[Ord. No. 433 §1, 10-12-2009]
A. Scope. This policy applies to the investment of all operating
funds of the City.
1. Pooling of funds. Except for cash in certain restricted
and special funds, the City will consolidate cash balances from all
funds to maximize investment earnings. Investment income will be allocated
to the various funds based on their respective participation and in
accordance with generally accepted accounting principles.
2. External management of funds. Investment through
external programs, facilities and professionals operating in a manner
consistent with this policy will constitute compliance.
B. General Objectives.
1. Safety. Safety of principal is the foremost objective
of the investment program. Investments shall be undertaken in a manner
that seeks to ensure the preservation of capital in the overall portfolio.
The objective will be to minimize credit risk and interest rate risk.
a. Credit risk. The City will minimize credit risk,
the risk of loss due to the failure of the security issuer or backer,
by:
(1)
Prequalifying the financial institutions, brokers/dealers, intermediaries
and advisors with which the City will do business.
(2)
Diversifying the portfolio so that potential losses on individual
securities will be minimized.
b. Interest rate risk. The City will minimize the risk
that the market value of securities in the portfolio will fall due
to changes in general interest rates by:
(1)
Structuring the investment portfolio so that securities mature
to meet cash requirements for ongoing operations, thereby avoiding
the need to sell securities on the open market prior to maturity.
(2)
Investing operating funds primarily in short-term securities.
2. Liquidity. The investment portfolio shall remain
sufficiently liquid to meet all operating requirements that may be
reasonably anticipated. This is to be accomplished by structuring
the portfolio so that securities mature concurrent with cash needs
to meet anticipated demands.
3. Yield. The investment portfolio shall be designed
with the objectives of attaining a market rate of return throughout
budgetary and economic cycles, taking into account the investment
risk constraints and liquidity needs. Return on investment is of secondary
importance to the safety and liquidity objectives described above.
The core of investments are to be limited to relatively low risk securities
in anticipation of earning a fair return relative to the risk being
assumed. Securities shall not be sold prior to maturity with the following
exceptions:
a. A security with declining credit may be sold early to minimize loss
of principal;
b. A security swap intended to improve the quality, yield or target
duration;
c. Liquidity needs of the portfolio require that the security be sold.
C. Standards Of Care.
1. Prudence. 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.
2. Ethics and conflicts of interest. Officers and employees
involved in the investment process shall refrain from personal business
activity that could conflict with the proper execution and management
of the investment program or that could impair their ability to make
impartial decisions. Employee and investment officials shall disclose
any material interests in financial institutions in which they conduct
business. They shall further disclose any personal financial/investment
positions that could be related to the performance of the investment
portfolio. Employees and officials shall refrain from undertaking
personal investment transactions with the same individual with which
business is conducted on behalf of the City.
3. Delegation of authority. Authority to manage the
investment program is granted to the Mayor, with the advice and consent
of the Board of Alderpersons, hereinafter referred to as investment
officer and derived from the State Statutes or Constitution. 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 versus 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.
D. Investment Transactions — Controls.
1. The investment officer is responsible for establishing and maintaining
an internal control structure that will be reviewed annually with
the City's independent auditor. The internal control structure shall
be designed to ensure that the assets of the City are protected from
loss, theft or misuse and to provide reasonable assurance that these
objectives are met. The concept of reasonable assurance recognizes
that:
a. The cost of control should not exceed the benefits likely to be derived;
and
b. The valuation of costs and benefits require estimates and judgments
by management.
2. The internal controls shall address the following points:
b. Separation of transaction authority from accounting and record keeping;
d. Clear delegation of authority to subordinate staff members;
e. Written confirmation of transactions for investments and wire transfers;
and
f. Development of a wire transfer agreement.
