Resolution No. 72721 RESOLUTION NO. 7272
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A RESOLUTION OF THE CITY COUNCIL OF
3 THE CITY OF VERNON AMENDING
RESOLUTION NO.7092 WHICH APPROVED
4 THE ANNUAL STATEMENT OF INVESTMENT
POLICY OF THE CITY AND DELEGATED
5 INVESTMENT AUTHORITY TO THE CITY
TREASURER
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7 WHEREAS, pursuant to California Government Code
8 Section 53646(a)(2), the City Treasurer shall annually render to
9 the City Council an Annual Statement of Investment Policy; and
10 WHEREAS, pursuant to Resolution No.7092, the City
11 Council approved the Annual Statement of Investment Policy which
12 delegates investment authority to the City Treasurer, and grants
13 the City Treasurer express authority to make investments of City
14 funds in securities with a term or term remaining to maturity at
15 the time of investment in excess of five years as part of an
16 investment program; and
17 WHEREAS, the City Council desires to amend said City
18 Investment Policy so that it comports with recent changes in the
19 California Government Code concerning the types of investments in
20 which the City may invest its funds for deposit and the
21 statements concerning the investment of funds.
22 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF
23 THE CITY OF VERNON AS FOLLOWS:
24 SECTION 1: The City Council of the City of Vernon does
25 hereby find and determine that the recitals contained hereinabove
26 are true and correct.
27 SECTION 2: The City Council of the City of Vernon
28 hereby adopts the amended City investment policy, "Annual
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1 Statement of Investment Policy of the City of Vernon, California
2 for the Year 1999," a copy of which is attached hereto and
3 incorporated herein as Exhibit "A" to this Resolution.
4 SECTION 3: The City Council of the City of Vernon
5 hereby delegates to the City Treasurer the authority to implement
6 said Annual Statement of Investment Policy and select the
7 instruments for the City's investment portfolio in accordance
8 with said Statement of Investment Policy.
9 SECTION 4: The City Council of the City of Vernon
10 hereby grants express authority to the City Treasurer as part of
11 the City's investment program to invest in securities with a term
12 or term remaining to maturity, at the time of investment, in
13 excess of five years.
14 SECTION 5: The City Clerk of the City of Vernon shall
15 certify to the passage of this Resolution and thereupon and
16 thereafter the same shall be in full force and effect.
17 APPROVED AND ADOPTED this 16th day of February,
18 1999.
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ONIS C. MALBU G, Mayo
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22 ATTEST:
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25 BRUCE V. MALKENHORST, City Clerk
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1 STATE OF CALIFORNIA )
2 COUNTY OF LDS ANGELES )
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4 I, BRUCE V. MALKENHORST, City Clerk of the City of
5 Vernon, do hereby certify that the foregoing Resolution, being
6 Resolution No. 7272 , was duly adopted by the City Council of the
7 City of Vernon at a regular meeting of the City Council duly held
8 on Tuesday, February 16th 1999, and thereafter was duly signed
9 by the Mayor of the City of Vernon.
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BRUCE V. MALKENHORST, City Clerk
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SUPPORTING
DOCUMENTS
ANNUAL STATEMENT
OF
INVESTMENT POLICY
OF THE CITY OF VERNON, CALIFORNIA
FOR THE YEAR 1999
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Monies not required for immediate expenditure by the City of Vernon shall be invested
in compliance with governing provisions of law and this policy. The City will maintain
adequate cash availability and strive for maximum yield on invested idle funds while
insuring that the principal sum invested is protected from loss. This Investment Policy
shall be in compliance with the Government Code of the State of California, including
Sections 53600.3, 53600.5, 53600.6, 53601, 53601.6, 53607, 53630, 53630.1, 53631.5, 53635,
53638, 53646, 53651, 53651.2, 53651.4, 53651.6, and 53652, relating to local agency
finances.
I. DELEGATION OF AUTHORITY; PRUDENT INVESTOR STANDARD
Pursuant to Resolution of the City of Vernon adopted February, 1999, and
California Government Code Section 53607, the City Treasurer has been
delegated investment authority for a one year period by the City Council. The
City Treasurer, the City Administrator, and all persons and governing bodies of
the City authorized to make investment decisions on behalf of the City are
"trustees" and therefore fiduciaries subject to the prudent investor standard.
When investing, reinvesting, purchasing, acquiring, exchanging, selling, or
managing public funds, a trustee of the City 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 City, 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 City. Within the limitations of
this Investment Policy and Section 53600.3 of the California Government Code
and considering individual investments as part to an overall strategy, the City
Treasurer is authorized to acquire investments as authorized by law.
II. INVESTMENT CRITERIA
When investing, reinvesting, purchasing, acquiring, exchanging, selling, or
managing public funds, the primary objective of a trustee of the City shall be to
safeguard the principal of the funds under its control. The secondary objective
shall be to meet the liquidity needs of the City. The third objective shall be to
achieve a return on the funds under its control.
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M. POLICIES AND OBJECTIVES
The investment program of the City shall require the City Treasurer and the
Finance Department to actively manage the City's portfolio of investments in
order to take advantage of changing economic conditions and to insure that the
liquidity needs of the City are satisfied. As part of the City's investment program,
the City Treasurer has the express authority to make investments in securities that
have a term, or a term remaining to maturity, at the time of investment, in excess
of five years, as long as such investments, taken in the aggregate in relation to the
City's entire investment portfolio, do not adversely impact the liquidity needs of
the City and its funds and enterprises.
The City Treasurer has the express authority to sell, as he deems prudent, any
securities in the City's portfolio of investments prior to the maturity date of the
particular security. The City Treasurer has the express authority to invest in, as
he deems prudent, any security authorized by this Investment Policy with the
objective of selling that same security prior to its maturity date. The City
Treasurer's authority to buy and sell securities for investment on behalf of the
City includes the authorization to buy and sell the same security on the same
trading day.
Any persons authorized to make investment decisions on behalf of the City, shall
be subject to daily oversight and monitoring by the City Treasurer and Finance
Department in order to insure full and complete compliance with this Investment
Policy and the Government Code of the State of California, relating to the deposit
and investment of funds and local agency finances.
