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<br />. <br /> <br />. <br /> <br />. <br /> <br />2. Ethics and C01?tlicls (?t1111/!/"CSI <br />The Treasurer OCficers and employee~; inyol';ed in the investment proee~;s shall refi'ain from personal <br />business activity that could conflict with the proper execution and management ofthe investment <br />program. or that could impair their ability to make impmtial decisions. The Treasurer Officers and <br />employee:; shall disclose any material interests in financial institutions \"ith which they conduct <br />business. They shall further disclose any personal financial/investment positions that could be related <br />to the performance of the investment p0l1folio. The Treasurer Officers and employees shall reCrain <br />from undeltaking personal investment transactions with the same individual with whom business is <br />conducted on behalf of the City. <br /> <br />3. Delegal ion qj'A /II hori~\' <br />Authority to manage the investment program is granted to the Finance Director hereinafter rcrerred to <br />as--tHe Treasurer and derived fi'om the following: Annual Resolution Appointing Official Newspaper. <br />Acting Mayor. Official Depository. and Treasurer. Responsibility for the operation of the investment <br />program is hereby delegated to the Treasurer. who shall act in accordance with established written <br />procedures and internal controls for the operation of the investment program consistent with this <br />investment policy. Procedures should include relerences to: safekeeping. delivery vs. payment. <br />investment accounting. repurchase agreements. wire transfer agreements, and collateral/depository <br />agreements. [Please refer to GFOA's 1II1'est111elll Procedures A/milia!. :l003.} No person may engage <br />in an investment transaction except as provided under the terms of this policy and the procedures <br />established by the Treasurer. The Treasurer shall be responsible for all transactions undertaken and <br />shall establish a system oC controls to regulate the activities of subordinate orticials. <br /> <br />V. Authorized Financial Institutions, Depositories, and Brokerillealers <br /> <br />I. A/llhori::.ed Final1c;alll1stilutiol1s, Depositories, and Brokeli'Dcal/!/"s <br />A list will be maintained of financial institutions and depositories authorized to provide investment <br />services. In addition. a list will be maintained of approved security broker/dealers selected by <br />creditw0l1hiness (e.g., a min imum capital requirement of $ I 0.000.000 and at least five years of <br />operation). These may include "primary" dealers or regional dealers that quali(y under Securities and <br />Exchange Commission (SEC) Rule 15C3-1 (unili.mn net capital rule). <br /> <br />Alllinancial institutions and broker/dealers who desire to become qualified for investment <br />transactions must supply the following as appropriate: <br />. Audited financial statements demonstrating compliance with state and federal capital adequacy <br />guidelines <br />. Proof of National Association of Securities Dealers (NASD) cel1ification (not applicable to <br />Certilicate of Deposit counterpmiies) <br />. Proof of state registration <br />. Completed broker/dealer questionnaire (not applicable to Certificate of Deposit counterpaJiies) <br />. Certification of having read and understood and agreeing to comply with the r entity'sJ investment <br />policy. <br />. l:vidence of adequate insurance coverage. <br /> <br />An annual review of the financial condition and registration of all qualilicd financial institutions and <br />broker/dealers will be conducted by the Treasurer. (See Appendix for the GFOA Recommended <br />Practice on "Governmental Relationships with Securities Dealers.") <br />