CC Resolution 9450
RESOLUTION NO. 9450
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF CAMPBELL APPROVING THE ANNUAL UPDATE TO THE INVESTMENT
POLICY AND RELATED ADMINISTRATIVE POLICY REVISIONS
WHEREAS, Government Code Section 53646 requires a statement of Investment
Policy be submitted to the City's legislative body annually for its consideration at a public
hearing; and
WHEREAS, there has been submitted to the City Council a statement of the City's
Investment Policy; and
WHEREAS, the Policy has been reviewed by the City Council;
NOW, THEREFORE, BE IT RESOLVED, by the City Council of the City of
Campbell that the changes to the Investment Policy and related Administrative Policy be
approved as submitted.
PASSED AND ADOPTED the 2nd day of November, 1998 by the following roll call
vote:
AYES:
Councilmembers Conant, Furtado, Dougherty, Dean, Watson
NOES:
Councilmembers None
ABSENT:
Councilmembers None
APPROVED:
A~
~
Anne Bybee, CIty Clerk
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
I. PURPOSE
It is the policy of the City of Campbell to invest public funds in a prudent manner which will
provide the maximum security while meeting the daily cash flow needs and conforming to all
statutes governing the investment of public funds.
The purpose of this document is to identify the policies guiding prudent investment of the City
and Redevelopment Agency's temporarily idle funds and to establish guidelines and objectives
for suitable investments including delegation of authority, prudence, monitoring and reporting,
policy review, diversification, eligible securities, safekeeping, collateralization, selection of
depositories, brokers/dealers, glossary of terms, and forms utilized.
II. SCOPE
A. This investment policy shall apply to all financial assets, investment activities, and debt
issues of the City of Campbell and the Campbell Redevelopment Agency including the
following fund types:
1. General Fund
2. Special Revenue Funds
3. Debt Service Funds
4. Capital Projects Funds
5. Internal Service Funds
6. Trust and Agency Funds
B. The policy does not cover funds held by the Public Employees Retirement System nor
funds of the Deferred Compensation program.
III. OBJECTIVES
A. It is the objective of this policy to provide a system which will monitor and forecast
revenues and expenditures so that the City and the Redevelopment (RDA) Agency can
invest temporarily idle funds to the fullest extent possible. The temporarily idle funds
shall be invested in accordance with provisions of California Government Code Section
53600 et. seq.
B. The City and RDA adhere to conservative investment philosophies including investment
of all idle cash, buying and holding until maturity, preservation of principal at the risk
of yield, and not "actively" trading the investment portfolio.
C. This policy specifically prohibits trading securities for the sole purpose of speculating
on the future direction of interest rates. It further prohibits reverse repurchase
agreements, use of derivative products, and/or leveraging of the portfolio.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
D. The City and Redevelopment Agency shall insure the safety of invested funds by
limiting credit and interest rate risks. The three primary objectives of the City's
Investment Policy in order of priority are:
1.
Safety:
Safety of principal is the foremost objective of the City of
Campbell. Safety and the minimizing of risk associated with
investing refers to attempts to reduce the potential for loss of
principal, interest or a combination of the two. The City ensures
safety of its invested idle funds and limits credit and interest rate
risks by the following (all of which are detailed within the body of
the Investment Policy):
a. Investing only in those instruments that are generally
accepted as safe investment vehicles for local
government as authorized by this Policy,
b. Pre qualifying the financial institutions and limiting
broker/dealer to primary dealers with order desks
located in California,
c. Diversifying the investment portfolio as prescribed
within this Policy,
d. Structuring the portfolio such that securities mature to
meet the City's cash requirements for ongoing
operations, thereby avoiding the need to sell securities
on the open market prior to their maturation, and
e. Limiting the weighted average maturity of the portfolio
to two years.
f. The physical security or safekeeping of the City's
investments is also an important element of safety.
2. Liquidity: Liquidity is the second most important objective of the City's
Policy. Liquidity refers to the ability to convert an investment to
cash promptly without loss of principal and minimal loss of
interest. For example, this is accomplished by investing either in
the Local Agency Investment Fund (LAIF) with 24-hour fund
availability, or investing in securities with active secondary or
resale markets.
