HomeMy WebLinkAboutFin City Investment Policy 2017SAN RAFAEL
THE CITY WITH A MISSION
Agenda Item No: 4.b
Meeting Date: August 7, 2017
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: Finance P -
Prepared by: Mark Moses, City Manager Approval:
Finance Director
TOPIC: CITY INVESTMENT POLICY
SUBJECT: ANNUAL REVIEW AND RESOLUTION TO APPROVE THE CITY'S INVESTMENT
POLICY
RECOMMENDATION: ACCEPT REPORT AND ADOPT RESOLUTIONS AS PRESENTED
BACKGROUND: Consistent with best public investing practices and the City's investment policy, a
review of the content of the investment policy is conducted annually.
The purpose of this report is to provide the City Council with an opportunity to review the City's current
cash and investment management policies, changes recommended by the City's investment advisor
and staff, and to formally approve the policy.
In January 2005, the City engaged Cutwater Asset Management to manage the long-term portion of the
City's investment portfolio (Cutwater Asset Management transitioned to Insight Investment in 2015).
These services were suspended in December 2011 because the City did not have sufficient cash to
invest long-term under this advisory structure. The growth in fund balances since that time prompted
the City to revive its contract with Cutwater beginning in March 2014. One of the services that Cutwater
provides is assistance with the annual review of the City's investment policy. The policy was last
reviewed on June 20, 2016.
ANALYSIS: The California State Code limits the types of investments open to local municipalities. The
City's investment priorities — in order - are safety, liquidity and yield. The City pursues a fair market
return on its investments after considering the security of investment principal, cash flow requirements
and current investment portfolio structure.
There are no proposed changes to authorized investments. The City's investment advisor suggested
only minor edits to clarify that they types of securities held under money market funds are limited to
U.S. Treasury, Agency and Federal Instrumentalities.
FISCAL IMPACT: There is no direct fiscal impact from accepting the policy as proposed.
FOR CITY CLERK ONLY
File No.: 8-9 x 8-18
Council Meeting: 08/07/2017
Disposition: Resolution 14374
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
RECOMMENDATION: Staff recommends that the City Council accept the report and adopt the
Resolution as presented.
ATTACHMENT:
Investment Policy with changes tracked
Resolution with Exhibit A
RESOLUTION NO. 14374
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL TO APPROVE
THE CITY OF SAN RAFAEL INVESTMENT POLICY
WHEREAS, the City Council of the City of San Rafael takes seriously its stewardship of
the City's public resources and City's current cash management practices; and
WHEREAS, the City's Investment Policy requires consideration and approval of the
investment policy annually; and
WHEREAS, all funds are invested in accordance with the investment policy and applicable
sections of the California Government Code; and
WHEREAS, the investment policy is intended to provide a long-term strategy for prudent
care of the City's cash.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of San Rafael
hereby adopts the updated Investment Policy that is attached hereto as Exhibit A.
I, ESTHER C. BEIRNE, Clerk of the City of San Rafael, hereby certify that the foregoing
resolution was duly and regularly introduced and adopted at a regular meeting of the City Council
of said City held on Monday the 7th day of August, 2017, by the following vote, to wit:
AYES: COUNCILMEMBERS: Bushey, Colin, Gamblin and Mayor Phillips
NOES: COUNCILMEMBERS: None
ABSENT: COUNCILMEMBERS: McCullough
=%;3-g e . ,e
ESTHER C. BEIRNE, City Clerk
City of San Rafael Investment Policy
PROPOSED August 7, 2017
The City Council of the City of San Rafael (the City) has adopted this Investment Policy (the
Policy) in order to establish the investment scope, objectives, delegation of authority,
standards of prudence, reporting requirements, internal controls, eligible investments and
transactions, diversification requirements, risk tolerance, and safekeeping and custodial
procedures for the investment of the funds of the City. All such funds will be invested in
accordance with this Policy and with applicable sections of the California Government Code.
This Policy was endorsed and adopted by the City Council on the approved date noted
above. It replaces any previous investment policy or investment procedures of the City.
SCOPE
It is intended that this Policy cover all short-term operating funds and investment activities of
the City. These funds are accounted for in the annual audit report, and include:
• General Fund
• Special Revenue Funds
• Debt Service Funds
• Capital Projects Funds
• Enterprise Funds
• Internal Service Funds
• Fiduciary Funds
Additional funds that may be created from time to time shall be administered in accordance
with the provisions of this Policy.
All cash shall be pooled for investment purposes. The investment income derived from the
pooled investment account shall be allocated to the contributing funds based upon the
proportion of the respective average balances relative to the total pooled balance in the
investment portfolio. Investment income shall be distributed to the individual funds not less
than annually.
