
1. Safety. Safety of principal is the foremost objective of the investment
program. Investments shall be undertaken in a manner that seeks to
ensure the preservation of capital in the overall portfolio.
2. Liquidity. The investment portfolio shall remain sufficiently liquid to meet
operating requirements that may be reasonably anticipated. This is
accomplished by structuring the portfolio so that securities mature
concurrent with cash needs to meet anticipated demands.
3. Yield. The investment portfolio shall be designed with the objective of
attaining a market rate of return, taking into account the investment risk
constraints and liquidity needs. Return on investment is of secondary
importance compared to the safety and liquidity objectives described
above.
(F) Allowable Investments
The investments listed in this Policy are authorized investments pursuant to
Sections 53601 and 53635 of the California Government Code and are
authorized investments for the City subject, however, to the restrictions set
forth in Section “K” of this Investment Policy. In the event that an apparent
discrepancy is found between this Policy and the Government Code, the more
restrictive parameters will take precedence.
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Exhibit A
(G) Collateralization
If collateral is required for a particular investment type, it will be provided in
compliance with California Government Code requirements.
(H) Investment Pools/Mutual Funds
Prior to investing in any pooled investment program (e.g., LAIF, money market
funds), the Director of Finance will review the program’s documentation (e.g.,
investment policy, policies for participation, fees) to determine the
appropriateness of the pool for City funds. Whenever the City has funds
invested in a pooled investment program, the Director of Financeshould
periodically review the pool’s investment holdings. The review shall, at a
minimum, obtain the following information:
A description of eligible investment securities, and a written
statement of investment policy and objectives.
A description of interest calculations and how it is distributed, and
how gains and losses are treated.
A description of how the securities are safeguarded (including the
settlement processes), and how often the securities are priced and
the program audited.
A description of who may invest in the program, how often, and
what size of deposits and withdrawals are allowed.
A schedule for receiving statements and portfolio listings.
A description of how the pool/fund utilizes reserves, retained
earnings, etc.
A fee schedule, including when and how fees are assessed.
The eligibility of the pool/fund to invest in bond proceeds and
special district funds, and a description of its practices
(I) Diversification
The City shall diversify the investments within the portfolio to avoid incurring
unreasonable risks inherent in over-investing in specific instruments, individual
financial institutions, or maturities. To promote diversification, no more than 5%
of the portfolio may be invested in the securities of any one issuer, regardless of
security type; excluding U.S. Treasuries, federal agencies, supranationals, and
pooled investments such as LAIF, money market funds, or local government
investment pools.
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Exhibit A
(J) Maximum Maturities
For those investment types for which this Policy does not specify a maturity
limit, no individual investment shall exceed a maturity of five years from the date
of purchase unless the City Council has granted express authority to make that
investment either specifically or as a part of an investment program approved by
the City Council no less than three months prior to the investment. The
weighted average duration of the investment portfolio shall not exceed 3.0
years.
(K) Authorized Investments of the City
The following types of investments are authorized by this Policy:
1. U.S. Treasury Instruments. United States Treasury notes, bonds, bills, or
certificates of indebtedness, or those for which the faith and credit of the
United States are pledged for the payment of principal and interest.
There is no limitation as to the percentage of the City’s portfolio that may
be invested in this category. The maximum maturity for this investment is
five years from the time of purchase.
2.State of California’s Local Agency Investment Fund (LAIF). A State of
California-managed investment pool. The maximum amount invested in
this category may not exceed the limit set by LAIF for operating accounts.
For 2020 that deposit limit is $75 million.
3.Local Government Investment Pools (“LGIP”). Shares of beneficial
interest issued by joint powers authority organized pursuant to Section
6509.7 that invests in the securities and obligations authorized in
Government Code (e.g. Cal Trust). The City will limit investments to LGIPs
that seek to maintain a stable net asset value. There is no limitation as to
the percentage of the City’s portfolio that may be invested in this
category.
