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); and
D. To obtain a reasonable rate of return (yield).
The governing board's responsibility for administration
of the investment program is delegated to the Supervisor, who shall
establish written procedures for the operation of the investment program
consistent with these investment guidelines. Such procedures all 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 of Greenwich 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
monies are those designated at the Annual Organizational Meeting of
the Town of Greenwich.
In accordance with the provisions of General Municipal Law § 10,
all deposits of the Town of Greenwich, 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 by:
A. A pledge of eligible securities with an aggregate market value as
provided by GML § 10, equal to the aggregate amount of deposits
from the categories designated by Appendix A to the policy.
B. 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. 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 of Greenwich 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 (Call Report) at
the request of the Town of Greenwich. 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 depositaries, 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.