This chapter applies to all moneys 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 local government's investment activities
are, in priority order:
A. To conform with all applicable federal, state and other
legal requirements (legal).
B. To adequately safeguard principal (safety).
C. To provide sufficient liquidity to meet all operating
requirements (liquidity).
D. To obtain a reasonable rate of return (yield).
The governing board's responsibility for administration of the
investment program is delegated to the Village 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 regulate the activities
of subordinate employees.
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 Village of Middleport to govern effectively.
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. 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 Village of Middleport to diversify its deposits
and investments by financial institution, by investment instrument and by
maturity scheduling.
The banks and trust companies authorized for the deposit of moneys up
to the maximum amounts are:
Depository Name
|
Maximum Amount
|
Officer
|
---|
Fleet Bank
|
$3,000,000
|
Stephen Petherbridge
|
M & T Bank
|
$3,000,000
|
Mary Brogan
|
Marine Midland Bank
|
$3,000,000
|
Douglas Bowden
|
Key Bank of Western New York
|
$3,000,000
|
Paul DePlato
|
In accordance with the provisions of General Municipal Law § 10,
all deposits of Village of Middleport, 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:
A. By a pledge of eligible securities with an aggregate
market value as provided by General Municipal Law § 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 deposits and the agreed upon interest, if any. A qualified
bank if 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 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 Village of Middleport 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 credit worthy. Banks shall provide their most recent consolidated
report of condition (Call Report) at the request of the Village of Middleport.
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 Village 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.
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
States of America and obligations guaranteed by agencies of the United States
of America.
D. No substitution of securities will be allowed.
E. The custodian shall be a party other than the trading
partner.