IV. INSTRUMENTS AUTHORIZED FOR INVESTMENT
The City, having money in a sinking fund of, or surplus money in, its treasury not
required for the immediate needs of the City may invest any portion of the money
that it deems wise or expedient in those investments set forth below. If the City
purchases or obtains any securities prescribed in Section IV, in a negotiable,
bearer, registered, or nonregistered format, the City shall require delivery of the
securities to the City, including those purchased for the City by financial advisors,
consultants, or managers using the City's funds, by book entry, physical delivery,
or by third party custodial agreement. The transfer of securities to the
counterparty bank's customer book entry account may be used for book entry
delivery. For purposes of this Section IV counterparty means the other party to
the transaction. A counterparty bank's trust department or separate safekeeping
department may be used for the physical delivery of the security if the security is
held in the name of the City. Investments may be made in any security
authorized by this Section IV, including a security underlying a repurchase or
reverse repurchase agreement authorized by Section 53601 of the California
Government Code, that at the time of investment has a term or a term remaining
to maturity in excess of five years as long as such investment comports with the
policies and objectives of this Investment Policy.
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(a) Bonds issued by the City, including bonds payable solely out of the
revenues from a revenue -producing property owned, controlled, or operated by
the City or by a department, board, agency, or authority of the City.
(b) United States Treasury notes, bonds, bills, or certificates of
indebtedness, or those for which the faith and credit of the United States are
pledged for the payment of principal and interest.
(c) Registered state warrants or treasury notes or bonds of this state,
including bonds payable solely out of the revenues from a revenue -producing
property owned, controlled, or operated by the state or by a department, board --
agency, or authority of the state.
(d) Bonds, notes, warrants, or other evidences of indebtedness of any
local agency within this state, including bonds payable solely out of the revenues
from a revenue -producing property owned, controlled, or operated by the local
agency, or by a department, board, agency, or authority of the local agency.
(e) Obligations issued by banks for cooperatives, federal land banks,
federal intermediate credit banks, federal home loan banks, the Federal Home
Loan Bank Board, the Tennessee Valley Authority, or in obligations,
participations, or other instruments of, or issued by, or fully guaranteed as to
principal and interest by, the Federal National Mortgage Association; or in
guaranteed portions of Small Business Administration notes; or in obligations,
participations, or other instruments of, or issued by, a federal agency or a United
States government -sponsored enterprise.
(f) Bills of exchange or time drafts drawn on and accepted by a
commercial bank, otherwise known as bankers acceptances. Purchases of bankers
acceptances may not exceed 270 days maturity or 40 percent of the City's surplus
money that may be invested pursuant to this subsection (f). However, no more
than 30 percent of the City's surplus funds may be invested in the bankers
acceptances of any one commercial bank pursuant to this section.
(g) Commercial paper of "prime" quality of the highest ranking or of the
highest letter and numerical rating as provided for by Moody's Investors Service,
Inc., or Standard and Poor's Corporation. Eligible paper is further limited to
issuing corporations that are organized and operating within the United States
and having total assets in excess of five hundred million dollars ($500,000,000)
and having an "A" or higher rating for the issuer's debt, other than commercial
paper, if any, as provided for by Moody's Investors Service, Inc., or Standard and
Poor's Corporation. Purchases of eligible commercial paper may not exceed 180
days maturity nor represent more than 10 percent of the outstanding paper of an
issuing corporation. Purchases of commercial paper may not exceed 15 percent of
the City's surplus money that may be invested pursuant to this subsection (g). An
additional 15 percent, or a total of 30 percent of the City's surplus money, may be
invested pursuant to this subsection. The additional 15 percent may be so
invested only if the dollar -weighted average maturity of the entire amount does
not exceed 31 days. "Dollar weighted average maturity" means the sum of the
amount of each outstanding commercial paper investment multiplied by the
number of days to maturity, divided by the total amount of outstanding
commercial paper.
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(h) Negotiable certificates of deposits issued by a nationally or
state -chartered bank or a state or federal association (as defined by Section 5102
of the California Financial Code) or by a state -licensed branch of a foreign bank.
Purchases of negotiable certificates of deposit may not exceed 30 percent of the
City's surplus money which may be invested pursuant to this subsection (h). For
purposes of this subsection (h), negotiable certificates of deposits do not come
within Article 2 of the California Government Code (commencing with Section
53630), except that the amount so invested shall be subject to the limitations of
California Government Code Section 53638 concerning maximum deposits.
(i) (1) Investments in repurchase agreements or reverse repurchase
agreements of any securities authorized by this subsection (i), as long as the
agreements are subject to this subsection (i), including, the delivery requirements
specified in this subsection (i).
(2) Investments in repurchase agreements may be made, on any
investment authorized in this Section IV, when the term of the agreement does
not exceed one year. The market value of securities that underlay a repurchase
agreement shall be valued at 102 percent or greater of the funds borrowed against
those securities and the value shall be adjusted no less than quarterly. Since the
market value of the underlying securities is subject to daily market fluctuations,
the investments in repurchase agreements shall be in compliance if the value of
the underlying securities is brought back up to 102 percent no later than the next
business day.
(3) Reverse repurchase agreements may be utilized only when
either of the following conditions are met:
(A) The security was owned or specifically committed to
purchase by the City prior to December 31, 1994, and was sold using a reverse
repurchase agreement on December 31, 1994.
(B) The security to be sold on reverse repurchase agreement
has been owned and fully paid for by the City for a minimum of 30 days prior to
sale; the total of all reverse repurchase agreements on investments owned by the
City not purchased or committed to purchase, prior to December 31, 1994, does
not exceed 20 percent of the base value of the portfolio; and the agreement does
not exceed a term of 92 days, unless the agreement includes a written codicil
guaranteeing a minimum earning or spread for the entire period between the sale
of a security using a reverse repurchase agreement and the final maturity date of
the same security.
(4) After December 31, 1994, a reverse repurchase agreement may
not be entered into with securities not sold on a reverse repurchase agreement
and purchased, or committed to purchase, prior to that date, as a means of
financing or paying for the security sold on a reverse repurchase agreement, but
may only be entered into with securities owned and previously paid for a
minimum of 30 days prior to the settlement of the reverse repurchase agreement,
in order to supplement the yield on securities owned and previously paid for or to
provide funds for the immediate payment of a City obligation. Funds obtained or
funds within the pool of an equivalent amount to that obtained from selling a
security to a counterparty by way of a reverse repurchase agreement, on securities
originally purchased subsequent to December 31, 1994, shall not be used to
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purchase another security with a maturity longer than 92 days from the initial
settlement date of the reverse repurchase agreement, unless the reverse
repurchase agreement includes a written codicil guaranteeing a minimum earning
or spread for the entire period between the sale of a security using a reverse
repurchase agreement and the final maturity date of the same security. Reverse
repurchase agreements specified in subparagraph (B) of paragraph (3) may not be
entered into unless the percentage restrictions specified in that subparagraph are
met, including the total of any reverse repurchase agreements specified in
subparagraph (A) of paragraph (3).