OBJECTIVES
The City's funds shall be invested in compliance with all applicable City Municipal Codes,
California State statutes, and Federal regulations, and in a manner designed to accomplish
the following objectives, which are listed in priority order:
1. Preservation of capital and protection of investment principal.
2. Maintenance of sufficient liquidity to meet anticipated cash flows.
3. Attainment of a market value rate of return.
4. Diversification to avoid incurring unreasonable market risks.
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City of San Rafael
Investment Policy
August 7, 2017
DELEGATION OF AUTHORITY
The management responsibility for the City's investment program is delegated annually by
the City Council to the Treasurer pursuant to California Government Code Section 53607.
The Treasurer may delegate the authority to conduct investment transactions and to
manage the operation of the investment portfolio to other specifically authorized staff
members. The Treasurer shall maintain a list of persons authorized to transact securities
business for the City. No person may engage in an investment transaction except as
expressly provided under the terms of this Policy.
The City Manager and the Treasurer jointly shall develop written administrative procedures
and internal controls, consistent with this Policy, for the operation of the City's investment
program. Such procedures shall be designed to prevent losses of public funds arising from
fraud, employee error, misrepresentation by third parties, or imprudent actions by
employees of the City.
The City may engage the support services of outside investment advisors in regard to its
investment program, so long as it can be clearly demonstrated that these services produce
a net financial advantage or necessary financial protection of the City's financial resources.
PRUDENCE
The standard of prudence to be used for managing the City's investments shall be California
Government Code Section 53600.3, the prudent investor standard which states, "When
investing, reinvesting, purchasing, acquiring, exchanging, selling, or managing public funds,
a trustee shall act with care, skill, prudence, and diligence under the circumstances then
prevailing, including, but not limited to, the general economic conditions and the anticipated
needs of the agency, that a prudent person acting in a like capacity and familiarity with those
matters would use in the conduct of funds of a like character and with like aims, to
safeguard the principal and maintain the liquidity needs of the agency."
The City's overall investment program shall be designed and managed with a degree of
professionalism that is worthy of the public trust. The City recognizes that no investment is
totally without risk and that the investment activities of the City are a matter of public record.
Accordingly, the City recognizes that occasional measured losses may be desirable in a
diversified portfolio and shall be considered within the context of the overall portfolio's return,
provided that adequate diversification has been implemented and that the sale of a security
is in the best long-term interest of the City.
The Treasurer and authorized investment personnel acting in accordance with written
procedures and exercising due diligence shall be relieved of personal responsibility for an
individual security's credit risk or market price changes, provided that the deviations from
expectations are reported in a timely fashion to the City Manager and appropriate action is
taken to control adverse developments.
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City of San Rafael
Investment Policy
August 7, 2017
ETHICS AND CONFLICTS OF INTEREST
Elected officials and employees involved in the investment process shall refrain from
personal business activity that could conflict with proper execution of the investment
program or that could impair or create the appearance of an impairment of their ability to
make impartial investment decisions. Employees and investment officials shall disclose to
the City Manager any business interests they have in financial institutions that conduct
business with the City and they shall subordinate their personal investment transactions to
those of the City. In addition, the City Manager and the Treasurer shall file a Statement of
Economic Interests each year pursuant to California Government Code Section 87203 and
regulations of the Fair Political Practices Commission.
AUTHORIZED SECURITIES AND TRANSACTIONS
All investments and deposits of the City shall be made in accordance with California
Government Code Sections 16429.1, 53600-53609 and 53630-53686, except that, pursuant
to California Government Code Section 5903(e), proceeds of bonds and any moneys set
aside or pledged to secure payment of the bonds may be invested in securities or
obligations described in the ordinance, resolution, indenture, agreement, or other instrument
providing for the issuance of the bonds. Any revisions or extensions of these code sections
will be assumed to be part of this Policy immediately upon being enacted. However, in the
event that amendments to these sections conflict with this Policy and past City investment
practices, the City may delay adherence to the new requirements when it is deemed in the
best interest of the City to do so. In such instances, after consultation with the City's
attorney, the City Manager and the Treasurer will present a recommended course of action
to the City Council for approval.
The City has further restricted the eligible types of securities and transactions as follows:
1. United States Treasury bills, notes and bonds with a final maturity not exceeding five
years from the date of trade settlement.
2. Federal Aaencv debentures and mortgage-backed securities with a final maturity not
exceeding five years from the date of trade settlement.
3. Federal Instrumentalitv (government sponsored enterprise) debentures, discount notes,
callable and step-up securities, with a final maturity not exceeding five years from the
date of trade settlement.
4. Medium -Term Notes issued by corporations organized and operating within the United
States or by depository institutions licensed by the United States or any state and
operating within the United States, with a final maturity not exceeding five years from the
date of trade settlement, and rated at least "A" or the equivalent by a NRSRO. No more
than 5% of the portfolio shall be invested in medium-term notes of any one issuer, and
the aggregate investment in medium-term notes shall not exceed 30% of the City's total
portfolio.