3. Yield: Yield on the City's portfolio is last in rank among investment
objectives. Investments are limited to relatively low risk securities
in anticipation of earning a fair return relative to the risk being
assumed.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Date:
Subject:
INVESTMENT POLICY
November 2, 1998
IV. STRUCTURE AND RESPONSIBILITY
A. DELEGATION OF AUTHORITY:
1. The City Council assumes direction over City and RDA investments, and
assigns management responsibility for the investment program to the Finance
Director, who shall serve as Chief Fiscal Officer, and have legal custody of
funds. The Finance Director may provide for delegation of his/her
responsibilities to other persons under his/her control responsible for
investment transactions, including designation of certain portions of the
investment portfolio related to debt financing to be administered by professional
portfolio administrators, i.e, California Arbitrage Management Program
(C.A.M.P.) or such other designated administrators approved by the Finance
Sub-Committee.
B. POLICY REVIEW:
1. This Investment Policy shall be reviewed and approved annually.
C. RESPONSIBILITIES:
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1.
Responsibilities of the City Council: The City Council consists of a Mayor and
four Council members and is the policy setting board for the City of Campbell.
The City Council has considered and adopted a written Investment Policy for
the City of Campbell and the Campbell Redevelopment Agency. Pursuant to the
City's Financial Policies, the City Council shall on an annual basis, approve
necessary changes to the Investment Policy as recommended by the Finance
Sub-Committee. On a monthly basis, the City Council shall receive, review and
accept the Monthly Investment Report submitted by the Accounting Manager.
2.
Responsibilities of the Finance Sub-Committee: The Finance Sub-Committee
consists of two Council members, the City Manager, the Finance Director, and
the Accounting Manager. On an annual basis, this Sub-Committee shall review
necessary revisions to the established Investment Policy of the City of Campbell
and the Campbell Redevelopment Agency and make a recommendation to the
City Council accordingly. No less than once per fiscal year, the City's
investment strategy will be reviewed by the Finance Sub-Committee. A
summary of the investment strategy will be shared with the City Council at that
time. Should market activity encourage revisions in the City's strategy, the
Finance Sub-Committee shall be advised accordingly.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
3. Responsibilities of the City Manager: The City Manager is responsible for
directing and supervising the Finance Director. He/she has the responsibility of
keeping the City Council fully advised as to the financial condition of the City.
a. Wire Transfer Authority: The City Manager has wire transfer
authority for transfers up to of $5,000,000 for a single transaction. Such a
transaction requires joint review, approval and verification in advance by
the City Manager and Finance Director. The transaction shall be
highlighted in the Monthly Investment Report to Council.
4. Responsibilities of the Finance Director: The Finance Director is appointed
by the City Manager and serves as Chief Fiscal Officer. He/she is subject to the
direction and supervision of the City Manager. The Finance Director is charged
with the responsibility for the conduct of all Finance Department functions
including the custody and investment of City and RDA funds, and investment of
those funds in accordance with principles of sound treasury management and in
accordance with applicable laws and policies. Refer to "Delegation of
Authority" for additional information pertaining to delegation of investment
responsibilities.
a. Wire Transfer Authority: The Finance Director has wire transfer
authority not to exceed $5,000,000 for a single transaction. Such a
transaction shall be reviewed, approved and verified in advance by the City
Manager. The transaction shall be highlighted in the Monthly Investment
Report to Council.
5. Responsibilities of the Accounting Manager: The Accounting Manager is
appointed by the Finance Director and serves as the Investment Manager for the
City and RDA pursuant to specific delegation authority provided by this
Investment Policy. He/she is subject to the direction and supervision of the
Finance Director and is charged with the responsibility and conduct of the day-
to-day accounting and cash management functions of the City and RDA. This
includes the custody and investment of City and RDA funds, and investment of
those funds in accordance with principles of sound treasury management and in
accordance with applicable laws and policies. Refer to "Delegation of
Authority" for additional information pertaining to delegation of investment
responsibilities.
Implementation and maintenance of the Investment Policy are the responsibility
of this individual. On an annual basis, the Accounting Manager shall present to
the Finance Sub-Committee, recommended changes to the City's Investment
Policy. On a monthly basis, the Accounting Manager shall present to the City
Council a Monthly Investment Report. Refer to "Monitoring and Reporting"
for additional information.
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CITY OF CAl\1PBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
a. Wire Transfer Authority: The Accounting Manager has wire transfer
authority not to exceed $3,000,000 for a single investment transaction.
Such a transaction shall be reviewed, approved and verified in advance by
the Finance Director, and shall be highlighted on the Daily Investment
Transaction Form. The transaction must also be reported in the Monthly
Investment Report to Council.