(5) Investments in reverse repurchase agreements or similar
investments in which the City sells securities prior to purchase with a
simultaneous agreement to repurchase the security, may only be made upon prior
approval of the City Council and shall only be made with primary dealers of the
Federal Reserve Bank of New York.
(6) (A) "Repurchase agreement" means a purchase of securities
by the City pursuant to an agreement by which the counterparty seller will
repurchase the securities on or before a specified date and for a specified amount
and the counterparty will deliver the underlying securities to the City by book
entry, physical delivery, or by third party custodial agreement. The transfer of
underlying securities to the counterparty bank's customer book -entry account may
be used for book -entry delivery.
(B) "Securities," for purpose of repurchase under this
subsection (i), means securities of the same issuer, description, issue date, and
maturity.
(C) "Reverse repurchase agreement" means a sale of
securities by the City pursuant to an agreement by which the City will repurchase
the securities on or before a specified date and includes other comparable
agreements.
(D) For purposes of this subsection (i), the base value of the
City's pool portfolio shall be that dollar amount obtained by totaling all cash
balances placed in the pool by all pool participants, excluding any amounts
obtained through selling securities by way of reverse repurchase agreements or
other similar borrowing methods.
(E) For purposes of this subsection (i), the spread is the
difference between the cost of funds obtained using the reverse repurchase
agreement and the earnings obtained on the reinvestment of the funds.
0) Medium -term notes of a maximum of five years maturity 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. Notes eligible for investment under this subsection 0) shall be
rated in a rating category of "A" or its equivalent or better by a nationally
recognized rating service. Purchases of medium -term notes may be not exceed 30
percent of the City's surplus money which may be invested pursuant to this
subsection 0).
(k) (1) Shares of beneficial interest issued by diversified management
companies that invest in the securities and obligations as authorized by
subsections (a) to 0), inclusive, or subsections (m) or (n) of this Section IV and
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that comply with the investment restrictions of Article 1 (commencing with
Section 53600 of the California Government Code) and Article 2 (commencing
with Section 53630 of the California Government Code). However,
notwithstanding these restrictions, a counterparty to a reverse repurchase
agreement is not required to be a primary dealer of the Federal Reserve Bank of
New York if the company's board of directors finds that the counterparty presents
a minimal risk of default, and the value of the securities underlying a repurchase
agreement may be 100 percent of the sales price if the securities are marked to
market daily.
(2) Shares of beneficial interest issued by diversified management
companies that are money market funds registered with the Securities and
Exchange Commission under the Investment Company Act of 1940 (15 U.S.C.
Sec. 80a-1, et seq.).
(3) If investment is in shares issued pursuant to paragraph (1), the
company shall have met either of the following criteria:
(A) Attained the highest ranking or the highest letter and
numerical rating provided by not less than two nationally recognized statistical
rating organizations.
(B) Retained an investment adviser registered or exempt
from registration with the Securities and Exchange Commission with not less than
five years' experience investing in the securities and obligations authorized by
subsections (a) to 0), inclusive, or subsections (m) or (n) and with assets under
management in excess of five hundred million dollars ($500,000,000).
(4) If investment is in shares issued pursuant to paragraph (2), the
company shall have met either of the following criteria:
(A) Attained the highest ranking or the highest letter and
numerical rating provided by not less than two nationally recognized statistical
rating organizations.
(B) Retained an investment adviser registered or exempt
from registration with the Securities and Exchange Commission with not less than
five years' experience managing money market mutual funds with assets under
management in excess of five hundred million dollars ($500,000,000).
(5) The purchase price of shares of beneficial interest purchased
pursuant to this subsection (k) shall not include any commission that the
companies may charge and shall not exceed 20 percent of the City's surplus
money that may be invested pursuant to this subsection (k). However, no more
than 10 percent of the City's surplus funds may be invested in shares of beneficial
interest of any one mutual fund pursuant to paragraph (1) of subsection (k).
(1) Notwithstanding anything to the contrary contained in this Section
IV, Section 53601 and Section 53635 of the California Government Code, or any
other provision of law, moneys held by a trustee or fiscal agent and pledged to the
payment or security of bonds or other indebtedness, or obligations under a lease,
installment sale, or other agreement of the City, or certificates of participation in
those bonds, indebtedness, or lease installment sale, or other agreements, may be
invested in accordance with the statutory provision governing the issuance of those
bonds, indebtedness, or lease installment sale, or other agreement, or to the
extent not inconsistent therewith or if there are no specific statutory provisions, in
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accordance with the ordinance, resolution, indenture, or agreement of the City
providing for the issuance.
(m) Notes, bonds, or other obligations that are at all times secured by a
valid first priority security interest in securities of the types listed by Section 53651
of the California Government Code as eligible securities for the purpose of
securing local agency deposits having a market value at least equal to that
required by Section 53652 of the California Government Code for the purpose of
securing local agency deposits. The securities serving as collateral shall be placed
by delivery or book entry into the custody of a trust company or the trust
department of a bank which is not affiliated with the issuer of the secured
obligation, and the security interest shall be perfected in accordance with the
requirements of the Uniform Commercial Code or federal regulations applicable
to the types of securities in which the security interest is granted.
(n) Any Mortgage pass -through security, collateralized mortgage
obligation, mortgage -backed or other pay -through bond, equipment lease -backed
certificate, consumer receivable pass -through certificate, or consumer
receivable -backed bond of a maximum of five years maturity. Securities eligible
for investment under this subsection shall be issued by an issuer having an "A" or
higher rating for the issuer's debt as provided by a nationally recognized rating
service and rated in a rating category of "AA' or its equivalent or better by a
nationally recognized rating service. Purchase of securities authorized by this
subsection (n) may not exceed 20 percent of the City's surplus money that may be
invested pursuant to this Section IV.
(o) The City shall not invest any funds pursuant to this Section IV in
inverse floaters, range notes, or interest -only strips that are derived from a pool of
mortgages.