E. Suitable And Authorized Investments.
1. Investment types. In accordance with and subject
to restrictions imposed by current Statutes, the following list represents
the entire range of investments that the City will consider and which
shall be authorized for the investments of funds by the City.
a. 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 interest.
b. United States agency securities. The City may invest
in obligations issued or guaranteed by any agency of the United States
Government.
c. 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 Treasury and government
agency securities while simultaneously agreeing to resell the securities
at predetermined dates and prices.
d. Collateralized public deposits. Instruments issued
by financial institutions which state that specified sums have been
deposited for specified periods of time and at specified rates of
interest. Such deposits are required to be backed by acceptable collateral
securities as dictated by State Statute.
e. Banker's acceptance. Time drafts drawn on and accepted
by a commercial bank, otherwise known as bankers' acceptances. The
City may invest in bankers' acceptances issued by domestic commercial
banks possessing the highest rating issued by Moody's Investor Services,
Inc. or Standard and Poor's Corporation.
f. Commercial paper. The City may invest in commercial
paper issued by domestic corporations, which has received the highest
rating issued by Moody's Investor Services, Inc., or Standard and
Poor's Corporation. Eligible paper is further limited to issuing corporations
that have total assets in excess of five hundred million dollars ($500,000,000.00).
2. Investment restrictions and prohibited transactions. To provide for the safety and liquidity of the City's funds, the
investment portfolio will be subject to the following restriction:
a. Borrowing for investment purposes ("leverage") is prohibited.
(1)
Instruments known as structured notes (e.g., inverse floaters,
leveraged floaters and equity-linked securities) are not permitted.
Investment in any instrument which is commonly considered a "derivative"
investment (e.g., options, futures, swaps, caps, floors and collars)
is prohibited.
(2)
Contracting to sell securities not yet acquired in order to
purchase other securities for purposes of speculating on developments
or trends in the market is prohibited.
b. No more than twenty percent (20%) of the total market value of the
portfolio may be invested in commercial paper at any one time.
F. Collateralization.
1. Collateralization will be required on two (2) types of investments:
certificates of deposit and repurchase agreements. In order to anticipate
market changes and provide a level of security for all funds, the
market value (including accrued interest) of the collateral should
be at least one hundred percent (100%).
2. 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 Corporation
or the National Credit Unions Share Insurance Fund.
3. All securities, which serve as collateral against the deposits of
a depository institution, must be safe kept 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.
4. 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 pledge to secure deposits
is enforceable against the receiver of a failed financial institution.
G. Repurchase Agreements. The securities for which repurchase
agreements will be transacted will be limited to Treasury and government
agency securities that are eligible to be delivered via the Federal
Reserve's Fedwirebook entry system. Securities will be delivered to
the City's designated custodial agent. Funds and securities will be
transferred on a delivery versus payment basis.
H. Investment Parameters.
1. Maximum maturities.
a. To the extent possible, the City shall attempt to match its investments
with anticipated cash flow requirements. Investments in bankers' acceptances
and commercial paper shall mature and become payable not more than
one hundred eighty (180) days from the date of purchases. All other
investments shall mature and become payable not more than three (3)
years from the date of purchase.
b. Because of inherent difficulties in accurately forecasting cash flow
requirements, a portion of the portfolio should be continuously invested
in readily available funds such as in bank deposits or overnight repurchase
agreements to ensure that appropriate liquidity is maintained to meet
ongoing obligations.
c. Reporting methods. The investment officer will prepare
an investment report 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 to ascertain
whether investment activities during the reporting period have conformed
to the investment policy. The report shall be provided to the Board
of Alderpersons.
[Ord. No. 433 §1, 10-12-2009]
A. Objective. The objective of this policy is to establish
guidelines for the acquisition, accounting and disposal for and of
capital assets of the City.
B. Definition Of Responsibilities. It is the responsibility
of the City Board of Alderpersons to appoint such City staff as the
Board deems necessary to accomplish the objectives of this policy,
to devise such systems and procedures necessary to insure that the
policy is implemented, and to conduct periodic inventories of the
assets of the City and report to the Board of Alderpersons the findings
of those inventories and to explain any discrepancies discovered.
The Board is also responsible for such periodic reviews necessary
to insure that the policies detailed are complied with in full.
C. Recognizing
that governmental standards for accounting and reporting of capital
assets and treatment are changed and modified from time to time by
proper authority, the Board of Alderpersons may by resolution adopt
current policy statements and guidance pursuant to this Section.