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<br />VI. Safekeeping and Custody Internal Controls <br /> <br />1. Delivery vs. Payment <br />All trades of marketable securities will be executed by delivery vs. payment (DVP) to ensure that <br />securities are deposited in an eligible financial institution prior to the release of funds. <br /> <br />2. Safekeeping <br />Securities will be held by a [centralized] independent third-party custodian selected by the entity as <br />evidenced by safekeeping receipts in the City’s name. The safekeeping institution shall annually <br />provide a copy of their most recent report on internal controls (Statement of Auditing Standards No. <br />70, or SAS 70). <br /> <br />3. 1. Internal Controls <br />The Finance Director is responsible for establishing and maintaining an internal control structure <br />designed to ensure that the assets of the City are protected from loss, theft or misuse. Details of <br />the internal controls system shall be documented in an investment procedures manual and shall <br />be reviewed and updated annually. The internal control structure shall be designed to provide <br />reasonable assurance that these objectives are met. The concept of reasonable assurance <br />recognizes that (1) the cost of a control should not exceed the benefits likely to be derived and <br />(2) the valuation of costs and benefits requires estimates and judgments by management. <br /> <br />The internal controls structure shall address the following points: <br /> <br />• Avoidance of physical delivery securities <br />• Written confirmation of transactions for investments and wire transfers <br />• Password protected authorizations of wire transfers <br />• Development of a wire transfer agreement with the lead bank <br />Accordingly, the investment officer shall establish a process for an annual independent review <br />by an external auditor to assure compliance with policies and procedures or alternatively, <br />compliance should be assured through the City’s annual independent audit. <br /> <br /> <br />VII. Suitable and Authorized Investments <br /> <br />1. Investment Types <br />Consistent with the GFOA Policy Statement on State and Local Laws Concerning Investment <br />Practices, the following investments will be permitted by this policy and are those defined by <br />state and local law where applicable: <br />• U.S. Treasury obligations which carry the full faith and credit guarantee of the United States <br />government and are considered to be the most secure instruments available; <br />• U.S. government agency and instrumentality obligations that have a liquid market with a readily <br />determinable market value; <br />• Certificates of deposit and other evidences of deposit at financial institutions, <br />• Bankers' acceptances; <br />• Commercial paper, rated in the highest tier (e.g., A-1, P-1, F-1, or D-1 or higher) by a nationally <br />recognized rating agency; <br />• Money market mutual funds regulated by the Securities and Exchange Commission and whose <br />portfolios consist only of dollar-denominated securities; and