(p) The City shall not invest any funds pursuant to this subsection (p) in
any security that could result in zero interest accrual if held to maturity.
However, the City may hold prohibited instruments until their maturity dates.
The limitation in this subsection (p) shall not apply to City investments in shares
of beneficial interest issued by diversified management companies registered
under the Investment Company Act of 1940 (15 U.S.C. Sec. 80a-1, and following)
that are authorized for investment pursuant to subsection (k).
V. STATEMENTS OF INVESTMENT ACTIVITIES AND POLICY
The City Treasurer shall annually render to the City Council and the Finance
Committee of the City a statement of investment policy, which the City shall
consider at a public meeting. Any changes in this investment policy shall also be
considered by the City Council of the City at a public meeting.
The City Treasurer shall render a quarterly report to the Finance Committee and
City Council. The quarterly report shall be so submitted within 30 days following
the end of the quarter covered by the report. This report shall include the type of
investment, issuer, date of maturity par and dollar amount invested on all
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securities, investments and moneys held by the City and shall additionally include
a description of any of the City's funds, investments, or programs, that are under
the management of contracted parties, including lending programs. With respect
to all securities held by the City and under management of any outside party that
is not also a local agency or the State of California Local Agency Investment
Fund, the report shall also include a current market value as of the date of the
report, and shall include the source of this same valuation.
For local agency investments that have been placed in the Local Agency
Investment Fund, in National Credit Union Share Insurance Fund -insured
accounts in a credit union, in accounts insured or guaranteed pursuant to Section
14858 of the California Financial Code, or in Federal Deposit Insurance
Corporation -insured accounts in a bank or savings and loan association, in a_
County investment pool, or any combination of these, the City Treasurer and the
Finance Department may supply to the City Council and Finance Committee the
most recent statements received by the City from these institutions.
The quarterly report shall state compliance of the portfolio to the statement of
investment policy, or manner in which the portfolio is not in compliance. The
quarterly report shall include a statement denoting the ability of the City to meet
its budgeted expenditure requirements for the next six months, or provide an
explanation as to why sufficient money shall, or may, not be available. In the
quarterly report, a subsidiary ledger of investments may be used in accordance
with accepted accounting practices.
The authority of the City Council to invest or to reinvest funds of the City, or to
sell or exchange securities so purchased has been delegated for a one-year period
by the City Council to the City Treasurer, who shall thereafter assume full
responsibility for those transactions and shall make a monthly report of those
transactions to the City Council
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OFFICE OF THE CITY ADMINISTRATOR/
CITY CLERK
INTER -OFFICE MEMORANDUM
DATE: February 23, 1999
TO: Sharon Johnson, Deputy City Treasurer
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FROM: Gloria J. Oros 'Chief Deputy City Clerk
RE: Annual Statement of Investment Policy of the
City of Vernon, California for the Year 1999
Enclosed, for your files, is a copy of the above referenced
investment policy which was approved by City Council on February
16, 1999 through Resolution No. 7272.
c: Finance Committee
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RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF VERNON AMENDING
RESOLUTION NO.7092 WHICH APPROVED
THE ANNUAL STATEMENT OF INVESTMENT
POLICY OF THE CITY AND DELEGATED
INVESTMENT AUTHORITY TO THE CITY
TREASURER
WHEREAS, pursuant to California Government Code
Section 53646(a)(2), the City Treasurer shall annually render to
the City Council an Annual Statement of Investment Policy; and
WHEREAS, pursuant to Resolution No.7092, the City
Council approved the Annual Statement of Investment Policy which
delegates investment authority to the City Treasurer, and grants
the City Treasurer express authority to make investments of City
funds in securities with a term or term remaining to maturity at
the time of investment in excess of five years as part of an
investment program; and
WHEREAS, the City Council desires to amend said City
Investment Policy so that it comports with recent changes in the
California Government Code concerning the types of investments in
which the City may invest its funds for deposit and the
statements concerning the investment of funds.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF
THE CITY OF VERNON AS FOLLOWS:
SECTION 1: The City Council of the City of Vernon does
hereby find and determine that the recitals contained hereinabove
are true and correct.
SECTION 2: The City Council of the City of Vernon
hereby adopts the amended City investment policy, "Annual
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Statement of Investment Policy of the City of Vernon, California
for the Year 1999," a copy of which is attached hereto and
incorporated herein as Exhibit "A" to this Resolution.
SECTION 3: The City Council of the City of Vernon
hereby delegates to the City Treasurer the authority to implement
said Annual Statement of Investment Policy and select the
instruments for the City's investment portfolio in accordance
with said Statement of Investment Policy.
SECTION 4: The City Council of the City of Vernon
hereby grants express authority to the City Treasurer as part of
the City's investment program to invest in securities with a term
or term remaining to maturity, at the time of investment, in
excess of five years.
SECTION 5: The City Clerk of the City of Vernon shall
certify to the passage of this Resolution and thereupon and
thereafter the same shall be in full force and effect.
APPROVED AND ADOPTED this day of February,
1999.
ATTEST:
BRUCE V. MALKENHORST, City Clerk
LEONIS C. MALBURG, Mayor
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1 STATE OF CALIFORNIA )
2 COUNTY OF LOS ANGELES )
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4 I, BRUCE V. MALKENHORST, City Clerk of the City of
5 Vernon, do hereby certify that the foregoing Resolution, being
6 Resolution No. , was duly adopted by the City Council of the
7 City of Vernon at a regular meeting of the City Council duly held
81 on Tuesday, February , 1999, and thereafter was duly signed
91 by the Mayor of the City of Vernon.
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BRUCE V. MALKENHORST, City Clerk
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�&, , * ;W.7,
CITY COUNCIL
LEONIS C. MALBURG
Mayor
THOMAS A. YBARRA
Mayor Pro -Tern
Wm. 'BILL" DAVIS
Councilman
H. "LARRY" GONZALES
Councilman
W. MICHAEL McCORMICK
Councilman
BRUCE V. MALKENHORST
City Administrator / City Clerk
FAX (323) 581-7924
Finance Committee
City of Vernon
Honorable Members:
DAVID B. BREARLEY
City Attorney
FAX: (626) 330-5818
KEVIN WILSON
Director of Community Services & Water
FAX: (323) 588-2761
CITY HALL
4305 SANTA FE AVENUE, VERNON, CALIFORNIA 90058
TELEPHONE (323) 583-8811
February 4, 1999
KENNETH J. DeDARIO
Director of Municipal Utilities
FAX: (323) 583-1983
DAVE TELFORD
Fire Chief
FAX: (323) 581-1385
BRUCE W. OLSON
Police Chief
FAX: (323) 583-5236
In accordance with Government Code Section 53646(a)(2), an Annual Statement
of Investment Policy for the Year 1999 has been prepared, and transmitted
herewith, for your review and acceptance.
