Agenda Packets - 2005/05/09 - Laserfiche WebLink

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2. Ethics and Conflicts of Interest The Treasurer Officers and employees involved in the investment process shall refrain from personal business activity that could conflict with the proper execution and management of the investment program, or that could impair their ability to make impartial decisions. The Treasurer Officers and employees shall disclose any material interests in financial institutions with which they conduct business. They shall further disclose any personal financial/investment positions that could be related to the performance of the investment portfolio. The Treasurer Officers and employees shall refrain from undertaking personal investment transactions with the same individual with whom business is conducted on behalf of the City. 3. Delegation of Authority Authority to manage the investment program is granted to the Finance Director hereinafter referred to as the Treasurer and derived from the following: Annual Resolution Appointing Official Newspaper, Acting Mayor, Official Depository, and Treasurer. Responsibility for the operation of the investment program is hereby delegated to the Treasurer, who shall act in accordance with established written procedures and internal controls for the operation of the investment program consistent with this investment policy. Procedures should include references to: safekeeping, delivery vs. payment, investment accounting, repurchase agreements, wire transfer agreements, and collateral/depository agreements. [Please refer to GFOA’s Investment Procedures Manual, 2003.] No person may engage in an investment transaction except as provided under the terms of this policy and the procedures established by the Treasurer. The Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. V. Authorized Financial Institutions, Depositories, and Broker/Dealers 1. Authorized Financial Institutions, Depositories, and Broker/Dealers A list will be maintained of financial institutions and depositories authorized to provide investment services. In addition, a list will be maintained of approved security broker/dealers selected by creditworthiness (e.g., a minimum capital requirement of $10,000,000 and at least five years of operation). These may include "primary" dealers or regional dealers that qualify under Securities and Exchange Commission (SEC) Rule 15C3-1 (uniform net capital rule). All financial institutions and broker/dealers who desire to become qualified for investment transactions must supply the following as appropriate: • Audited financial statements demonstrating compliance with state and federal capital adequacy guidelines • Proof of National Association of Securities Dealers (NASD) certification (not applicable to Certificate of Deposit counterparties) • Proof of state registration • Completed broker/dealer questionnaire (not applicable to Certificate of Deposit counterparties) • Certification of having read and understood and agreeing to comply with the [entity's] investment policy. • Evidence of adequate insurance coverage. An annual review of the financial condition and registration of all qualified financial institutions and broker/dealers will be conducted by the Treasurer. (See Appendix for the GFOA Recommended Practice on “Governmental Relationships with Securities Dealers.”)