6. Responsibilities of the Accountant: The Accountant is appointed by the
Finance Director and is subject to the direction and supervision of the
Accounting Manager. The Accountant carries out the specific instructions
provided by the Accounting Manager regarding the purchase and sale of
securities in accordance with principles of sound treasury management and in
accordance with applicable laws and policies. Accounting for the various
investment transactions is the responsibility of the Accountant.
a. Wire Transfer Authority: The Accountant has wire transfer authority
not to exceed $500,000 for a single investment transaction. The standard
operating procedure is that all cash and investment wire transfers made by
the Accountant are reviewed, approved and verified in advance by the
Accounting Manager, and are reported both on the Daily Investment
Transaction Form and in the Monthly Investment Report to Council.
D. Prudence:
1.
It is the understanding of the individuals holding pOSitIOns with investment
responsibilities that the "prudent person" rule applies. This means that
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 and income to be derived.
2.
This standard of prudence shall be applied in the context of managing the City
and RDA's investment portfolio. If individuals having investment
responsibilities act in accordance with written policies/procedures and exercise
due diligence in performing their duties shall be relieved of personal
responsibility in the event of principal or interest losses to the portfolio,
provided that the Finance Director, City Manager and City Council are advised
in writing in a timely fashion, and appropriate action is taken to control adverse
developments should they occur.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
E. Ethics and Conflicts of Interest:
1. Those involved in the investment process shall refrain from personal business
activity that could conflict with proper execution of the investment program, or
which could impair their ability to make impartial investment decisions. A
mandatory disclosure is required of any material financial interests in financial
institutions that conduct business within this jurisdiction, and they shall further
disclose any large personal financiallinvestment positions that could be related to
the performance of the City and the RDA, particularly with regard to the time
of purchases and sales.
F. Conflict with State Statutes or Regulations
1. Any conflict between the City of Campbell Investment Policy and Government
Code Section 53600 et seq., shall be interpreted in favor of the Government
Code.
V. MONITORING AND REPORTING
A. The Finance Director shall routinely monitor the contents of the portfolio and shall file
with the City Council the Accounting Manager's Investment Report within 30 days of
the end of the quarter. The report shall include the following on all invested monies:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
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Type of Investment and Issuer
Beginning Balances
Purchases During Month
Maturities or Sales During the Month
Ending Balances
Maturity Date
Weighted Average Maturity
Interest Rate
Weighted Average Yield
Face Value or Purchase Cost
Market Value including source
Interest Earned During Month
Interest Earned to Maturity
Cash Flow Projection for the Following Month
Summary of Cash Invested to Total Cash Balances
Comparative Statistics by Fiscal Year
Reconciliation of Cash & Investments to General Ledger
Balances
Schedule ofInvestments Beyond 5 (Five) Years
Investments under the Management of Contracted Parties
Statement of Compliance with the Investment Policy
Statement of Ability to Meet Obligations of Next Six Months
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
B. Upon Council's approval of the Monthly Investment Report, a copy shall be
distributed to the "Elected" City Treasurer.
C. Each time an investment transaction is made, an "Investment Transaction
Record" form shall be prepared by the Accountant and approved by the
Accounting Manager. Copies of the form are to be distributed to the City
Manager, City Treasurer and Finance Director. (See Exhibit A.)
VI. SELECTION OF BROKERS. DEALERS AND INSTITUTIONS
A. Brokers/Dealers:
1. In selecting brokers or dealers, the Finance Director or designated staff
member shall select brokers representing primary dealers in government
securities that have established offices and order desks within the State of
California.
2. Before accepting funds or engaging in investment transactions with the
City, the supervising officer at each depository and recognized securities
broker/dealer shall submit a certification that the officer has reviewed the
investment policies and objectives and agrees to disclose potential
conflicts or risks to public funds that might arise out of business
transactions between the firm/depository and the City of Campbell.
3. A current audited financial statement is required to be on file for each
financial institution and broker/dealer with which the City of Campbell
invests.
VII. SAFEKEEPING AND COLLATERALIZATION
A. Safekeeping:
1.
The City shall contract with a bank or banks for the safekeeping of
securities which are owned by the City and/or RDA as a part of the
investment portfolio. Staff shall periodically review the performance and
pricing of the third-party, safekeeping agent services.
2.