Also transmitted herewith is a communication from our legal counsel, Eric
Fresch, identifying areas where the report was revised and/or changed.
It is hereby recommended that this Annual Statement of Investment Policy for
the Year 1999 be approved and copies disseminated to the City Council.
Very truly yours,
z�- �
Bruce V. Malkenhorst
City Treasurer
BVM/gst
enclosures
ANNUAL STATEMENT
OF
INVESTMENT POLICY
OF THE CITY OF VERNON, CALIFORNIA
FOR THE YEAR 1999
INTRODUCTION
Monies not required for immediate expenditure by the City of Vernon shall be invested
in compliance with governing provisions of law and this policy. The City will maintain
adequate cash availability and strive for maximum yield on invested idle funds while
insuring that the principal sum invested is protected from loss. This Investment Policy
shall be in compliance with the Government Code of the State of California, including
Sections 53600.3, 53600.5, 53600.6, 53601, 53601.6, 53607, 53630, 53630.1, 53631.5, 53635,
53638, 53646, 53651, 53651.2, 53651.4, 53651.6, and 53652, relating to local agency
finances.
I. DELEGATION OF AUTHORITY; PRUDENT INVESTOR STANDARD
Pursuant to Resolution of the City of Vernon adopted February, 1999, and
California Government Code Section 53607, the City Treasurer has been
delegated investment authority for a one year period by the City Council. The
City Treasurer, the City Administrator, and all persons and governing bodies of
the City authorized to make investment decisions on behalf of the City are
"trustees" and therefore fiduciaries subject to the prudent investor standard.
When investing, reinvesting, purchasing, acquiring, exchanging, selling, or
managing public funds, a trustee of the City 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 City, 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 City. Within the limitations of
this Investment Policy and Section 53600.3 of the California Government Code
and considering individual investments as part to an overall strategy, the City
Treasurer is authorized to acquire investments as authorized by law.
II. INVESTMENT CRITERIA
When investing, reinvesting, purchasing, acquiring, exchanging, selling, or
managing public funds, the primary objective of a trustee of the City shall be to
safeguard the principal of the funds under its control. The secondary objective
shall be to meet the liquidity needs of the City. The third objective shall be to
achieve a return on the funds under its control.
III. POLICIES AND OBJECTIVES
The investment program of the City shall require the City Treasurer and the
Finance Department to actively manage the City's portfolio of investments in
order to take advantage of changing economic conditions and to insure that the
liquidity needs of the City are satisfied. As part of the City's investment program,
the City Treasurer has the express authority to make investments in securities that
have a term, or a term remaining to maturity, at the time of investment, in excess
of five years, as long as such investments, taken in the aggregate in relation to the
City's entire investment portfolio, do not adversely impact the liquidity needs of
the City and its funds and enterprises.
The City Treasurer has the express authority to sell, as he deems prudent, any
securities in the City's portfolio of investments prior to the maturity date of the
particular security. The City Treasurer has the express authority to invest in, as
he deems prudent, any security authorized by this Investment Policy with the
objective of selling that same security prior to its maturity date. The City
Treasurer's authority to buy and sell securities for investment on behalf of the
City includes the authorization to buy and sell the same security on the same
trading day.
Any persons authorized to make investment decisions on behalf of the City, shall
be subject to daily oversight and monitoring by the City Treasurer and Finance
Department in order to insure full and complete compliance with this Investment
Policy and the Government Code of the State of California, relating to the deposit
and investment of funds and local agency finances.
IV. INSTRUMENTS AUTHORIZED FOR INVESTMENT
The City, having money in a sinking fund of, or surplus money in, its treasury not
required for the immediate needs of the City may invest any portion of the money
that it deems wise or expedient in those investments set forth below. If the City
purchases or obtains any securities prescribed in Section IV, in a negotiable,
bearer, registered, or nonregistered format, the City shall require delivery of the
securities to the City, including those purchased for the City by financial advisors,
consultants, or managers using the City's funds, by book entry, physical delivery,
or by third party custodial agreement. The transfer of securities to the
counterparty bank's customer book entry account may be used for book entry
delivery. For purposes of this Section IV "counterparty" means the other party to
the transaction. A counterparty bank's trust department or separate safekeeping
department may be used for the physical delivery of the security if the security is
held in the name of the City. Investments may be made in any security
authorized by this Section IV, including a security underlying a repurchase or
reverse repurchase agreement authorized by Section 53601 of the California
Government Code, that at the time of investment has a term or a term remaining
to maturity in excess of five years as long as such investment comports with the
policies and objectives of this Investment Policy.
Ili
(a) Bonds issued by the City, including bonds payable solely out of the
revenues from a revenue -producing property owned, controlled, or operated by
the City or by a department, board, agency, or authority of the City.
(b) United States Treasury notes, bonds, bills, or certificates of
indebtedness, or those for which the faith and credit of the United States are
pledged for the payment of principal and interest.
(c) Registered state warrants or treasury notes or bonds of this state,
including bonds payable solely out of the revenues from a revenue -producing
property owned, controlled, or operated by the state or by a department, board,
agency, or authority of the state.
(d) Bonds, notes, warrants, or other evidences of indebtedness of any
local agency within this state, including bonds payable solely out of the revenues
from a revenue -producing property owned, controlled, or operated by the local
agency, or by a department, board, agency, or authority of the local agency.
(e) Obligations issued by banks for cooperatives, federal land banks,
federal intermediate credit banks, federal home loan banks, the Federal Home
Loan Bank Board, the Tennessee Valley Authority, or in obligations,
participations, or other instruments of, or issued by, or fully guaranteed as to
principal and interest by, the Federal National Mortgage Association; or in
guaranteed portions of Small Business Administration notes; or in obligations,
participations, or other instruments of, or issued by, a federal agency or a United
States government -sponsored enterprise.
