This investment policy applies to all monies and other financial
resources available for investment on its own behalf or on behalf
of any other entity or individual.
The primary objectives of the City of Middletown's investment
activities are, in priority order:
A. Legal: to conform with all applicable federal, state and other local
requirements;
B. Safety: to adequately safeguard principal;
C. Liquidity: to provide sufficient liquidity to meet all operating
requirements; and
D. Yield: to obtain reasonable rate of return.
The governing board's responsibility for administration
of the investment program is delegated to the Treasurer who shall
establish written procedures for the operation of the investment program
consistent with these investment guidelines. Such procedures shall
include an adequate internal control structure to provide a satisfactory
level of accountability based on data base or records incorporating
description and amounts of investments, transaction dates, and other
relevant information and regulate the activities of subordinate employees.
It is the policy of the City of Middletown to diversify its
deposits and investments by financial institutions, by investment,
and by maturity scheduling.
The bank and trust companies authorized for the deposit of monies
up to the maximum amounts are:
Depository Name
|
Maximum Amount
|
---|
JP Morgan Chase
|
$18,000,000
|
TD Bank
|
$18,000,000
|
Sterling National Bank
|
$18,000,000
|
Orange Trust Bank
|
$12,500,000
|
Key Bank
|
$5,250,000
|
In accordance with the provisions of General Municipal Law §
10, all deposits of the City of Middletown, including certificates of deposits and special time deposits, in excess of the amount insured under the provisions of the Federal Deposit Insurance Act shall be secured:
A. By a pledge of eligible securities with an aggregate market value as provided by GML §
10, equal to the aggregate amount of deposits from the categories designated in Appendix A to the policy.
B. By an eligible irrevocable letter of credit issued by a qualified
bank other than the bank with the deposits in favor of the government
for a term not to exceed 90 days with an aggregate value equal to
140% of the aggregate amount of the deposits and the agreed upon interest,
if any, or 100% in the case of an irrevocable letter of credit issued
in favor of the local government by certain federal home loan banks.
A qualified bank is one whose commercial paper and other unsecured
short-term debt obligations are rated in one of the three highest
rating categories by at least one nationally recognized statistical
rating organization or by a bank that is in compliance with applicable
federal minimum risk-based capital requirements.
C. By an eligible surety bond payable to the government for an amount
at least equal to 100% of the aggregate amount of the deposits and
the agreed upon interest, if any, executed by an insurance company
authorized to do business in New York State, whose claims-paying ability
is rated in the highest rating category by at least two nationally
recognized statistical rating organizations.
The City of Middletown shall maintain a list of financial institutions
and dealers approved for investment purposes and establish appropriate
limits to the amount of investments, which can be made with each financial
institution or dealer. All financial institutions with which the local
government conducts business must be credited worthy. Banks shall
provide their most recent consolidated report of condition (call report)
at the request of the City of Middletown. Security dealers not affiliated
with a bank shall be required to be classified as reporting dealers
affiliated with the New York Federal Reserve Bank as primary dealers.
The Treasurer is responsible for evaluating the financial position
and maintaining a listing of proposed depositaries, trading partners
and custodians. Such listing shall be evaluated at least annually.
Repurchase agreements are authorized subject to the following
restrictions:
A. All repurchase agreements must be entered into subject to a master
repurchase agreement.
B. Trading partners are limited to banks or trust companies authorized
to do business in New York and primary reporting dealers.
C. Obligations shall be limited to obligations of the United States
of America and obligations guaranteed by agencies of the United States
of America.
D. No substitution of security will be allowed.
E. The custodian shall be a party other than the trading partner.