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City of San Rafael
Investment Policy
August 7, 2017
5. Negotiable Certificates of Deposits (CDs) of commercial banks rated at least A-1, or the
equivalent, with maturities not exceeding five years from the date of trade settlement. In
addition, the City may not invest in the CD of a state or federal credit union where any
person with investment decision making authority at the City also serves on the board of
directors, or any committee appointed by the board of directors, or the credit committee
or the supervisory committee of the state or federal credit union issuing the negotiable
certificates of deposit. No more than 5% of the portfolio may be invested in the CDs of
any one issuer, and the aggregate investment in CDs shall not exceed 30% of the
portfolio.
6. Non-neaotiable Certificates of Deposit and savings deposits with a maturity not
exceeding five years from the date of trade settlement, in FDIC insured state or
nationally chartered banks or savings banks that qualify as a depository of public funds
in the State of California as defined in California Government Code Section 53630.5. No
more than 5% of the portfolio may be invested in the CDs of any one issuer, and the
aggregate investment in CDs shall not exceed 30% of the portfolio.
Deposits in excess of the insured amount shall be secured pursuant to California
Government Code Section 53651 and 53652. The City shall comply with and act to
secure compliance with the security (collateralization) system specified in the
Government Code Section 53649 and 56652.
7. Deposits may be placed using a private sector entity that assists in the placement of
deposits per section 53601.8 and 53635.8 in the Government Code. No more than 5% of
the portfolio may be invested through any one private sector entity that assists in the
placement of such deposits and the aggregate investment in CDs shall not exceed 30%
of the portfolio.
8. Special Assessment District Obliaations issued by the City of San Rafael as Limited
Obligation Improvement Bonds related to special assessment districts and special tax
districts. Investment in such obligations requires the approval of the City Council and
maturities may extend to 30 years from the date of trade settlement.
9. Prime Commercial Paper with a maturity not exceeding 270 days from the date of
purchase with the highest ranking or of the highest letter and number rating as provided
for by a NRSRO. The entity that issues the commercial paper shall meet all of the
following conditions in either sub -paragraph A. or sub -paragraph B. below:
A. The entity shall (1) be organized and operating in the United States as a
general corporation, (2) have total assets in excess of five $500,000,000 and
(3) Have debt other than commercial paper, if any, that is rated "A" or higher
by a NRSRO.
B. The entity shall (1) be organized within the United States as a special
purpose corporation, trust, or limited liability company, (2) have program -wide
credit enhancements, including, but not limited to, over collateralization,
letters of credit or surety bond and (3) have commercial paper that is rated
"A-1" or higher, or the equivalent, by a NRSRO.
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City of San Rafael
Investment Policy
August 7, 2017
Purchases of eligible commercial paper may not represent more than 10% of the
outstanding commercial paper of any single corporate issuer. No more than 5% of the
City's total portfolio, shall be invested in the commercial paper of any one issuer, and the
aggregate investment in commercial paper shall not exceed 25% of the City's total
portfolio.
10. Eligible Banker's Acceptances issued by FDIC insured commercial banks, rated at least
A-1 or the equivalent by a NRSRO with maturities not exceeding 180 days from the date
of purchase. If issuers have senior debt outstanding, it shall be rated at least A or the
equivalent by a NRSRO. No more than $2,000,000 shall be invested in banker's
acceptances of any one commercial bank, and the aggregate investment in banker's
acceptances shall not exceed 40% of the City's total portfolio.
11. Repurchase Aqreements with a final termination date not exceeding one year
collateralized by U.S. Treasury obligations, Federal Agency securities, or Federal
Instrumentality securities listed in items 1, 2 and 3 above with the maturity of the
collateral not exceeding five years. For the purpose of this section, the term collateral
shall mean purchased securities under the terms of the City's approved Master
Repurchase Agreement. The purchased securities shall have a minimum market value
including accrued interest of 102% of the dollar value of the funds borrowed. Collateral
shall be held in the City's custodian bank, as safekeeping agent, and the market value of
the collateral securities shall be marked -to -the -market daily.
Repurchase Agreements shall be entered into only with broker/dealers who are
recognized as Primary Dealers by the Federal Reserve Bank of New York or have a
primary dealer within their holding company structure. Repurchase agreement
counterparties shall execute a City approved Master Repurchase Agreement with the
City. The Treasurer shall maintain a copy of the City's approved Master Repurchase
Agreement along with a list of the broker/dealers who have executed same.
12. State of California's Local Aaencv Investment Fund (LAIF), pursuant to California
Government Code Section 16429.1.
