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 City of Lackawanna'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 City Council's responsibility for administration
of the investment program is delegated to the City Comptroller who
shall establish written procedures for the operation of the investment
program consistent with these investment guidelines. Such written
procedures shall be presented to the City Council for review and approval.
Should changes to the procedure be necessary, the City Comptroller
shall promptly notify the City Council as to the modifications considered.
The 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 as well as regulating
the activities of subordinate employees.
It is the policy of the City of Lackawanna 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 up to the maximum amounts are:
Depository Name
|
Maximum Amount
|
---|
Key Bank
|
$10,000,000
|
M & T Trust Co.
|
$10,000,000
|
Chemical (Chase) Bank
|
$10,000,000
|
HSBC Bank
|
$10,000,000
|
In accordance with the provisions of General
Municipal Law § 10, all deposits of the City of Lackawanna,
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:
A. By a pledge of eligible securities with an aggregate
market value, as provided by General Municipal Law § 10,
at least equal to the aggregate amount of deposits and interest accrued
on such City deposits. The categories of eligible securities are designated
in Appendix A to the policy.
B. By an eligible irrevocable letter of credit issued
by a qualified bank other than the bank with the deposits in favor
of the City 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. By an eligible surety bond payable to the City 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 City of Lackawanna 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 City of Lackawanna.
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 City Comptroller is responsible
for evaluating the financial position and maintaining a listing of
proposed depositaries, trading partners and custodians. Such listings
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, where the payment of principal and interest
are guaranteed by 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.