4.Municipal Bonds. Registered state warrants or treasury notes or bonds
of this state, including bonds payable solely out of the revenues from a
revenue-producing property owned, controlled, or operated by the state
or by a department, board, agency, or authority of the state.
Registered treasury notes or bonds of any of the other 49 states in
addition to California, including bonds payable solelyout of the revenues
from a revenue-producing property owned, controlled, or operated by a
state or by a department, board, agency, or authority of any of the other
49 states, in addition to California.
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Exhibit A
Bonds, notes, warrants, or other evidences of indebtedness of a local
agency within this state, including bonds payable solely out of the
revenues from a revenue-producing property owned, controlled, or
operated by the local agency, or by a department, board, agency, or
authority of the local agency.
Purchases are limited to securities rated in a rating category of “A” (long-
term) or “A-1” (short-term) or their equivalents or better by a Nationally
Recognized Statistical Rating Organization (NRSRO). A maximum of 30%
the City’s portfolio may be invested in this category. The maximum
maturity for this investment is five years from the time of purchase.
5.Federal Agency Securities. Federal agency or United States government-
sponsored enterprise obligations, participations, or other instruments,
including those issued by or fully guaranteed as to principal and interest
by federal agencies or United States government-sponsored enterprises.
There is no limitation as to the percentage of the City’s portfolio that may
be invested in this category. The maximum maturity for this investment
is five years from the time of purchase.
6.Negotiable Certificates of Deposit. Negotiable certificates of deposit
issued by a nationally or state-chartered bank, a savings association or a
federal association, a state or federal credit union, or by a federally
licensed or state-licensed branch of a foreign bank. Securities in this
category shall be limited to the maximum amount covered by federal
deposit insurance currently set at $250,000 for 2019. A maximum of 30%
the City’s portfolio may be invested in this category. The maximum
maturity for this investment is five years from the time of purchase.
7. Commercial Paper. Commercial paper of “prime” quality of the highest
ranking or of the highest letter and number rating as provided for by a
NRSRO. The entity that issues the commercial paper shall meet all of the
following conditions in either paragraph (1) or (2):
(1) The entity meets the following criteria: (A) Is organized and
operating in the United States as a general corporation; (B) Has
total assets in excess of five hundred million dollars
($500,000,000), and (C) Has debt other than commercial paper, if
any, that is rated in a rating category of “A” or its equivalent or
better by an NRSRO.
(2) The entity meets the following criteria: (A) Is organized within the
United States as a special purpose corporation, trust, or limited
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Exhibit A
liability company, (B) Has program-wide credit enhancements
including, but not limited to, overcollateralization, letters of
credit, or a surety bond, and (C) Has commercial paper that is
rated “A-1” or better, or the equivalent, by an NRSRO.
Purchases are limited to securities that have a maximum maturity of 270
days. A maximum of 25% the City’s portfolio may be invested in this
category with a maximum of 5% per issuer.
8. Corporate orMedium-Term Notes. Corporate or medium-term notes,
defined as all corporate and depository institution debt securities with a
maximum remaining maturity of five years or less, issued by corporations
organized and operating within the United States or by depository
institutions licensed by the United States or any state and operating
within the United States. Purchases are limited to securities rated in a
rating category of “A” or its equivalent or better by an NRSRO. A
maximum of 30% the City’s portfolio may be invested in this category
with a maximum of 5% per issuer.
9. Money Market Funds (“MMF”). Purchases are restricted to Government
Money Market Funds. Furthermore, these Money Market Funds must
have met either of the following criteria: (A) Attained the highest ranking
or the highest letter and numerical rating provided by not less than two
NRSROs, or (B) Retained an investment advisor with not less than five
years’ experience and registered or exempt from registration with the
SEC, with assets under management in excess of five hundred million
dollars ($500,000,000). A maximum of 20% of the City’s portfolio may be
invested in this category.