13. Monev Market Funds registered under the Investment Company Act of 1940 that (1) are
"no-load" (meaning no commission or fee shall be charged on purchases or sales of
shares); (2) have a constant daily net asset value per share of $1.00; (3) invest only in
United States Treasury securities, United States Agency securities and Federal
Instrumentality securities and (4) have a rating of at least AAA or the equivalent by at
least two NRSROs. The aggregate investment in money market funds shall not exceed
10% of the City's total portfolio.
It is the intent of the City that the foregoing list of authorized securities and transactions is
strictly interpreted. Any deviation from this list must be preapproved by resolution of the City
Council.
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City of San Rafael
Investment Policy
August 7, 2017
PORTFOLIO MATURITIES AND LIQUIDITY
To the extent possible, investments shall be matched with anticipated cash flow
requirements and known future liabilities. The City will not invest in securities maturing more
than five years from the date of purchase, unless the City Council has by resolution granted
authority to make such an investment at least three months prior to the date of investment.
SELECTION OF BROKER/DEALERS
The Treasurer shall maintain a list of broker/dealers authorized for investment purposes,
and it shall be the policy of the City to purchase securities only from those authorized firms.
To be eligible, a firm must be licensed by the State of California as a broker/dealer as
defined in Section 25004 of the California Corporations Code, and:
1. be recognized as a Primary Dealer by the Federal Reserve Bank of New York or have a
primary dealer within its holding company structure, or
2. report voluntarily to the Federal Reserve Bank of New York, or
3. qualify under Securities and Exchange Commission (SEC) Rule 15c3-1 (Uniform Net
Capital Rule).
The City may engage the services of investment advisory firms to assist in the management
of the portfolio and investment advisors may utilize their own list of approved
Broker/Dealers. Such Broker/Dealers will comply with the selection criteria above and the
list of approved firms shall be provided to the City on an annual basis or upon request.
In the event that an external investment advisor is not used in the process of recommending
a particular transaction in the City's portfolio, authorized broker/dealers shall attest in writing
that they have received and reviewed a copy of this policy and annually update a City
approved Broker/Dealer Information Request form which includes the firm's most recent
financial statements. The Treasurer shall maintain a list of the broker/dealers that have
been approved by the City, along with each firm's most recent broker/dealer Information
Request form.
The City may purchase commercial paper from direct issuers even though they are not on
the approved broker/dealer list as long as they meet the criteria outlined in Item 5 of the
Authorized Securities and Transactions section of this Policy.
COMPETITIVE TRANSACTIONS
Each investment transaction shall be competitively transacted with authorized
broker/dealers. At least three broker/dealers shall be contacted for each transaction and
their bid and offering prices shall be recorded.
If the City is offered a security for which there is no other readily available competitive
offering, the Treasurer will document quotations for comparable or alternative securities.
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City of San Rafael
Investment Policy
August 7, 2017
SELECTION OF BANKS
The Treasurer shall maintain a list of banks that are approved to provide banking services
for the City. To be eligible for authorization, a bank must be a member of the FDIC and
shall qualify as a depository of public funds in the State of California as defined in California
Government Code Section 53630.5.
SAFEKEEPING AND CUSTODY
The Treasurer shall select one or more banks to provide safekeeping and custodial services
for the City, in accordance with the provisions of Section 53608 of the California
Government Code. A Safekeeping Agreement approved by the City shall be executed with
each custodian bank prior to utilizing that bank's safekeeping services. Custodian banks will
be selected on the basis of their ability to provide services for the City's account and the
competitive pricing of their safekeeping related services.
The purchase and sale of securities and repurchase agreement transactions shall be settled
on a delivery versus payment basis. All securities shall be perfected in the name of the City.
Sufficient evidence to title shall be consistent with modern investment, banking and
commercial practices.
All investment securities purchased by the City will be delivered by book entry and will be
held in third -party safekeeping by a City approved custodian bank, or its Depository Trust
Company (DTC) participant account.
The City's custodian shall be required to furnish the City a list of holdings on at least a
monthly basis and safekeeping receipts or customer confirmations shall be issued for each
transaction.
PORTFOLIO PERFORMANCE
The investment portfolio shall be designed to attain a market rate of return throughout
budgetary and economic cycles, taking into account prevailing market conditions, risk
constraints for eligible securities, and cash flow requirements. The performance of the City's
investments shall be compared to the average yield on the U.S. Treasury security that most
closely corresponds to the portfolio's actual weighted average effective maturity. When
comparing the performance of the City's portfolio, its rate of return will be computed net of all
fees and expenses.