All investment securities (except the collateral for certificates of deposit
in banks, and/or savings and loans) purchased by the City shall be held in
third-party safekeeping by an institution designated as primary agent.
The primary agent shall issue a safekeeping receipt to the City listing the
specific instrument, rate, maturity and other pertinent information.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
B. Collateralization:
1. Deposit-type securities (i.e. certificates of deposit) shall be collateralized
through the State of California collateral pool requirements for any
amount exceeding FDIC coverage in accordance with California
Government Code Section 53652 and/or 53651(m) (1). Collateral for
certificates of deposit in savings and loans shall be held with the Federal
Home Loan Bank. Collateral for certificates of deposit in banks shall be
held in the City's name in the bank I s trust department, (if a safekeeping
agreement has been executed) or, alternatively, in the San Francisco
Federal Reserve Bank.
2. Other securities shall be collateralized by the actual security held in third-
party safekeeping by the primary agent.
VIII. DIVERSIFICATION AND ELIGIBLE SECURITIES
A. Diversification:
1.
The City will diversify use of investment instruments to avoid incurring
unreasonable risks in overinvesting in specific instruments, individual
financial institutions or maturities.
2.
Investment officials shall recognize that the investment portfolio is subject
to public review and evaluation. The overall program shall be designed
and managed with a degree of professionalism worthy of the public trust.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
November 2, 1998
Date:
B. Eligible Investments & Criteria:
The following is a summary of the authorized investment instruments and limitations:
~ Location Guarantee Limits Maturity
Local Agency Investment California State Fund Allowable limit On Demand
Fund (LAIF) (currently $30 Million
per agency)
V.S. Treasury Bills, 50 % of Portfolio
Notes & Bonds nla V. S. Treasury 5 Years *
V. S. Government Agency n/a V. S. Treasury 50 % of Portfolio 5 Years *
Issues (e.g. F.N.M.A., or Government
G.N.M.A., etc.) Agency
Banker's Major banks & Accepting 30 % of Portfolio 270 Days *
Acceptances reporting dealers Bank
wIth an A-I rating
or better
Certificates of Deposit California FD I C insured 25 % of portfolio 5 years *
with banks or savings first $100,000. and $1 Million in
and loan associations Amounts above anyone institution.
FD I C insurance The ratio of such
shall be de~sits in Savings
collateralized & oans shall be
per this policy such that at any time,
deposits shall not
exceed 40 % of the
totals in Banks and
Savings & Loans
Repurchase Major banks & Issuing Bank/ 10% of Portfolio 15 days*
Agreements reporting dealers collateralized must have signed
wIth an A-I rating Master Repurchase
or better Agreement
Commercial Domestic V.S. Corps. Corporation 15 % of Portfolio 180 Days*
Paper meeting Gvmnt. Liquidity
Code requirements
and having an A liP 1
rating or better
Diversified
manage~ent
compames
attaining highest
ranking by 2 out of
3 largest, national
rating agencies having
an investment advisor
registered with the
S.E.C. and ,having five
years expenence III
public entity investment
Maximum term unless expressly authorized by the City Council three months prior to purchase.
Mutual Funds
invested in securities and
obligations authorized by
subdivisions (a) through
(m) of Section 53601 of
the Calif. Government
Code unless further
restricted by the City I S
Investment Policy
*NOTE:
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Fund assets
and net worth
(N 0 stated
guarantee)
15 % of Portfolio
5 Years *
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Attachment A
City of Campbell
Investment Transaction Record
To Be Used For Each Investment Transaction
Date:
Value @ Par:
Financial Institution:
Type of Investment:
Term:
Maturity Date:
Daily Interest Rate:
%
AS of Date
Cost:
Quarterly Interest Rate:
%
AS of Date
Was Collateral Waived?
Interest Payable At:
Type of Collateral:
Collateral and/or
Securities Held By:
L.A.I.F. Transaction:
Source of Funds
(Deposit Amount)
L.A.I.F. Transaction:
Purpose:
(Withdrawal Amount)
L.A.I.F. Reference:
(Contact Person)
(Confirmation Number)
Early Withdrawal Penalties:
How was Transaction Handled?:
Reference:
Other Quotation Received:
Institution
Type of Instrument
Interest Rate
Prepared By
Date
Reviewed By
Date
cc: City Treasurer - City Manager - Finance IJire('for
Cshrpt99 Investments
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
EXHIBIT B
GLOSSARY OF ELIGIBLE INVESTMENTS
Local Agency Investment Fund (L.A.I.F.). The L.A.J.F. was established by the state of
California to enable treasurers to place funds in a pool for investments. There currently is a
limitation of $~ $30 million per agency subject to a maximum of 10 total transactions per
month. The City of Campbell uses this fund when interest rates are declining as well as for
short -term investments and liquidity.
