[R.O. 2016 § 160.010; Ord. No. 848-09 § 1, 6-9-2009]
It is the policy of the City of Park
Hills to invest public funds in a manner which will provide the highest
investment return with the maximum security while meeting the daily
cash flow demands of the City and conforming to all State and local
Statutes governing the investment of public funds.
[R.O. 2016 § 160.020; Ord. No. 848-09 § 1, 6-9-2009]
A. This investment policy applies to all financial
assets of the City of Park Hills. These funds are accounted for in
the City's annual financial statements and include the following and
any other funds created in the future:
8.
Special Allocation Funds II, III,
IV.
[R.O. 2016 § 160.030; Ord. No. 848-09 § 1, 6-9-2009]
Authority to manage the City's investment
program is derived from the following: Section 30.950, RSMo.
[R.O. 2016 § 160.040; Ord. No. 848-09 § 1, 6-9-2009]
Authority to manage the investment
program is granted to the City Administrator, hereinafter referred
to as investment officer, and derived from the enabling City ordinance.
Responsibility for the operation of the investment program is hereby
delegated to the investment officer who shall act in accordance with
the established written procedures and internal controls for the operation
of the investment program consistent with this investment policy.
Procedures should include references to: safekeeping, delivery vs.
payment, investment accounting, repurchase agreements, wire transfer
agreements and collateral/depository agreements. No person may engage
in an investment transaction except as provided under the terms of
this policy and the procedures established by the investment officer.
The investment officer shall be responsible for all transactions undertaken
and shall establish a system of controls to regulate the activities
of subordinate officials.
[R.O. 2016 § 160.050; Ord. No. 848-09 § 1, 6-9-2009]
A. The City's Investment Committee shall be
responsible for monitoring and reviewing the investment process, setting
and monitoring general strategies, selecting and recommending broker/dealers
to the City Council for approval, reviewing portfolio performance
on a quarterly basis and reporting the status and performance of the
investment portfolio to the City Council on a quarterly basis. In
reviewing the portfolio performance, the investments shall be revalued
to reflect prevailing market prices. Investments which are downgraded
below the minimum acceptable rating level shall be reviewed for possible
sale within a reasonable time period.
B. Members of the Committee shall include:
1.
City Administrator or designee.
6.
President Pro Tem of the City Council.
[R.O. 2016 § 160.060; Ord. No. 848-09 § 1, 6-9-2009]
A. The standard of care to be used by investment
officials shall be the "prudent person" standard and shall be applied
in the context of managing an overall portfolio. Investment officials
acting in accordance with written procedures and this investment policy
and exercising due diligence shall be relieved of personal liability
for an individual security's credit risk or market price changes,
provided deviations from expectations are reported in a timely fashion
to the Governing Body and the liquidity and the sale of securities
are carried out in accordance with the terms of this policy.
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
probable safety of their capital as well as the probable income to
be derived.
[R.O. 2016 § 160.070; Ord. No. 848-09 § 1, 6-9-2009]
Personnel 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. Employees and
investment officials shall disclose to the Investment Committee any
material financial interests in financial institutions that conduct
business with the City and they shall further disclose any large personal
financial/investment positions that could be related to the performance
of the City's portfolio, particularly with regard to time of purchases
and sales. Employees and officers shall refrain from undertaking significant
personal investment transactions with the same individual with which
business is conducted on behalf of the City of Park Hills.
[R.O. 2016 § 160.080; Ord. No. 848-09 § 1, 6-9-2009]
A. The primary objective, in priority order,
of the City of Park Hills investment activities shall be:
1.
Internal Controls.
a.
The investment officer is responsible
for establishing and maintaining an internal control structure that
will be reviewed annually with the City of Park Hills' independent
auditor. The internal control structure shall be designed to ensure
that the assets of the City of Park Hills are protected from loss,
theft or misuse and to provide reasonable assurance that these objectives
are met. The concept of reasonable assurance recognizes that:
(1) The cost of control
should not exceed the benefits likely to be derived; and
(2) The valuation of costs
and benefits require estimates and judgments by management.
b.
The internal controls shall address
the following points:
(2) Separation of transaction
authority from accounting and recordkeeping.
(4) Avoidance of physical
delivery securities.
(5) Clear delegation of
authority to subordinate staff members.
(6) Written confirmation
of transactions for investments and wire transfers.
(7) Development of a wire
transfer agreement with the lead bank and third party custodian.
2.
Safety. Safety of principal is the
foremost objective of the investment program. Investments of the City
shall be undertaken in a manner that seeks to ensure the preservation
of capital in the overall portfolio. To attain this objective, diversification
is required in order that potential losses on individual securities
do not exceed the income generated from the remainder of the portfolio.
3.
Liquidity. The City's investments
portfolio will remain sufficiently liquid to enable the City to meet
all operating requirements which might be reasonably anticipated.
This is accomplished by structuring the portfolio so that securities
mature concurrent with cash needs to meet anticipated demands (static
liquidity).
4.
Yield. The City's investment portfolio
shall be designed with the objective of attaining a rate of return
throughout budgetary and economic cycles, commensurate with the City's
investment risk constraints and liquidity needs. Return on investment
is of secondary importance compared to the safety and liquidity objectives
described above.
[R.O. 2016 § 160.090; Ord. No. 848-09 § 1, 6-9-2009]
A. Investments will be made through banks
or securities dealers who have been approved by the Investment Committee.