(f) Bills of exchange or time drafts drawn on and accepted by a
commercial bank, otherwise known as bankers acceptances. Purchases of bankers
acceptances may not exceed 270 days maturity or 40 percent of the City's surplus
money that may be invested pursuant to this subsection (f). However, no more
than 30 percent of the City's surplus funds may be invested in the bankers
acceptances of any one commercial bank pursuant to this section.
(g) Commercial paper of "prime" quality of the highest ranking or of the
highest letter and numerical rating as provided for by Moody's Investors Service,
Inc., or Standard and Poor's Corporation. Eligible paper is further limited to
issuing corporations that are organized and operating within the United States
and having total assets in excess of five hundred million dollars ($500,000,000)
and having an "A" or higher rating for the issuer's debt, other than commercial
paper, if any, as provided for by Moody's Investors Service, Inc., or Standard and
Poor's Corporation. Purchases of eligible commercial paper may not exceed 180
days maturity nor represent more than 10 percent of the outstanding paper of an
issuing corporation. Purchases of commercial paper may not exceed 15 percent of
the City's surplus money that may be invested pursuant to this subsection (g). An
additional 15 percent, or a total of 30 percent of the City's surplus money, may be
invested pursuant to this subsection. The additional 15 percent may be so
invested only if the dollar -weighted average maturity of the entire amount does
not exceed 31 days. "Dollar weighted average maturity" means the sum of the
amount of each outstanding commercial paper investment multiplied by the
number of days to maturity, divided by the total amount of outstanding
commercial paper.
11:
(h) Negotiable certificates of deposits issued by a nationally or
state -chartered bank or a state or federal association (as defined by Section 5102
of the California Financial Code) or by a state -licensed branch of a foreign bank.
Purchases of negotiable certificates of deposit may not exceed 30 percent of the
City's surplus money which may be invested pursuant to this subsection (h). For
purposes of this subsection (h), negotiable certificates of deposits do not come
within Article 2 of the California Government Code (commencing with Section
53630), except that the amount so invested shall be subject to the limitations of
California Government Code Section 53638 concerning maximum deposits.
(i) (1) Investments in repurchase agreements or reverse repurchase
agreements of any securities authorized by this subsection (i), as long as the
agreements are subject to this subsection (i), including, the delivery requirements
specified in this subsection (i).
(2) Investments in repurchase agreements may be made, on any
investment authorized in this Section IV, when the term of the agreement does
not exceed one year. The market value of securities that underlay a repurchase
agreement shall be valued at 102 percent or greater of the funds borrowed against
those securities and the value shall be adjusted no less than quarterly. Since the
market value of the underlying securities is subject to daily market fluctuations,
the investments in repurchase agreements shall be in compliance if the value of
the underlying securities is brought back up to 102 percent no later than the next
business day.
(3) Reverse repurchase agreements may be utilized only when
either of the following conditions are met:
(A) The security was owned or specifically committed to
purchase by the City prior to December 31, 1994, and was sold using a reverse
repurchase agreement on December 31, 1994.
(B) The security to be sold on reverse repurchase agreement
has been owned and fully paid for by the City for a minimum of 30 days prior to
sale; the total of all reverse repurchase agreements on investments owned by the
City not purchased or committed to purchase, prior to December 31, 1994, does
not exceed 20 percent of the base value of the portfolio; and the agreement does
not exceed a term of 92 days, unless the agreement includes a written codicil
guaranteeing a minimum earning or spread for the entire period between the sale
of a security using a reverse repurchase agreement and the final maturity date of
the same security.
(4) After December 31, 1994, a reverse repurchase agreement may
not be entered into with securities not sold on a reverse repurchase agreement
and purchased, or committed to purchase, prior to that date, as a means of
financing or paying for the security sold on a reverse repurchase agreement, but
may only be entered into with securities owned and previously paid for a
minimum of 30 days prior to the settlement of the reverse repurchase agreement,
in order to supplement the yield on securities owned and previously paid for or to
provide funds for the immediate payment of a City obligation. Funds obtained or
funds within the pool of an equivalent amount to that obtained from selling a
security to a counterparty by way of a reverse repurchase agreement, on securities
originally purchased subsequent to December 31, 1994, shall not be used to
- 4 - EXHIBIT "A"
purchase another security with a maturity longer than 92 days from the initial
settlement date of the reverse repurchase agreement, unless the reverse
repurchase agreement includes a written codicil guaranteeing a minimum earning
or spread for the entire period between the sale of a security using a reverse
repurchase agreement and the final maturity date of the same security. Reverse
repurchase agreements specified in subparagraph (B) of paragraph (3) may not be
entered into unless the percentage restrictions specified in that subparagraph are
met, including the total of any reverse repurchase agreements specified in
subparagraph (A) of paragraph (3).
(5) Investments in reverse repurchase agreements or similar
investments in which the City sells securities prior to purchase with a
simultaneous agreement to repurchase the security, may only be made upon prior
approval of the City Council and shall only be made with primary dealers of the
Federal Reserve Bank of New York.
(6) (A) "Repurchase agreement" means a purchase of securities
by the City pursuant to an agreement by which the counterparty seller will
repurchase the securities on or before a specified date and for a specified amount
and the counterparty will deliver the underlying securities to the City by book
entry, physical delivery, or by third party custodial agreement. The transfer of
underlying securities to the counterparty bank's customer book -entry account may
be used for book -entry delivery.
(B) "Securities," for purpose of repurchase under this
subsection (i), means securities of the same issuer, description, issue date, and
maturity.
(C) "Reverse repurchase agreement" means a sale of
securities by the City pursuant to an agreement by which the City will repurchase
the securities on or before a specified date and includes other comparable
agreements.
(D) For purposes of this subsection (i), the base value of the
City's pool portfolio shall be that dollar amount obtained by totaling all cash
balances placed in the pool by all pool participants, excluding any amounts
obtained through selling securities by way of reverse repurchase agreements or
other similar borrowing methods.
(E) For purposes of this subsection (i), the spread is the
difference between the cost of funds obtained using the reverse repurchase
agreement and the earnings obtained on the reinvestment of the funds.
0) Medium -term notes of a maximum of five years maturity 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. Notes eligible for investment under this subsection 0) shall be
rated in a rating category of "A" or its equivalent or better by a nationally
recognized rating service. Purchases of medium -term notes may be not exceed 30
percent of the City's surplus money which may be invested pursuant to this
subsection 0).