U.S. Treasury Bills. Commonly referred to as T-Bills, these are short-term marketable
securities sold as obligations of the U. S. Government. They are offered in three month, six
month, and one-year maturities. T-Bills do not accrue interest but are sold at a discount to pay
face value at maturity.
U.S. Treasury Notes. These are marketable, interest-bearing securities sold as obligations of
the U.S. Government with original maturities of one to ten years. Interest IS paid
semi-annually.
U.S. Treasury Bonds. These are the same as U.S. Treasury Notes except they have original
maturities of ten years or longer.
U.S. Government Agency Issues. Include securities which fall into these categories: 1) Issues
which are unconditionally backed by the full faith and credit of the United States, 2) Issues
which are conditionally backed by the full faith and credit of the United States and 3) Issues
which are not backed by the full faith and credit of the United States.
Issues which are unconditionally backed by the full faith and credit of the United States
include: Small Business Administration (SBA), General Services Administration (GSA).
Issues which are not backed by the full faith and credit of the United States include: Federal
National Mortgage Association (FNMA), Federal Home Loan Bank (FHLB), Federal Farm
Credit Bank (FFCB) , Banks for Cooperation (Co-ops), Federal Lands Banks (FLB), Federal
Intermediate Credit Banks (FICB).
While all the above issues are not unconditionally backed by the full faith and credit of the
United States, they do in fact have de facto backing from the federal government, and it would
be most unlikely that the government would let any of these agencies default on its obligations.
Banker's Acceptance. This is a negotiable time draft (bill of exchange) with a maturity of six
months or less drawn on and accepted by a commercial bank. Banker's Acceptance are usually
created to finance the import and export of goods, the shipment of goods within the United
States and storage of readily marketable commodities. Per State Law, cities may not invest
more than 30 % of idle cash in Banker's Acceptances.
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CITY OF CAMPBELL
ADMINISTRATIVE POLICIES AND PROCEDURES
Subject:
INVESTMENT POLICY
Date:
November 2, 1998
Glossary of Eligible Investments & Criteria - Continued
Certificate of Deposit (CD's). - is a receipt for funds deposited in a bank or savings and loan
association for a specified period of time at a specified rate of interest. The first $100,000 of a
certificate of deposit is guaranteed by the Federal Deposit Insurance Corporation (FDIC).
CD's with a face value in excess of $100,000 can be collateralized by Treasury Department
Securities, which must be at least 110% of the face value of the CD's, in excess of the first
$100,000, or by first mortgage loans which must be at least 150% of the face value of the CD
balance in excess of the first $100,000.
Repurchase Agreements (REPOS). - is a contractual arrangement between a financial
institution, or dealer, and an investor. This agreement normally can run for one or more days.
The investor puts up his funds for a certain number of days at a stated yield. In return, he
takes a given block of securities as collateral. At maturity, the securities are repurchased and
the funds repaid plus interest.
Commerciill Paper. - notes are unsecured promissory notes of industrial corporations,
utilities and bank holding companies. Notes are in bearer form starting at $100,000. State law
limits a city to investments in United States corporations having assets in excess of five
hundred million dollars with an "A" or higher rating. Per State law, cities may not invest
more than 15 % of idle cash in commercial paper.
Mutual Funds. - are investment companies that make investments on behalf of individuals
and institutions who share common financial goals. The portfolio must adhere to restrictions
set forth in California Government Code Section 53601 et al. regarding allowable investments
and maturity lengths (unless further restricted by the City's Investment Policy). The Code
currently prohibits the utilization of mutual funds that invest in equity securities (i.e.,
Corporate stocks and bonds, etc.). In effect the investor is delegating investment decisions to
the fund's professional money managers. An investor buys shares of the funds, each share
representing an ownership in all the funds underlying securities. These funds are very liquid,
all or part of the share can be cashed in at any time for the current value of the investment
which is recalculated daily. The investors per share calculation (known as "net asset value")
can be determined by daily publication in financial section of most major newspapers.
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