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HomeMy WebLinkAboutItem #04 Investment Policy Revision AGENDA ITEM COVER SHEET Meeting Date: 5/02/06 Item # ~ Contact Name: Contact Number: Wanda Horton 1520 Reviewed By: ~.~. Department Director: _ _ City Manager: -- Subject: Investment Policy Revision Background Summary: The external auditors recommend the City amend its investment policy requiring a cap on the percentage of the portfolio invested in certain types of issues. Issue: Staff was not in compliance with the City's investment policy during FY2005. Interest rates on an issue type which is restricted to only 25% of the portfolio offered an opportunity to earn the highest yield at the time of investing. Staff took advantage of the opportunity thus exceeding the 25% cap. Recommendations Staff recommends the Commission approve the revised Investment policy reflecting the removal of the percentage caps contained in the policy which appeared under Authorized Investments and Maximum Maturities (p.4). Attachments: Revised investment policy. Financial Impact: This action has no immediate financial impact but could allow for maximizing interest earnings in the future. Type of Item: (please mark with an "x') Public Hearing _ Ordinance First Reading _ Ordinance Second Reading Resolution Commission Approval Discussion & Direction For Clerk's Deat Use: _ Consent Agenda _ Public Hearing _ Regular Agenda _ Original Document/Contract Attached for Execution by City Clerk _ Original Document/Contract Held by Department for Execution Reviewed by City Attorney Reviewed by Finance Dept. Reviewed by ( ) e4~ N/A N/A N/A City of Ocoee Investment Policy and Plan PURPOSE The purpose of this policy is to set forth the requirements and objectives governing the investment management of the City's cash reserves, including any public funds in excess of amounts needed by the City to meet current expenses. The City recognizes that liquidity needs must be met and has established cash flow projections for the debt service funds, capital project funds, general operating funds and enterprise funds. SCOPE This investment policy applies to all the investment activity of the City of Ocoee, except for employee pension funds which are organized and administered separately. Funds subject to this policy include: . General Fund . Special Revenue Funds . Capital Projects Funds . Enterprise Funds . Debt Service Funds . Any new fund created by the City, unless specifically exempt at its inception and/or by state statute or federal law. OBJECTIVES The primary objectives for the City's cash reserves are first, protection and safety of the City's funds, second, provision for liquidity, and third, maximized return on the portfolio but minimized risk, in that order. The investment portfolio will maintain sufficient liquidity to ensure cash availability for operating cash flow requirements. Funds of the City will be invested and handled in accordance with sections 166.261 and 218.415 and Chapter 280, Florida Statutes, this policy and City Resolution 94-08. DELEGATION OF AUTHORITY The Finance Director and Finance Manager are designated as Investment Officers of the City and are responsible for investment decisions and activities, under the direction of the City Manager. The investment officers will complete eight (8) hours of continuing education annually in subjects or courses of study related to investment practices and products. The daily administration of the cash management program is handled by the Finance Director. No person may engage in an investment transaction City of Ocoee Investment Policy and Plan Page two except as provided under the terms of this policy and the procedures so established. The City may appoint an outside investment manager as "Agent" for the City's cash reserves. Positions authorized as investment signatories are City Manager, Finance Director, and Finance Manager. The persons holding these positions are also authorized to initiate wire transfers for the City in conformance with Resolution 94-08. Investment transactions shall be approved by any two of the above signatories as required. PRUDENCE AND ETHICAL STANDARDS The level of prudence and ethical standards to be applied by the investment officers shall be the "Prudent Person Rule" as it appears in the Government Finance Officers Association's Committee on Cash Management's Model Investment Legislation, which states: "Investments shall be made with judgment and care, under circumstances then prevailing, which persons of prudence, discretion, and intelligence exercise in the management of their own affairs, not for speculation, but for investment, considering the probable safety of their capital as well as the probable income to be derived from the investment." The "Prudent Person Rule" shall be applied in the context of managing the overall portfolio. The investment officers and staff, acting in accordance with the written procedures and exercising due diligence, shall not be held personally responsible for a specific security's credit risk or market price changes, provided that any changes in the credit risk or market price are reported immediately to the Financial Advisors and that appropriate action is taken to control adverse developments. INTERNAL CONTROLS The Investment Officers shall establish and monitor internal and procedural controls designed to protect the City's assets and ensure proper accounting and reporting of the related transactions. Such controls shall include but not be limited to the following: . Transfer of all funds (purchases, sales, etc.) through a central account only . Separation of functions including transaction authority from accounting and recordkeeping . Custodial safekeeping . Avoidance of bearer- form or non wire able securities . Delegation of authority to staff members . Written confirmation of telephone transactions . Supervisory control of employee actions City of Ocoee Investment Policy and Plan Page three . Specific guidelines regarding securities losses and remedial action . Documentation of transaction by investment officials . Review of selected investment transactions by external Auditors All securities purchased by and all collateral obtained by the City shall be properly designated as an asset of the City. All securities purchased will be transferred when possible only under the "delivery versus payment" (D.V.P.) method but on all securities sold on the "payment versus delivery" method to insure that funds for securities are not released until all criteria relating to the specific transaction are met. The Investment Officers are authorized to accept, on behalf of and in the name of the City of Ocoee, bank trust receipts or confirmations from a third party custodian in return for investment of temporarily idle funds as evidence of actual delivery of the obligations or