REPORTING
On a quarterly basis, the Treasurer shall submit to the Council a report of the investment
earnings and performance results of the City's investment portfolio. The report shall include
the following information:
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City of San Rafael
Investment Policy
August 7, 2017
1. Investment type, issuer, date of purchase, purchase price, date of maturity, par value,
current rate of interest and dollar amount invested in all securities, and investments and
monies held by the City;
2. A description of the funds, investments and programs;
3. A market value as of the date of the report (or the most recent valuation as to assets not
valued monthly) and the source of the valuation;
4. Overall portfolio yield based on historical cost;
5. Weighted average final maturity and weighted average effective maturity;
6. A statement of compliance with this Policy or an explanation for not -compliance;
7. A description of any of the City's funds, investments or programs that are under the
management of contracted parties, including lending programs; and
8. A statement of the ability to meet expenditure requirements for six months, as well as an
explanation of why money will not be available if that is the case.
The Treasurer shall submit to the Council a report of any changes affecting more than 15%
of the investment portfolio within 30 days of such change.
POLICY REVIEW
This Investment Policy shall be reviewed and approved by City Council annually to ensure
its consistency with the overall objectives of preservation of principal, liquidity, yield and
diversification and its relevance to current law and economic trends. Any additional
amendments to this Investment Policy shall be submitted to the City Council for approval.
Page 8
City of San Rafael Investment Policy
PROPOSED August 7, 2017
The City Council of the City of San Rafael (the City) has adopted this Investment Policy (the
Policy) in order to establish the investment scope, objectives, delegation of authority,
standards of prudence, reporting requirements, internal controls, eligible investments and
transactions, diversification requirements, risk tolerance, and safekeeping and custodial
procedures for the investment of the funds of the City. All such funds will be invested in
accordance with this Policy and with applicable sections of the California Government Code.
This Policy was endorsed and adopted by the City Council on the approved date noted
above. It replaces any previous investment policy or investment procedures of the City.
SCOPE
It is intended that this Policy cover all short-term operating funds and investment activities of
the City. These funds are accounted for in the annual audit report, and include:
• General Fund
• Special Revenue Funds
• Debt Service Funds
• Capital Projects Funds
• Enterprise Funds
• Internal Service Funds
• Fiduciary Funds
Additional funds that may be created from time to time shall be administered in accordance
with the provisions of this Policy.
All cash shall be pooled for investment purposes. The investment income derived from the
pooled investment account shall be allocated to the contributing funds based upon the
proportion of the respective average balances relative to the total pooled balance in the
investment portfolio. Investment income shall be distributed to the individual funds not less
than annually.
OBJECTIVES
The City's funds shall be invested in compliance with all applicable City Municipal Codes,
California State statutes, and Federal regulations, and in a manner designed to accomplish
the following objectives, which are listed in priority order:
1. Preservation of capital and protection of investment principal.
2. Maintenance of sufficient liquidity to meet anticipated cash flows.
3. Attainment of a market value rate of return.
4. Diversification to avoid incurring unreasonable market risks.
Page 1
City of San Rafael
Investment Policy
August 7, 2017
DELEGATION OF AUTHORITY
The management responsibility for the City's investment program is delegated annually by
the City Council to the Treasurer pursuant to California Government Code Section 53607.
The Treasurer may delegate the authority to conduct investment transactions and to
manage the operation of the investment portfolio to other specifically authorized staff
members. The Treasurer shall maintain a list of persons authorized to transact securities
business for the City. No person may engage in an investment transaction except as
expressly provided under the terms of this Policy.
The City Manager and the Treasurer jointly shall develop written administrative procedures
and internal controls, consistent with this Policy, for the operation of the City's investment
program. Such procedures shall be designed to prevent losses of public funds arising from
fraud, employee error, misrepresentation by third parties, or imprudent actions by
employees of the City.
The City may engage the support services of outside investment advisors in regard to its
investment program, so long as it can be clearly demonstrated that these services produce
a net financial advantage or necessary financial protection of the City's financial resources.
PRUDENCE
The standard of prudence to be used for managing the City's investments shall be California
Government Code Section 53600.3, the prudent investor standard which states, "When
investing, reinvesting, purchasing, acquiring, exchanging, selling, or managing public funds,
a trustee shall act with care, skill, prudence, and diligence under the circumstances then
prevailing, including, but not limited to, the general economic conditions and the anticipated
needs of the agency, that a prudent person acting in a like capacity and familiarity with those
matters would use in the conduct of funds of a like character and with like aims, to
safeguard the principal and maintain the liquidity needs of the agency."
The City's overall investment program shall be designed and managed with a degree of
professionalism that is worthy of the public trust. The City recognizes that no investment is
totally without risk and that the investment activities of the City are a matter of public record.
Accordingly, the City recognizes that occasional measured losses may be desirable in a
diversified portfolio and shall be considered within the context of the overall portfolio's return,
provided that adequate diversification has been implemented and that the sale of a security
is in the best long-term interest of the City.
The Treasurer and authorized investment personnel acting in accordance with written
procedures and exercising due diligence shall be relieved of personal responsibility for an
individual security's credit risk or market price changes, provided that the deviations from
expectations are reported in a timely fashion to the City Manager and appropriate action is
taken to control adverse developments.