10. Supranational Obligations. United States dollar denominated senior
unsecured unsubordinated obligations issued or unconditionally
guaranteed by the International Bank for Reconstruction and
Development, International Finance Corporation, or Inter-American
Development Bank, with a maximum remaining maturity of five years or
less, and eligible for purchase and sale within the United States.
Investments under this subdivision shall be rated in a rating category of
“AA” or its equivalent or better by a NRSRO. A maximum of 10% the
City’s portfolio may be invested in this categorywith a maximum of 5%
per issuer. State law limits the percentage to 30% of the portfolio.
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Exhibit A
11. Bankers Acceptances. Bankers’ acceptances are short-term debt
instruments issued by a company that is guaranteed by a commercial
bank. Bankers Acceptances are limited to institutions with short-term
debt obligations of A-1 or higher and have long term debt obligations
rated “A” or higher, or the equivalent by a NRSRO. The maturity shall not
exceed 180 days and no more than 30 percent of the total portfolio may
be invested in banker’s acceptances and no more than 5% per issuer.
City of San Bernardino Authorized Investment Policy Table
Maximum % of Maximum per
Investment TypeMaximum Term Minimum Rating
Portfolio Issuer
US Treasury
5 Years NONE NONE NONE
Obligations
The City may invest up
Local Agency
to the maximum
Investment Fund
N/A N/A NONE
amount permitted by
(LAIF)
California state law.
Joint Powers/Local
Government N/A NONE N/A NONE
Investment Pool
Municipal Debt5 Years30%A1, A
Federal Agency
5 Years NONE NONE NONE
Obligations
Securities in this
Certificate of
category shall be
Deposits
limited to the
5 Years 30% NONE
maximum amount
covered by federal
deposit insurance.
Commercial Paper270 Days 25%5% A1/P1 , A
Medium
Term/Corporate 5 Years 30% 5% A
Notes
Money Market
N/A 20% NONE AAA
Mutual Funds
Supranational
Obligations (IBRD, 5 Years 10% 5% AA
IFC, IDB)
Banker’s
180 Days 30% 5% A1, A
Acceptances
(L) Prohibited Investments
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Exhibit A
Furthermore, the City will not invest in inverse floaters, range notes, mortgage-
derived, interest-only strips, or any security that could result in zero interest
accrual if held to maturity. In order to anticipate market changes and provide a
level of security for all funds, the collateralization level will 100% of market value
for Certificate of Deposits and 102% for reverse purchase agreements or
principal and accrued interest.Collateral will always be held by an independent
third party with whom the entity has a current custodial relationship
(M)Performance Standards
The investment portfolio shall be managed with the objective of obtaining a
market-average rate of return during budgetary and economic cycles,
considering the City’s investment risk constraints and the cash flow needs.
Investment return is a consideration only after the core investment portfolio
tenets of safety and liquidity have been met. The Director of Finance will adopt
a benchmark which best approximates the composition and weighted average
maturity of the City’s portfolio. The City will monitor the City’s portfolio yield
against the US Treasury Constant Maturity and the performance yield presented
by LAIF. However, the benchmark will be used only as a reference tool and does
not infer that the portfolio will be managed in an attempt to attain or exceed the
stated benchmark. Benchmarks may change over time based on changes in
market conditions or cash flow requirements. The selected performance
benchmarks shall be representative of the City’s overall investment objectives
and liquidity requirements.
(N) Investment Reporting
The Director of Finance shall submit to the City Council, on a monthly basis, a
report summarizing the individual transactions executed within the month. The
Director of Finance shall submit to the City Council on a quarterly basis a report
summarizing the status of the current investment portfolio and the individual
transactions executed over the last quarter. The report shall be prepared in a
manner which shall allow the City Council to ascertain whether investment
activities during the reporting period have conformed to the Investment Policy.