securities. Any such trust receipt or confirmation shall fully describe the various obligations or securities held, together with the specific number of each obligation or security held, and that they are held for the City in the city's name. The actual obligations or securities, whether in book entry or physical form, on which trust receipts or confirmations are issued may be held by a bank/depository chartered by the United States Government or the State of Florida. The internal controls set forth in this policy shall be reviewed by the independent auditors of the City as part of any financial audit periodically required of the City. MONITORING AND ADJUSTING THE PORTFOLIO The Investment Officers will routinely monitor the contents of the portfolio, the available markets and the relative values of competing instruments and will adjust the portfolio accordingl y. AUTHORIZED INSTITUTIONS AND DEALERS The City shall purchase securities only through qualified public depositories of the State of Florida as identified by the State Treasurer, in accordance with Chapter 280 of the State Statutes. Repurchase agreements shall only be entered into with primary securities dealers and financial institutions which are state qualified public depositories. City of Ocoee Investment Policy and Plan Page four Before engaging in investment transactions with an institution, the investment officers shall receive a signed certification form attesting that the individual responsible for the City's account with that firm has reviewed the City's investment policy and that they agree to undertake reasonable efforts to preclude imprudent transactions involving City funds or transactions in violation of the City's investment policy. SECURITY SELECTION PROCESS The investment officers shall select the security which provides the highest rate of return within the parameters of this policy and given the current objectives and needs of the City's portfolio when purchasing or selling securities,. The City shall utilize the competitive bid process to select the securities to be purchased or sold when feasible and appropriate. AUTHORIZED INVESTMENTS AND MAXIMUM MATURITIES Cash in bank and cash reserves of the City of Ocoee may be invested only in the following and for the maturities indicated: 1. Treasury Bills, Notes and Bonds -with maturity dates within five years or less 2. Insured or fully collateralized Certificates of Deposit of banks -must be a state-certified public funds depository in the State of Florida, as defined in Section 280.02, Florida Statutes -maturities of three years or less 3. Full faith or general faith and credit obligations of the United States Government or United States Government Agency Securities. -maximum maturity shall be five years or less 4. Repurchase Agreements a) Term Repurchase Agreements collateralized by U.S. Treasury Securities and market-to-market -purchased only from authorized dealers as provided for in this policy -any authorized institution with whom the City transacts repurchase agreements must have on file a fully executed copy of the City's Master Repurchase Agreement -must adhere to requirements of the City's Master Repurchase Agreement City of Ocoee Investment Policy and Plan Page five b) Overnight (sweep) Repurchase Agreements collateralized by full faith or general faith and credit obligations of the United States Government or United States Government Agency securities. -purchased only from the City's contracted banking service provider -securities used as collateralization for the overnight (sweep) Repurchase Agreement will be held for the benefit of the City with a third party, the Federal Reserve Bank or the contracted bank's correspondent bank in an amount not less than 101 % of the overnight amount of the Repurchase Agreement -any authorized institution with whom the City transacts overnight (sweep) repurchase agreements must have on file an executed copy of the City's Master Repurchase Agreement for overnight repurchases and an executed Sweep Investment Service Agreement -must adhere to requirements of the City's Master Repurchase Agreement 5. State Board of Administration local government surplus funds investment pool. 6. State Board of Administration intermediate term investment pool. 7. Money Market funds placed only with financial institutions qualifying as public depositories as provided for in Chapter 280, Florida Statutes. 8. Securities of, or other interests in, any open-end or closed-end management type investment company or investment trust registered under the Investment Company Act of 1940, provided the portfolio of such investment company or investment trust is limited to United States Government obligations and to repurchase agreements full collateralized by such United States Government obligations. Investment in derivative products and the use of reverse repurchase agreements or other forms of leverage is prohibited. To the extent possible, the investment officers shall attempt to match investment maturities with known cash needs and anticipated cash-flow requirements. DEBT SERVICE REQUIREMENTS Any debt service requirements or bond covenants will supersede this investment policy. City of Ocoee Investment Policy and Plan Page six EXISTING INVESTMENTS Any investments currently held that do not meet the guidelines of this policy, shall be exempted from the requirements of this policy. At maturity or liquidation, such monies so invested shall be reinvested only as provided for in this policy. DIVERSIFICATION. LIQUIDITY AND RISK The Investment Officers shall diversify use of investment instruments to avoid incurring unreasonable risks inherent in over investing in specific instruments, individual financial institutions or maturities. Diversification strategies shall be determined and revised periodically by the Investment Officers. Liquidity shall be assured through practices ensuring that funds are readily available for current liabilities when due. Minimizing credit risk will be accomplished by limiting the maximum percentage that may be invested in anyone entity or instrument at anyone time, as outlined in this policy. ACCOUNTING METHOD Investments will be carried at fair value. Gains or losses from investments will be credited or charged to investment income at the time of sale. Premiums of discounts on securities may be amortized over the life of the securities. The City shall comply with Government Accounting Standards Board (GASB) requirements. REPORTING The Investment Officers shall submit quarterly investment reports to the City Commission that summarizes types of investments and quarterly yield. The report shall include securities in the portfolio by class or type, book value, income earned and market value as of the report date. Such reports shall be available to the public. investmentpolicy.doc 04/07/0612:17 PM