Page 2
City of San Rafael
Investment Policy
August 7, 2017
ETHICS AND CONFLICTS OF INTEREST
Elected officials and employees involved in the investment process shall refrain from
personal business activity that could conflict with proper execution of the investment
program or that could impair or create the appearance of an impairment of their ability to
make impartial investment decisions. Employees and investment officials shall disclose to
the City Manager any business interests they have in financial institutions that conduct
business with the City and they shall subordinate their personal investment transactions to
those of the City. In addition, the City Manager and the Treasurer shall file a Statement of
Economic Interests each year pursuant to California Government Code Section 87203 and
regulations of the Fair Political Practices Commission.
AUTHORIZED SECURITIES AND TRANSACTIONS
All investments and deposits of the City shall be made in accordance with California
Government Code Sections 16429.1, 53600-53609 and 53630-53686, except that, pursuant
to California Government Code Section 5903(e), proceeds of bonds and any moneys set
aside or pledged to secure payment of the bonds may be invested in securities or
obligations described in the ordinance, resolution, indenture, agreement, or other instrument
providing for the issuance of the bonds. Any revisions or extensions of these code sections
will be assumed to be part of this Policy immediately upon being enacted. However, in the
event that amendments to these sections conflict with this Policy and past City investment
practices, the City may delay adherence to the new requirements when it is deemed in the
best interest of the City to do so. In such instances, after consultation with the City's
attorney, the City Manager and the Treasurer will present a recommended course of action
to the City Council for approval.
The City has further restricted the eligible types of securities and transactions as follows:
1. United States Treasury bills, notes and bonds with a final maturity not exceeding five
years from the date of trade settlement.
2. Federal Aaencv debentures and mortgage-backed securities with a final maturity not
exceeding five years from the date of trade settlement.
3. Federal Instrumentalitv (government sponsored enterprise) debentures, discount notes,
callable and step-up securities, with a final maturity not exceeding five years from the
date of trade settlement.
4. Medium -Term Notes issued by corporations organized and operating within the United
States or by depository institutions licensed by the United States or any state and
operating within the United States, with a final maturity not exceeding five years from the
date of trade settlement, and rated at least A "A" or the equivalent by a NRSRO. No
more than 5% of the portfolio shall be invested in medium-term notes of any one issuer,
and the aggregate investment in medium-term notes shall not exceed 30% of the City's
total portfolio.
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City of San Rafael
Investment Policy
August 7, 2017
5. Negotiable Certificates of Deposits (CDs) of commercial banks rated at least A-1, or the
equivalent, with maturities not exceeding five years from the date of trade settlement. In
addition, the City may not invest in the CD of a state or federal credit union where any
person with investment decision making authority at the City also serves on the board of
directors, or any committee appointed by the board of directors, or the credit committee
or the supervisory committee of the state or federal credit union issuing the negotiable
certificates of deposit. No more than 5% of the portfolio may be invested in the CDs of
any one issuer, and the aggregate investment in CDs shall not exceed 30% of the
portfolio.
6. Non-neaotiable Certificates of Deposit and savings deposits with a maturity not
exceeding five years from the date of trade settlement, in FDIC insured state or
nationally chartered banks or savings banks that qualify as a depository of public funds
in the State of California as defined in California Government Code Section 53630.5. No
more than 5% of the portfolio may be invested in the CDs of any one issuer, and the
aggregate investment in CDs shall not exceed 30% of the portfolio.
Deposits in excess of the insured amount shall be secured pursuant to California
Government Code Section 53651 and 53652. The City shall comply with and act to
secure compliance with the security (collateralization) system specified in the
Government Code Section 53649 and 56652.
7. Deposits may be placed using a private sector entity that assists in the placement of
deposits per section 53601.8 and 53635.8 in the Government Code. No more than 5% of
the portfolio may be invested through any one private sector entity that assists in the
placement of such deposits and the aggregate investment in CDs shall not exceed 30%
of the portfolio.
8. Special Assessment District Obliaations issued by the City of San Rafael as Limited
Obligation Improvement Bonds related to special assessment districts and special tax
districts. Investment in such obligations requires the approval of the City Council and
maturities may extend to 30 years from the date of trade settlement.
9. Prime Commercial Paper with a maturity not exceeding 270 days from the date of
purchase with the highest ranking or of the highest letter and number rating as provided
for by a NRSRO. The entity that issues the commercial paper shall meet all of the
following conditions in either sub -paragraph A. or sub -paragraph B. below:
A. The entity shall (1) be organized and operating in the United States as a
general corporation, (2) have total assets in excess of five $500,000,000 and
(3) Have debt other than commercial paper, if any, that is rated "A" or higher
by a NRSRO.