The report will include the following elements:
Type of investment
Institution/Issuer
Purchase Date
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Exhibit A
Date of maturity
Amount of deposit or cost of the investment
Face value of the investment
Current market value of securities and source of valuation
Rate of interest
Interest earnings
Statement relating the report to its compliance with the Statement of
Investment Policy or the manner in which the portfolio is not in
compliance
Statement on availability of funds to meet the next six month’s
obligations
Percentage of Portfolio by Investment Type
Days to Maturity for all Investments
Comparative report on Monthly Investment Balances & Interest Yields
Monthly transactions
(O) Portfolio Review
The Director of Finance shall continually monitor portfolioperformance to
ensure that the securities in the portfolio are in compliance with this Policy. The
Director of Finance shall report any issues of material non-compliance in the
next quarterly Investment Report. Percentage holding limits and diversification
requirements listed in this Policy apply at the time a security is purchased. If a
percentage holding limit or diversification requirement is exceeded due to a
subsequent change in the portfolio, it is not a compliance violation, but no
additional securities may be purchased in that category or for that issuer until
the holdings are back under the Policy limits. Credit ratings, where shown,
specify the minimum credit rating category required at purchase. In the event a
security held by the City is subject to a credit rating change that brings it below
the minimum credit ratings specified in this Policy, the Director of Financewill
notify the City Council of the change in the next quarterly Investment Report.
The course of action to be followed will then be decided on a case-by-case basis,
considering such factors as the reason for the change, prognosis for recovery or
further rating downgrades, and the market price of the security. If a security is
determined to be out of compliance with this Policy due to a subsequent change
in this Policy or the Government Code, it may be held to maturity unless there is
a requirement that the security be sold.
(P) Debt Proceeds
Debt proceeds and bond reserve funds are to be invested in accordance with
their respective bond indenture. If the indenture is silent as to the permitted
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Exhibit A
investments, the bond proceeds will be invested in the securities permitted by
this Policy. Notwithstanding the other provisions of this Policy, the percentage
limitations listed elsewhere in this Policy do not apply to bond proceeds and
bond proceeds may be invested beyond five years if the maturities of such
investments do not exceed the expected use of the funds, the investments are
deemed prudent in the opinion of the Director of Finance, and the investments
are not prohibited by the applicable bond documents. Tax and Revenue
Anticipation Notes or other temporary financing proceeds shall not be invested
for a term that exceeds the term of the debt.
(Q)Safekeeping
To protect against potential losses by collapse of individual securities dealers, all
deliverable securities owned by the City, including collateral on repurchase
agreements, shall be held in safekeeping by a third party bank trust department
acting as agent for the City under the terms of a custody agreement executed by
the bank and by the City. All deliverable securities will be received and delivered
using standard delivery-versus-payment procedures.
(R)Qualified Financial Institutions and Broker/Dealers
The Director of Finance shall maintain a list of approved financial institutions
authorized to provide investment related services to the City. In addition, the
City shall maintain a list of approved security broker/dealers selected by
conducting a process of due diligence. These may include ‘primary’ dealers or
regional dealers that qualify under Securities and Exchange Commission (“SEC”)
Rule 15C3-1 (uniform net capital rule). A copy of this Investment Policy shall be
sent annually to all firms with which the City executes investments.
Additionally, all financial institutions and broker/dealers who desire to become
qualified bidders of investment transactions must provide the Director of
Finance with the following:
Audited Financial Statements
Proof of State Registration
Copy of most recently filed Financial Industry Regulated Authority
(FINRA) documentation
Certification of having read the Investment Policy and depository
contracts of the City of San Bernardino
The Director of Finance will review the existing list of either qualified
broker/dealers or qualified bidders for investment transactions on an annual
basis. At the discretion of the Director of Finance, and with the due diligence
noted above, add or delete either broker/dealers or qualified bidders.
