[HISTORY: Adopted by the City Council of
the City of Canandaigua 8-3-2006. Amendments noted where applicable.]
This investment policy shall apply to all moneys
and other financial resources available for investment on its own
behalf or on behalf of any other entity or individual.
The objectives of the investment policy are:
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 a data base or records incorporating
description and amounts of investments, transaction dates, and other
relevant information, and to regulate the activities of subordinate
employees.
A.
All participants in the investment process shall seek
to act responsibly as custodians of the public trust and shall avoid
any transaction that might impair public confidence in the City of
Canandaigua to govern effectively.
B.
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 safety of
the principal as well as the probable income to be derived.
C.
All participants 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.
It is the policy of the City of Canandaigua
to diversify its deposits and investments by financial institution,
by investment instrument and by maturity scheduling. Competitive terms,
including interest rates, will be reviewed for all investments of
90 days or longer.
A.
It is the policy of the City of Canandaigua that all
moneys collected by any officer or employee of the government to transfer
those funds to the Treasurer within two business days for amounts
totaling greater than $500 and weekly for amounts less than $500,
or within the time period specified in law, whichever is shorter.
B.
The Treasurer is responsible for establishing and
maintaining an internal control structure to provide reasonable, but
not absolute, assurance that deposits and investments are safeguarded
against loss from unauthorized use or disposition, that transactions
are executed in accordance with management's authorization and recorded
properly, and are managed in compliance with applicable laws and regulations.
[Amended 2-1-2007 by Res. No. 2007-007; 9-6-2007 by Res. No. 2007-088; 9-3-2015 by Res. No.
2015-079]
The banks and trust companies authorized for
the deposit of moneys up to the maximum amounts are:
|
Depository Name
|
Maximum Amount
|
|---|---|
|
Canandaigua National Bank
|
$10,000,000
|
|
MBIA
|
$3,500,000
|
|
Five Star Bank
|
$3,000,000
|
|
First Niagara Bank
|
$3,500,000
|
|
Lyons National Bank
|
$3,500,000
|
|
Genesee Regional Bank
|
$5,000,000
|
In accordance with General Municipal Law § 10,
all deposits of the City of Canandaigua, including certificates of
deposit and special time deposits, in excess of the amount insured
under the provisions of the Federal Deposit Insurance Act shall be
secured:
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 deposits and the agreed
upon interest, if any. 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 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 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 the highest rating category by at least two nationally recognized
statistical rating organizations.
A.
Eligible securities used for collateralizing deposits
shall be held by the depository or third party bank or trust company
subject to security and custodial agreements.
B.
The security agreement shall provide that eligible
securities are being pledged to secure local government deposits together
with agreed upon interest, if any, and any costs or expenses arising
out of the collection of such deposits upon default. It shall also
provide the conditions under which the securities may be sold, presented
for payment, substituted or released and the events which will enable
the local government to exercise its rights against the pledged securities.
In the event that the securities are not registered or inscribed in
the name of the local government, such securities shall be delivered
in a form suitable for transfer or with an assignment in blank to
the City of Canandaigua or its custodial bank.
C.
The custodial agreement shall provide that securities
held by the bank or trust company, or agent of and custodian for,
the local government, will be kept separate and apart from the general
assets of the custodial bank or trust company and will not, in any
circumstances, be commingled with or become part of the backing for
any other deposit or other liabilities. The agreement shall provide
for the frequency of revaluation of eligible securities and for the
substitution of the securities when a change in the rating of a security
may cause ineligibility. Such agreement shall include all provisions
necessary to provide the local government a perfected interest in
the securities.
A.
As authorized by General Municipal Law § 11,
the City of Canandaigua authorizes the Treasurer to invest moneys
not required for immediate expenditure for terms not to exceed its
projected cash flow needs in the following types of investments:
(1)
Time deposit accounts. Savings or demand deposit accounts
placed through a depository institution that has a main or branch
office in the State of New York and that contractually agrees to place
funds in federally insured depository institutions through the Insured
Cash Sweep service, or ICS.
[Amended 9-3-2015 by Res.
No. 2015-079]
(2)
Certificates of deposit. Certificates of deposit obtained
through a depository institution that has a main or branch office
in the State of New York and that contractually agrees to place funds
in federally insured depository institutions through the Certificate
of Deposit Account Registry Service, or CDARS.
[Amended 9-3-2015 by Res.
No. 2015-079
(3)
Obligations of the United States of America.
(4)
Obligations guaranteed by agencies of the United States
of America where the payment of principal and interest are guaranteed
by the United States of America.
(5)
Obligations of the State of New York.
(6)
Obligations issued pursuant of Local Finance Law § 24.00
or 25.00 (with approval of the State Comptroller) by any municipality,
school district or district corporation other than the City of Canandaigua.
(7)
Obligations of public authorities, public housing
authorities, urban renewal agencies and industrial development agencies
where the general state statutes governing such entities or whose
specific enabling legislation authorizes such investments.
(8)
Certificates of participation (COPS) issued pursuant
to General Municipal Law § 109-b.
(9)
Obligations of this local government, but only with
any moneys in a reserve fund established pursuant to General Municipal
Law § 6-c, 6-d, 6-e, 6-g, 6-h, 6-j, 6-k, 6-l, 6-m, or 6-n.
B.
All investment obligations shall be payable or redeemable
at the option of the City of Canandaigua within such times as the
proceeds will be needed to meet expenditures for purposes for which
the moneys were provided and, in the case of obligations purchased
with the proceeds of bonds or notes, shall be payable or redeemable
at the option of the City of Canandaigua within two years of the date
of purchase.
The City of Canandaigua 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 creditworthy. Banks shall provide their most recent consolidated
report of condition at the request of the City of Canandaigua. 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 depositories,
trading partners and custodians. Such listing shall be evaluated at
least annually.
A.
The Treasurer or City Manager is authorized to contact
for the purchase of investments:
(1)
Directly, including through a repurchase agreement,
from an authorized trading partner.
(2)
By participation in a cooperative investment program
with another authorized governmental entity pursuant to Article 5-G
of the General Municipal Law where such program meets all the requirements
set forth in the Office of the State Comptroller Opinion No. 88-46,
and the specific program has been authorized by the governing board.
(3)
By utilizing an ongoing investment program with an
authorized tracking partner pursuant to a contract authorized by the
governing board.
B.
All purchased obligations, unless registered or inscribed
in the name of the local government, shall be purchased through, delivered
to and held in the custody of a bank or trust company. Such obligations
shall be purchased, sold or presented for redemption or payment by
such bank or trust company only in accordance with prior written authorization
from the officer authorized to make the investment. All such transactions
shall be confirmed, in writing, to the City of Canandaigua by the
bank or trust company. Any obligation held in the custody of a bank
or trust company shall be held pursuant to written custodial agreement
as described in General Municipal Law § 10.
C.
The custodial agreement shall provide that securities
held by the bank or trust company, as agent of and custodian for,
the local government, will be kept separate and apart from the general
assets of the custodial bank or trust company and will not, in any
circumstances, be commingled with or become part of the backing for
any other deposit or other liabilities. The agreement shall describe
how the custodian shall confirm receipt and release of the securities.
Such agreement shall include all provisions necessary to provide the
local government a perfected interest in the securities.
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 State and primary reporting
dealers.
C.
Obligations shall be limited to obligations of the
United State of America and obligations guaranteed by agencies of
the United States of America.
D.
No substitutions are allowed.
E.
The custodian shall be a party other than the trading
partner.