B. The entity shall (1) be organized within the United States as a special
purpose corporation, trust, or limited liability company, (2) have program -wide
credit enhancements, including, but not limited to, over collateralization,
letters of credit or surety bond and (3) have commercial paper that is rated
"A-1" or higher, or the equivalent, by a NRSRO.
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City of San Rafael
Investment Policy
August 7, 2017
Purchases of eligible commercial paper may not represent more than 10% of the
outstanding commercial paper of any single corporate issuer. No more than 5% of the
City's total portfolio, shall be invested in the commercial paper of any one issuer, and the
aggregate investment in commercial paper shall not exceed 25% of the City's total
portfolio.
10. Eligible Banker's Acceptances issued by FDIC insured commercial banks, rated at least
A-1 or the equivalent by a NRSRO with maturities not exceeding 180 days from the date
of purchase. If issuers have senior debt outstanding, it shall be rated at least A or the
equivalent by a NRSRO. No more than $2,000,000 shall be invested in banker's
acceptances of any one commercial bank, and the aggregate investment in banker's
acceptances shall not exceed 40% of the City's total portfolio.
11. Repurchase Aqreements with a final termination date not exceeding one year
collateralized by U.S. Treasury obligations, Federal Agency securities, or Federal
Instrumentality securities listed in items 1, 2 and 3 above with the maturity of the
collateral not exceeding five years. For the purpose of this section, the term collateral
shall mean purchased securities under the terms of the City's approved Master
Repurchase Agreement. The purchased securities shall have a minimum market value
including accrued interest of 102% of the dollar value of the funds borrowed. Collateral
shall be held in the City's custodian bank, as safekeeping agent, and the market value of
the collateral securities shall be marked -to -the -market daily.
Repurchase Agreements shall be entered into only with broker/dealers who are
recognized as Primary Dealers by the Federal Reserve Bank of New York or have a
primary dealer within their holding company structure. Repurchase agreement
counterparties shall execute a City approved Master Repurchase Agreement with the
City. The Treasurer shall maintain a copy of the City's approved Master Repurchase
Agreement along with a list of the broker/dealers who have executed same.
12. State of California's Local Aaencv Investment Fund (LAIF), pursuant to California
Government Code Section 16429.1.
13. Monev Market Funds registered under the Investment Company Act of 1940 that (1) are
"no-load" (meaning no commission or fee shall be charged on purchases or sales of
shares); (2) have a constant daily net asset value per share of $1.00; (3) invest only in
United States Treasury the securities, United States Aaencv securities and Federal
Instrumentalitv securities a^�'� obligationo autho4zed in thio Ply and (4) have a rating
of at least AAA or the equivalent by at least two NRSROs. The aggregate investment in
money market funds shall not exceed 10% of the City's total portfolio.
It is the intent of the City that the foregoing list of authorized securities and transactions is
strictly interpreted. Any deviation from this list must be preapproved by resolution of the City
Council.
PORTFOLIO MATURITIES AND LIQUIDITY
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City of San Rafael
Investment Policy
August 7, 2017
To the extent possible, investments shall be matched with anticipated cash flow
requirements and known future liabilities. The City will not invest in securities maturing more
than five years from the date of purchase, unless the City Council has by resolution granted
authority to make such an investment at least three months prior to the date of investment.
SELECTION OF BROKER/DEALERS
The Treasurer shall maintain a list of broker/dealers authorized for investment purposes,
and it shall be the policy of the City to purchase securities only from those authorized firms.
To be eligible, a firm must be licensed by the State of California as a broker/dealer as
defined in Section 25004 of the California Corporations Code, and:
1. be recognized as a Primary Dealer by the Federal Reserve Bank of New York or have a
primary dealer within its holding company structure, or
2. report voluntarily to the Federal Reserve Bank of New York, or
3. qualify under Securities and Exchange Commission (SEC) Rule 15c3-1 (Uniform Net
Capital Rule).
The City may engage the services of investment advisory firms to assist in the management
of the portfolio and investment advisors may utilize their own list of approved
Broker/Dealers. Such Broker/Dealers will comply with the selection criteria above and the
list of approved firms shall be provided to the City on an annual basis or upon request.
In the event that an external investment advisor is not used in the process of recommending
a particular transaction in the City's portfolio, authorized broker/dealers shall attest in writing
that they have received and reviewed a copy of this policy and annually update a City
approved Broker/Dealer Information Request form which includes the firm's most recent
financial statements. The Treasurer shall maintain a list of the broker/dealers that have
been approved by the City, along with each firm's most recent broker/dealer Information
Request form.
The City may purchase commercial paper from direct issuers even though they are not on
the approved broker/dealer list as long as they meet the criteria outlined in Item 5 of the
Authorized Securities and Transactions section of this Policy.
COMPETITIVE TRANSACTIONS
Each investment transaction shall be competitively transacted with authorized
broker/dealers. At least three broker/dealers shall be contacted for each transaction and
their bid and offering prices shall be recorded.