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Exhibit A
(S) Continuing Education and Training
To ensure the highest level of professional standards for the execution of the
investment program, investment staff responsible for the day-to-day
management of the portfolio are encouraged to engage in continuing education
in the areas of cash and investment management.
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Exhibit A
GLOSSARY
AGENCIES: Federal agency securities.
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. The drafts are
drawn on a bank by an exporter or importer to obtain funds to pay for specific merchandise.
An acceptance is a high grade negotiable instrument.
BENCHMARK: A comparative base for measuring the performance or risk tolerance of the
investment portfolio. A benchmark should represent a close correlation to the level of risk and
the average duration of the portfolio’s investments.
BROKER: A broker brings buyers and sellers together for a commission. He/she does not take a
position.
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.
COMMERCIAL PAPER: Short term unsecured promissory note issued by a corporation (including
limited liability companies) to raise working capital. These negotiable instruments are
purchased at a discount to par value or at par value with interest bearing. Commercial paper is
issued by corporations such as General Motors Acceptance Corporation, IBM, Bank of America,
etc.
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/her own account.
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Exhibit A
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.
DIVERSIFICATION: Dividing investment funds among a variety of securities offering
independent returns.
FEDERAL CREDIT AGENCIES: Agencies of the Federal government set up to supply credit to
various classes of institutions (e.g. S&L’s, Small business firms, students, farmers, farm
cooperatives, and exporters).
FEDERAL DEPOSIT INSURANCE CORPORATION (FDIC): A Federal agency
that insures bank deposits, currently up to $250,000 per deposit.
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 a reasonable size can be done at those quotes.
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.
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.
NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION
(“NRSRO”): Firms that review and assess the creditworthiness of an obligor as an entity or with
respect to specific securities or money market instruments and express their opinion in the
form of a letter rating. A credit rating agency may apply to the SEC for registration as a
nationally recognized statistical rating organization (“NRSRO”). The primary rating agencies are
Standard & Poor’s Corporation, Moody’s Investor Services, Inc. and Fitch, Inc.
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Exhibit A
Negotiable Certificates of Deposit: Generally, short-term debt instrument that usually pays
interest and is issued by a bank, savings or federal association, state or federal credit union, or
state-licensed branch of a foreign bank. Negotiable CDs are traded in a secondary market and
are payable upon order to the bearer or initial depositor (investor). Negotiable CDs are insured
by FDIC up to $250,000, but they are not collateralized beyond that amount.
Non-Negotiable Certificates of Deposit: CDs that carry a penalty if redeemed prior to maturity.
Non-negotiable CDs issued by banks and savings and loans are insured by the Federal Deposit
Insurance Corporation up to the amount of $250,000, including principal and interest. Amounts
deposited above this amount may be secured with other forms of collateral through an
agreement between the investor and the issuer. Collateral may include other securities
including Treasuries or agency securities such as those issued by the Federal National Mortgage
Association.
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
firms.
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
that would be bought by a prudent person of discretion and intelligence who is seeking a
reasonable income and preservation of capital.
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.
SAFEKEEPING: The service provided by banks and trust companies for clientswhen the bank or
trust company stores the securities, takes in coupon payments, and redeems issues at maturity.
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Exhibit A
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”.
SUPRANATIONAL SECURITIES: United States dollar denominated senior unsecured
unsubordinated obligations issued or unconditionally guaranteed by the International Bank for
Reconstruction and Development (IBRD), International Finance Corporation (IFC), or Inter-
American Development Bank (IDB), with a maximum remaining maturity of five years or less,
and eligible for purchase and sale within the United States. Investments under this subdivision
shall be rated “AA” or better by an NRSRO and shall not exceed 10 percent of the agency’s
moneys that may be invested pursuant to this section.
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 BOND: Long-term U.S. Treasury securities having initial maturities of more than 10
years.
TREASURY NOTES: Intermediate-term coupon bearing U.S. Treasury having initial maturities of
from one year to ten years.
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
price 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 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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