(k) (1) Shares of beneficial interest issued by diversified management
companies that invest in the securities and obligations as authorized by
subsections (a) to 0), inclusive, or subsections (m) or (n) of this Section IV and
that comply with the investment restrictions of Article 1 (commencing with
Section 53600 of the California Government Code) and Article 2 (commencing
with Section 53630 of the California Government Code). However,
notwithstanding these restrictions, a counterparty to a reverse repurchase
agreement is not required to be a primary dealer of the Federal Reserve Bank of
New York if the company's board of directors finds that the counterparty presents
a minimal risk of default, and the value of the securities underlying a repurchase
agreement may be 100 percent of the sales price if the securities are marked to
market daily.
(2) Shares of beneficial interest issued by diversified management
companies that are money market funds registered with the Securities and
Exchange Commission under the Investment Company Act of 1940 (15 U.S.C.
Sec. 80a-1, et seq.).
(3) If investment is in shares issued pursuant to paragraph (1), the
company shall have met either of the following criteria:
(A) Attained the highest ranking or the highest letter and
numerical rating provided by not less than two nationally recognized statistical
rating organizations.
(B) Retained an investment adviser registered or exempt
from registration with the Securities and Exchange Commission with not less than
five years' experience investing in the securities and obligations authorized by
subsections (a) to 0), inclusive, or subsections (m) or (n) and with assets under
management in excess of five hundred million dollars ($500,000,000).
(4) If investment is in shares issued pursuant to paragraph (2), the
company shall have met either of the following criteria:
(A) Attained the highest ranking or the highest letter and
numerical rating provided by not less than two nationally recognized statistical
rating organizations.
(B) Retained an investment adviser registered or exempt
from registration with the Securities and Exchange Commission with not less than
five years' experience managing money market mutual funds with assets under
management in excess of five hundred million dollars ($500,000,000).
(5) The purchase price of shares of beneficial interest purchased
pursuant to this subsection (k) shall not include any commission that the
companies may charge and shall not exceed 20 percent of the City's surplus
money that may be invested pursuant to this subsection (k). However, no more
than 10 percent of the City's surplus funds may be invested in shares of beneficial
interest of any one mutual fund pursuant to paragraph (1) of subsection (k).
(1) Notwithstanding anything to the contrary contained in this Section
IV, Section 53601 and Section 53635 of the California Government Code, or any
other provision of law, moneys held by a trustee or fiscal agent and pledged to the
payment or security of bonds or other indebtedness, or obligations under a lease,
installment sale, or other agreement of the City, or certificates of participation in
those bonds, indebtedness, or lease installment sale, or other agreements, may be
invested in accordance with the statutory provision governing the issuance of those
bonds, indebtedness, or lease installment sale, or other agreement, or to the
extent not inconsistent therewith or if there are no specific statutory provisions, in
6 - EXHIBIT "A„
accordance with the ordinance, resolution, indenture, or agreement of the City
providing for the issuance.
(m) Notes, bonds, or otherobligations that are at all times secured by a
valid first priority security interest in securities of the types listed by Section 53651
of the California Government Code as eligible securities for the purpose of
securing local agency deposits having a market value at least equal to that
required by Section 53652 of the California Government Code for the purpose of
securing local agency deposits. The securities serving as collateral shall be placed
by delivery or book entry into the custody of a trust company or the trust
department of a bank which is not affiliated with the issuer of the secured
obligation, and the security interest shall be perfected in accordance with the
requirements of the Uniform Commercial Code or federal regulations applicable
to the types of securities in which the security interest is granted.
(n) Any Mortgage pass -through security, collateralized mortgage
obligation, mortgage -backed or other pay -through bond, equipment lease -backed
certificate, consumer receivable pass -through certificate, or consumer
receivable -backed bond of a maximum of five years maturity. Securities eligible
for investment under this subsection shall be issued by an issuer having an "A" or
higher rating for the issuer's debt as provided by a nationally recognized rating
service and rated in a rating category of "AA" or its equivalent or better by a
nationally recognized rating service. Purchase of securities authorized by this
subsection (n) may not exceed 20 percent of the City's surplus money that may be
invested pursuant to this Section IV.
(o) The City shall not invest any funds pursuant to this Section IV in
inverse floaters, range notes, or interest -only strips that are derived from a pool of
mortgages.
(p) The City shall not invest any funds pursuant to this subsection (p) in
any security that could result in zero interest accrual if held to maturity.
However, the City may hold prohibited instruments until their maturity dates.
The limitation in this subsection (p) shall not apply to City investments in shares
of beneficial interest issued by diversified management companies registered
under the Investment Company Act of 1940 (15 U.S.C. Sec. 80a-1, and following)
that are authorized for investment pursuant to subsection (k).
V. STATEMENTS OF INVESTMENT ACTIVITIES AND POLICY
The City Treasurer shall annually render to the City Council and the Finance
Committee of the City a statement of investment policy, which the City shall
consider at a public meeting. Any changes in this investment policy shall also be
considered by the City Council of the City at a public meeting.
The City Treasurer shall render a quarterly report to the Finance Committee and
City Council. The quarterly report shall be so submitted within 30 days following
the end of the quarter covered by the report. This report shall include the type of
investment, issuer, date of maturity par and dollar amount invested on all
�� 11:11 My.`%
securities, investments and moneys held by the City and shall additionally include
a description of any of the City's funds, investments, or programs, that are under
the management of contracted parties, including lending programs. With respect
to all securities held by the City and under management of any outside party that
is not also a local agency or the State of California Local Agency Investment
Fund, the report shall also include a current market value as of the date of the
report, and shall include the source of this same valuation.
For local agency investments that have been placed in the Local Agency
Investment Fund, in National Credit Union Share Insurance Fund -insured
accounts in a credit union, in accounts insured or guaranteed pursuant to Section
14858 of the California Financial Code, or in Federal Deposit Insurance
Corporation -insured accounts in a bank or savings and loan association, in a
County investment pool, or any combination of these, the City Treasurer and the
Finance Department may supply to the City Council and Finance Committee the
most recent statements received by the City from these institutions.
The quarterly report shall state compliance of the portfolio to the statement of
investment policy, or manner in which the portfolio is not in compliance. The
quarterly report shall include a statement denoting the ability of the City to meet
its budgeted expenditure requirements for the next six months, or provide an
explanation as to why sufficient money shall, or may, not be available. In the
quarterly report, a subsidiary ledger of investments may be used in accordance
with accepted accounting practices.
