[HISTORY: Adopted by the Town Board of the Town of Catskill 11-6-1995. Amendments noted where applicable.]034a Appendix A
This investment policy applies to all moneys and other financial resources available for investment on the town's own behalf or on behalf of any other entity or individual.
The primary objectives of the Town of Catskill's investment activities are, in priority order:
The governing board's responsibility for administration of the investment program is delegated to the person designated at the annual organizational meeting 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 to 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 Town of Catskill to govern effectively.
Investments shall be made with judgment and care, under circumstances then prevailing, which persons of prudence 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 Town of Catskill to diversify its deposits and investments by financial institution, by investment instrument and by maturity scheduling where necessary in order to properly secure or collateralize the same.
It is the policy of the Town of Catskill for all moneys collected by any officer or employee of the town to be transferred to the Chief Fiscal Officer within three business days of receipt.
The person designated is responsible for establishing and maintaining an internal control structure to provide reasonable, but not absolute, assurance that deposits and investments are safeguarded against loss from unauthorized use or disposition, that transactions are executed in accordance with management's authorization and recorded properly, and are managed in compliance with applicable laws and regulations.
The banks and trust companies authorized for the deposit of moneys are those designated at the annual organizational meeting. A resolution must specify the maximum amount which may be kept on deposit at any time in each bank or trust company (General Municipal Law § 10, Subdivision 2a).
In accordance with the provisions of General Municipal Law § 10, all deposits of the town, including certificates of deposit and special time deposit, in excess of the amount insured under the provisions of the Federal Deposit Insurance Act shall be secured by a pledge of eligible securities (Appendix A) with an aggregate market value of a two-percent excess of the principal amount of funds invested. Collateral will be monitored on a monthly basis.
Collateral will not be required with respect to the direct purchase of obligations of New York State, the United States and federal agencies, the principal and interest of which are guaranteed by the United States government.
Eligible securities used for collateralizing deposits shall be held by the depository and/or a third-party bank or trust company subject to security and custodial agreements.
The custodial agreement shall provide that securities held by the bank or trust company, or agent of and custodian for the town, will be kept separate and apart from the general assets of the custodial bank or trust company and will not, in any circumstances, be commingled with or become part of the backing for any other deposit or other liabilities. The agreement should also describe that the custodian shall confirm the receipt, substitute or release of the securities.
The agreement shall provide for the frequency of revaluation of eligible securities and for the substitution of securities when a change in the rating of a security may cause ineligibility. Such agreement shall include all provisions necessary to provide the town a perfected interest in the securities.
As authorized by General Municipal Law § 11, Subdivisions 2 and 3, the town authorizes the designated person to invest moneys not required for immediate expenditure for terms not to exceed its projected cash flow needs in the following types of investments:
Special time deposit accounts issued by a bank or trust company authorized to do business in New York State;
Certificates of deposit;
Obligations of the United States of America;
Obligations guaranteed by agencies of the United States of America where the payment of principal and interest is guaranteed by the United States of America, subject to General Municipal Law § 11, Subdivision 3a and b;
Obligations of the State of New York, subject to provisions of General Municipal Law § 11, Subdivision 3a and b;
All investment obligations shall be payable or redeemable at the option of the town within such times as the proceeds will be needed to meet expediters for purposes for which the moneys were provided and, in the case of obligations purchased with the proceeds of bonds or notes, shall be payable or redeemable at the option of the Town of Catskill within two years of the date of purchase.
The town 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 town 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 dealers. The Chief Fiscal Officer 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.
All purchased obligations, unless registered or inscribed in the name of the local government, shall be purchased through, delivered to and held in the custody of a bank or trust company.
Such obligations shall be purchased, sold or presented for redemption or payment by such bank or trust company only in accordance with prior written authorization from the officer authorized to make the investment. All such transactions shall be confirmed, in writing, to the town by the bank or trust company. Any obligation held in the custody of a bank or trust company shall be held pursuant to a written custodial agreement as described in General Municipal Law § 10.
The custodial agreement shall provide that securities held by the bank or trust company, as agent of and custodian for the local government, will be kept separate and apart from the general assets of the custodial bank or trust company and will not, in any circumstances, be commingled with or become part of the backing for any other deposit or other liabilities. The agreement shall describe how the custodian shall confirm the receipt and release of the securities. Such agreement shall include all provisions necessary to provide the town a perfected interest in the securities.