[HISTORY: Adopted by the Town Board of the Town of Catskill 11-6-1995.
Amendments noted where applicable.]
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.
A.
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.
B.
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.
C.
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.
A.
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.
B.
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).
A.
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[1]) 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.
[1]
Editor's Note: Appendix A is included at the end of this chapter.
B.
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.
A.
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.
B.
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.
C.
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.
A.
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:
(1)
Special time deposit accounts issued by a bank or trust
company authorized to do business in New York State;
(2)
Certificates of deposit;
(3)
Obligations of the United States of America;
(4)
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;
(5)
Obligations of the State of New York, subject to provisions
of General Municipal Law § 11, Subdivision 3a and b;
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.
A.
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.
B.
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.
C.
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.
