This chapter shall be known as the "Town of Webb Investment
Policy."
This investment policy 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.
The Town Board's responsibility for administration of the investment
program is delegated to the Supervisor of the Town of Webb, 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 database 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 Town to diversify its deposits and investments
by financial institution, by investment instrument and by maturity
scheduling.
In accordance with the provisions of General Municipal Law § 10,
all deposits of the Town, 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 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 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 Town shall maintain a list of financial institutions and
dealers approved for investment purposes and establish appropriate
limits to the amounts 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 (call report) at
the request of the Town. 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 Supervisor
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.