The authority of the City Council to invest or to reinvest funds of the City, or to
sell or exchange securities so purchased has been delegated for a one-year period
by the City Council to the City Treasurer, who shall thereafter assume full
responsibility for those transactions and shall make a monthly report of those
transactions to the City Council.
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January 20, 1999
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LAW OFFICES OF
EPIC T. FRESCH
CITICORP CENTER, ONE SANSOME STREET
TWENTY-FIRST FLOOR
SAN FRANCISCO, CALIFORNIA 94104
TELEPHONE (415) 95I-I035
FAX (4I5) 951-4660
Mr. Bruce V. Malkenhorst
City Administrator
City of Vernon
4305 Santa Fe Avenue
Vernon, CA 90058
S
(
JAN
Re: Annual Statement of Investment Policy; Legislation Affecting the Financial Affairs
of Local Agencies
Dear Bruce:
I have drafted the I
recommend the City Council and Finance Committee of the City approve and adopt the
new policy. I also recommend the City Council authorize you, as City Treasurer, to
make investments of City funds as you deem prudent in securities with a term or a term
remaining to maturity in excess of five years.
I recommend the City Council grant you the express authority to make such investments
every 90 days or calendar year quarter to cover the next 90-day investment period. I
have incorporated the necessary language in my draft resolution for approval of the
investment policy and will provide similar documents when the quarterly report of
investments is submitted to the City Council. My recommendation is based upon recent
interpretations by the State of California Attorney General's office and recent legislative
proposals, both concerning the relevant Government Code provisions regarding local
agency finances and accountability for City investment policies.
I have incorporated into this year's investment policy the amendments that were made to
various sections of the California Government Code concerning instruments authorized
for investment, the delegation of investment authority to the City Treasurer and the
required statements of investment activity.
I have reviewed various pieces of legislation that were enacted into law in the last half of
1998 which affect the types of investments the City may make and the statements the
City Treasurer and Finance Department must prepare for the City Council for the
investment of City funds. I have summarized the law and the recent changes in detail
below. These changes intend to make the City Council, the City Treasurer and their
consultants more accountable in the creation and execution of investment policy and in
the reporting and disclosure of investment transactions made with the City's funds.
Mr. Bruce V. Malkenhorst
1/20/99
Page 2
The following briefly outlines the requirements of both the law and of prudent practices
for City investment policy and reporting requirements which will directly impact the City
Treasurer and Finance Department.
1. The City Treasurer shall annually render to the City Council and Finance
Committee a statement of investment policy, which the City Council shall consider
at a public meeting. Any change in the investment policy shall also be considered
by the City Council at a public meeting.
2. The City Council may annually, after appropriate review, renew the delegation of
authority to the City Treasurer to carry out the investment policy and make
investments of the City's funds.
3. The City Treasurer shall render a quarterly report of City investments to the City
Administrator, the Internal City Auditors, the Finance Committee, and members
of the City Council. The quarterly report shall include the type of investment,
issuer, date of maturity par and dollar amount invested on all securities,
investments and moneys held by the City. It is also prudent that the quarterly
report include a current market value as of the date of the report.
The quarterly report shall include a statement reciting the compliance of the
City's portfolio of investments to the City's Annual Statement of Investment Policy
and a statement denoting the ability of the City to meet its expenditure
requirements for the next six months. The report shall be submitted within 30
days following the end of the quarter covered by the report.
4. The City Council may grant, as part of the City's investment program, to the City
Treasurer express authority to make investments, no less than three months prior
to the acquisition of the investments, in securities that have, at the time of
investment, a term, or a term remaining to maturity, in excess of five years.
Procedurally, the City Council may grant authority to the City Treasurer to invest
in securities with maturities longer than five years on the occasion of the
submission of the Quarterly Report of Investments to the City Council by the City
Treasurer. This grant of investment authority to the City Treasurer will authorize
the investment of City funds in longer than five-year term investments in the
subsequent quarterly period following the current quarter in which the approval is
granted.
Mr. Bruce V. Malkenhorst
1/20/99
Page 3
5. Monthly, the City Treasurer shall make a report of all investment transactions
involving City funds. The report shall be submitted by memorandum to the City
Council within 10 days following the end of the month covered by the report.
The law authorizes the City Council to delegate its authority to invest the City's funds to
the City Treasurer. This authority to delegate is limited to a one-year period, which the
City Council may renew annually after the Council has reviewed the transactions
undertaken by the City Treasurer.
The City is required to hold a meeting before making any decision that involves
borrowing money in the amount of $100,000 or more. The City Council must discuss,
consider and deliberate each decision to borrow money as a separate item of business on
the agenda of its council meetings.
Government Code Section 53600.3 concerns the prudent investor standard Ding applied
to the City Council and City Treasurer for the investment of City funds and states that
all governing bodies of the City or persons authorized to make investment decisions or
give investment advice of behalf of the City are trustees and therefore fiduciaries subject
to the prudent investor standard. When undertaking this investment function, a trustee
shall act with care, skill and prudence under the circumstances then prevailing, including,
but not limited to, the general economic conditions and the anticipated needs of the
agency.
The California State Legislature recently amended various sections of the California
Government Code concerning the deposit of funds of local agencies and the statements
concerning the investment of funds.
Recent amendments to the Government Code sections which specify percentage
limitations on the amount of funds the City may place in one type of investment have
been loosened a little. Now the percentage limitation is only applicable at the date of
purchase of the investment.
This amendment would impact a local agency's investment portfolio if its surplus funds
decreased over time. Therefore, it would not be necessary for the agency to adjust its
portfolio to conform to the statute's percentage limitations.
Recent legislative amendments also provide that investments in repurchase agreements
shall be in compliance with the Code's requirements concerning the market value of
underlying securities even if the value of the underlying securities falls below 102 , as
long as the securities are brought back up to 102% no later than the next business day.
Mr. Bruce V. Malkenhorst
1/20/99
Page 4
This memorandum is meant to serve as an overview of the requirements of the
Government Code and prudent investment practices and reporting requirements for the
financial affairs of local agencies. Please call me if you need detailed information
regarding these matters or have any questions or comments.
Sincerely,
Eric Fresch
cc: Sharon Johnson