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9 <br />expectations are reported in a timely fashion and appropriate action is taken to control adverse <br />developments. <br /> <br />3. Ethics and Conflicts of Interest <br />Employees involved in the investment process shall refrain from personal business activity <br />that could conflict with the proper execution and management of the investment program, or <br />that could impair their ability to make impartial decisions. They shall further disclose any <br />personal financial/investment positions that could be related to the performance of the <br />investment portfolio. Employees and officers shall refrain from undertaking personal <br />investment transactions with the same individual with whom business is conducted on behalf <br />of the City. <br /> <br />Authorized Financial Institutions, Depositories, and Broker/Dealers <br /> <br />The Finance Director will maintain a list of financial institutions and depositories authorized to <br />provide investment services. Annually, the Finance Director will obtain the Minnesota Broker <br />Notification and Certification form required by Minnesota Statutes 118A prior to any investment <br />transactions with the City. <br /> <br />Authorized Investments <br /> <br />The City will invest only in securities authorized by Minnesota Statute §118A.04 and §118A.05. <br /> <br />Investment instruments authorized and permitted by this policy are as follows: <br />1. United States Securities. City funds may be invested in governmental bonds, notes, bills, <br />mortgages (excluding high-risk mortgage-backed securities as defined in Minnesota <br />Statute §118A.04) and other securities, which are direct obligations or are guaranteed or <br />insured issues of the United States, its agencies, its instrumentalities, or organizations <br />created by an act of Congress. <br /> <br />2. State and Local Securities. City funds may be invested in the following: <br />A. Any security which is a general obligation of any state or local government with <br />taxing powers which is rated “A” or better by a national bond rating service <br />(including Debt issued by the City of Little Canada). <br />B. Any security which is a revenue obligation of any state or local government with <br />taxing powers which is rated “AA” or better by a national bond rating service <br />(including Debt issued by the City of Little Canada). <br />C. A general obligation of the Minnesota Housing Finance Agency which is a moral <br />obligation of the State of Minnesota and rated “A” or better by a national bond <br />rating agency. <br /> <br />3. Commercial Paper. City funds may be invested in commercial paper issued by United <br />States Corporations or their Canadian subsidiaries that are rated in the highest quality <br />category by at least two nationally recognized rating agencies and matures in 270 days or <br />less. <br /> <br />4. Time Deposit. City funds may be invested in time deposits that are fully insured by the <br />FDIC or bankers acceptances’ of United States banks.