Such securities dealers and banks shall be subjected to an appropriate
investigation by the Investment Committee. All approved dealers must
be fully licensed and registered NASD® broker/dealers or demonstrate compliance with Securities and Exchange
Commission Rule 15C3-1. Criteria to select securities dealers will
include:
1.
Audited financial statements.
2.
Proof of National Association of
Securities Dealers (NASD®) certification.
3.
Proof of State registration.
4.
Completed broker/dealer questionnaire.
5.
Certification of having read and
understood and agreeing to comply with the City's investment policy.
[R.O. 2016 § 160.100; Ord. No. 848-09 § 1, 6-9-2009]
A. The City is empowered by Statute to invest
in the following types of securities:
1.
Time deposit, bearing interest, in
banking institutions in the State of Missouri.
2.
Obligations of the United States
Government or any agency or instrumentality thereof maturing and becoming
payable not more than five (5) years from purchase.
3.
Repurchase agreements maturing and
becoming payable within ninety (90) days secured by United States
Treasury obligations (a Master Repurchase Agreement must be signed
with the bank or dealer). Overnight and open repurchase agreements
must be collateralized one hundred percent (100%) with approved securities.
B. Investment Types. In accordance with and
subject to restrictions imposed by current Statutes, the following
list represents the entire range of investments that City will consider
and which shall be authorized for the investments of funds by the
City.
1.
United States Treasury Securities.
The City may invest in obligations of the United States Government
for which the full faith and credit of the United States are pledged
for the payment of principal and interest.
2.
United States Agency Securities.
The City may invest in obligations issued or guaranteed by any agency
of the United States Government as described in V. (2).
3.
Repurchase Agreements. The City may
invest in contractual agreements between the City and commercial banks
or primary government securities dealers. The purchaser in a repurchase
agreement (repo) enters into a contractual agreement to purchase U.S.
Treasury and government agency securities while simultaneously agreeing
to resell the securities at predetermined dates and prices.
4.
Collateralized Public Deposits (Certificates
Of Deposit). Instruments issued by financial institutions which state
that specified sums have been deposited for specified periods of time
and at specified rates of interest. The certificates of deposit are
required to be backed by acceptable collateral securities as dictated
by State Statute.
C. The following investments are strictly
prohibited:
1.
Borrowing for investment purposes
("leverage").
2.
Instruments known as "structured
notes" (e.g., inverse leveraged floaters and equity-linked securities).
Any instrument which is considered a "derivative" instrument (e.g.,
options, futures, swaps, caps, floors and collars).
3.
Contracting to sell securities not
yet acquired in order to purchase other securities for purposes of
speculating on development or trends in the market.
[R.O. 2016 § 160.110; Ord. No. 848-09 § 1, 6-9-2009]
A. Collateralization will be required on two
(2) types of investments: certificates of deposit and repurchase agreements.
The market value (including accrued interest) of the collateral should
be at least one hundred percent (100%).
B. For certificates of deposit, the market
value of collateral must be at least one hundred percent (100%) or
greater of the amount of certificates of deposits plus demand deposits
with the depository, less the amount, if any, which is insured by
the Federal Deposit Insurance Corporation or the National Credit Unions
Share Insurance Fund.
C. All securities, which serve as collateral
against the deposits of a depository institution, must be kept safe
at a non-affiliated custodial facility. Depository institutions pledging
collateral against deposits must, in conjunction with the custodial
agent, furnish the necessary custodial receipts within five (5) business
days from the settlement date.
D. The City shall have a depositary contract
and pledge agreement with each safekeeping bank that will comply with
the Financial Institutions, Reform, Recovery and Enforcement Act of
1989 (FIRREA). This will ensure that the City's security interest
in collateral pledged to secure deposits is enforceable against the
receiver of a failed financial institution.
E. All deposits placed in financial institutions
must be at least one hundred percent (100%) collateralized with securities
which are acceptable to the State Treasurer.
[R.O. 2016 § 160.120; Ord. No. 848-09 § 1, 6-9-2009]
To the extent possible, the City
will attempt to match its investments with anticipated cash flow requirements.
To provide sufficient liquidity, the City will invest primarily in
securities maturing no more than one (1) year from the date of purchase.
Longer-term investments with maturities of no more than five (5) years
may consider for the City's Retirement Trust Fund.
[R.O. 2016 § 160.130; Ord. No. 848-09 § 1, 6-9-2009]
A. The investment officer shall prepare an
investment report at least quarterly, including a management summary
that provides an analysis of the status of the current investment
portfolio and transactions made over the last quarter. This management
summary will be prepared in a manner that will allow the City of Park
Hills to ascertain whether investment activities during the reporting
period have conformed to the investment policy. The report should
be provided to the Governing Body of the City of Park Hills. The report
will include the following:
1.
Listing of individual securities
held at the end of the reporting period.
2.
Realized and unrealized gains or
losses resulting from appreciation or depreciation by listing the
cost and market value of securities over one (1) year duration [in
accordance with Government Accounting Standards Board (GASB) 31 requirements].
(Note, this is only required annually.)
3.
Average weighted yield to maturity
of portfolio on investments as compared to applicable bench marks.
4.
Listing of investment by maturity
date.
5.
Percentage of the total portfolio
which each type of investment represents.
[R.O. 2016 § 160.140; Ord. No. 848-09 § 1, 6-9-2009]
The City of Park Hills Investment
Policy shall be adopted by ordinance of the City Council. The policy
shall be reviewed periodically by the Investment Committee and any
recommended changes will be presented to the City Council for consideration.