If the City is offered a security for which there is no other readily available competitive
offering, the Treasurer will document quotations for comparable or alternative securities.
SELECTION OF BANKS
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City of San Rafael
Investment Policy
August 7, 2017
The Treasurer shall maintain a list of banks that are approved to provide banking services
for the City. To be eligible for authorization, a bank must be a member of the FDIC and
shall qualify as a depository of public funds in the State of California as defined in California
Government Code Section 53630.5.
SAFEKEEPING AND CUSTODY
The Treasurer shall select one or more banks to provide safekeeping and custodial services
for the City, in accordance with the provisions of Section 53608 of the California
Government Code. A Safekeeping Agreement approved by the City shall be executed with
each custodian bank prior to utilizing that bank's safekeeping services. Custodian banks will
be selected on the basis of their ability to provide services for the City's account and the
competitive pricing of their safekeeping related services.
The purchase and sale of securities and repurchase agreement transactions shall be settled
on a delivery versus payment basis. All securities shall be perfected in the name of the City.
Sufficient evidence to title shall be consistent with modern investment, banking and
commercial practices.
All investment securities purchased by the City will be delivered by book entry and will be
held in third -party safekeeping by a City approved custodian bank,or its Depository Trust
Company (DTC) participant account.
The City's custodian shall be required to furnish the City a list of holdings on at least a
monthly basis and safekeeping receipts or customer confirmations shall be issued for each
transaction.
PORTFOLIO PERFORMANCE
The investment portfolio shall be designed to attain a market rate of return throughout
budgetary and economic cycles, taking into account prevailing market conditions, risk
constraints for eligible securities, and cash flow requirements. The performance of the City's
investments shall be compared to the average yield on the U.S. Treasury security that most
closely corresponds to the portfolio's actual weighted average effective maturity. When
comparing the performance of the City's portfolio, its rate of return will be computed net of all
fees and expenses.
REPORTING
On a quarterly basis, the Treasurer shall submit to the Council a report of the investment
earnings and performance results of the City's investment portfolio. The report shall include
the following information:
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City of San Rafael
Investment Policy
August 7, 2017
1. Investment type, issuer, date of purchase, purchase price, date of maturity, par value,
current rate of interest and dollar amount invested in all securities, and investments and
monies held by the City;
2. A description of the funds, investments and programs;
3. A market value as of the date of the report (or the most recent valuation as to assets not
valued monthly) and the source of the valuation;
4. Overall portfolio yield based on historical cost;
5. Weighted average final maturity and weighted average effective maturity;
6. A statement of compliance with this Policy or an explanation for not -compliance;
7. A description of any of the City's funds, investments or programs that are under the
management of contracted parties, including lending programs; and
8. A statement of the ability to meet expenditure requirements for six months, as well as an
explanation of why money will not be available if that is the case.
The Treasurer shall submit to the Council a report of any changes affecting more than 15%
of the investment portfolio within 30 days of such change.
POLICY REVIEW
This Investment Policy shall be reviewed and approved by City Council annually to ensure
its consistency with the overall objectives of preservation of principal, liquidity, yield and
diversification and its relevance to current law and economic trends. Any additional
amendments to this Investment Policy shall be submitted to the City Council for approval.
Page 8
SAN RAFAEL STAFF REPORT APPROVAL
THE CITY WITH AMISSION ROUTING SLIP
Staff Report Author: Van Bach Date of Meeting: 08/07/2017
Department: Finance
Topic: Investment Policy
Subject: Click here to enter text.
Type: (check all that apply) ❑ Consent Calendar ❑ Public Hearing
❑ Discussion Item 0 Resolution ❑ Ordinance
❑ Professional Services Agreement ❑ Informational Report
*If PSA, City Attorney approval is required prior to start of staff report approval process
Was agenda item publicly noticed? ❑ Yes El No I Date noticed: I ❑Mailed ❑Site posted ❑Marin U
Due Date Responsibility Description CompletedDate Initial / Comment
FRI, 7/21 Author
MON, 7/24 Director
PRELIMINARY REVIEW
Submit draft report to
Director
Submit draft report to ACM
Assistant City Manager Readiness review,
City Attorney preliminary legal and
Finance financial impact review
7/21/2017 0
Van Bach
7/24/2017 0
7/26/2017 Mark Moses
0
LG
TUES, 8/1 City Manager Final review and approval Click here to
enter a date.
CONTENT REVIEW
FRI, 7/28 Assistant City Manager
Content review
0
CA
Author
Revisions
0
FINAL REVIEW
MON, 7/31 City Attorney
Final legal review
8/1/2017
Click here to
LG
Finance
Final financial review
enter a date.
Click here to
Author
Revisions / accept changes
enter a date.
TUES, 8/1 City Manager Final review and approval Click here to
enter a date.