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HomeMy WebLinkAbout2014 Resolution No. 082• • • RESOLUTION NO. ~ SERIES OF 2014 A RESOLUTION APPROVING AMENDING THE CITY OF ENGLEWOOD INVESTMENT POLICY. WHEREAS, the Englewood City Council approved Resolutioµ No. 79, Series of 2006, accepting changes and updates to the City's Investment Policy; and WHEREAS, the Englewood City Council approved Resolution No. 84, Series of 2011, accepting changes and updates to the City of Englewood's Investment Policy; and WHEREAS, the passage of this proposed Resolution amends the existing Investment Policy with changes and updates; and WHEREAS, the Investment Policy is applicable to the investment of all funds not immediately needed for the operating expenditures/expenses of the City, except for the Firefighters Pension Fund, the Volunteer Firefighters Fund, the Police Officers Pension Fund and the Non-Emergency Employees Pension Fund; and WHEREAS, the Investment Policy focuses on four main tenents: • Preservation of Capital • Liquidity to Meet Disbursement Needs • Diversification to Reduce Risk • Obtain a Market Rate of Return; and WHEREAS, the changes involve clarifying language, restricting over-investing in one issuer, adding additional investment opportunities, and requiring broker/dealers provide financial information. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ENGLEWOOD, COLORADO, AS FOLLOWS: Section 1. The City Council of the City of Englewood, Colorado, hereby approves amending the City of Englewood Investment Policy, attached hereto as Exhibit A. ADOPTED AND APPROVED this 3rd of November, 2014 . I, Loucrishia A. Ellis, City Clerk for the City of Englewood, Colorado, hereby certify the above is a true copy of Resolution No.~ Series ~d ..s Loucrishia A. Ellis, City Clerk • • • • City of Englewood, Colorado INVESTMENT POLICY The Director of Finance and Administrative Services of the City of Englewood, Colorado is charged with the responsibility to prudently and properly manage any and all funds of the City. Because these funds may be called upon, it is essential that absolute maturity horizons are identifiable for the purpose of liquidity. Moreover, these funds must be fully collateralized and appropriately authorized. The following Investment Policy addresses the methods, procedures and practices which must be exercised to ensure effective and sound fiscal management. SCOPE This Investment Policy shall apply to the investment of all financial assets and all funds of the City of Englewood (hereafter referred to as the "City") over which it exercises financial control, except the City of Englewood Firefighters Pension Fund, Volunteer Firefighters Pension Fund, Police Officers Pension Fund, the Non-Emergency Employees Retirement Plan Fund and other City employee retirement plans. In order to effectively make use of the City's cash resources, all monies shall be pooled into one investment account and accounted for separately. The investment income derived from this account shall be distributed to the various City funds in accordance with Englewood Municipal Code, 4-1-2-A. OBJECTIVES The City's funds shall be invested in accordance with all applicable City policies, Colorado statutes, and Federal regulations, and in a manner designed to accomplish the following objectives, which are listed in priority order: • Preservation of capital and the protection of investment principal. • Maintenance of sufficient liquidity to meet anticipated disbursements and cash flows. • Diversification to avoid incurring unreasonable risks regarding securities owned. • Attainment of market rate of return equal to or higher than the performance measure established by the Director of Finance and Administrative Services. DELEGATION OF AUTHORITY The ultimate responsibility and authority for investment transactions involving the City resides with the Director of Finance and Administrative Services (hereinafter referred to as the "Director") who has been designated by the City Manager as the Investment Officer in accordance with Englewood Municipal Code. The Director may appoint other members of the City staff to assist him in the cash management and investment function . Persons who are authorized to transact business and wire funds on behalf of the City will be designated by the Director by the wire transfer agreement executed with the City's approved depository for bank services (see Appendix I}. The Director shall be responsible for all investment decisions and activities, and shall establish written administrative procedures for the operation of the City's investment program consistent with this Investment Policy. The Investment Officer acting within these procedures shall not be held personally liable for specific investment transactions. The Director may in his discretion appoint one or more Investment Advisors, registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940, to manage a Page 1 • ~ B + A portion of the City's assets. An appointed Investment Advisor may be granted limited investment discretion within the gu idelines of this Investment Policy with regard to the City's assets placed under its management An Investment Advisor can only be appointed after consultation with and approval by the City Manager. PRUDENCE The standard of prudence to be used for managing the City's assets is the "prudent investor" rule, which states that a prudent investor "shall exercise the judgment and care, under the circumstances then prevailing, which men of prudence, discretion, and intelligence exercise in the management of the property of another, not in regard to speculation but in regard to the permanent disposition of funds, considering the probable income as well as the probable safety of capital." (CRS 15-1-304, Standard for Investments.) The City's overall investment program shall be designed and managed with a degree of professionalism that is worthy of the public trust. The City recognizes that no investment is totally without risk and that the investment activities of the City are a matter of public record. Accordingly, the City recognizes that occasional measured losses may occur in a diversified portfolio and shall be considered within the context of the portfolio's overall return, provided that adequate diversification has been implemented and that the sale of a security is in the best long- term interest of the City. The Director and other authorized persons acting in accordance with established procedures and exercising due diligence shall be relieved of personal responsibility for an individual security's credit risk or market price changes, provided deviations from expectations are reported in a timely fashion to the City Council and appropriate action is taken to control adverse developments. ETHICS AND CONFLICTS OF INTEREST All City employees 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. Employees and investment officials shall disclose to the City Manager any material financial interest in financial institutions that conduct business with the City, and they shall further disclose any large personal financial/investment positions that could be related to the perfon:n ance of the City's portfolio. Employees shall subordinate their personal investment transactions to those of the City particularly with regard to the timing of p urchases and sales. ELIGIBLE INVESTMENTS AND TRANSACTIONS All investments will be made in accordance with the Colorado Revised Statutes (CRS) as follows: CRS 11-10.5-101, et seq. Public Deposit Protection Act; CRS 11-47-101, et seq. Savings and Loan Association Public Deposit Protection Act; CRS 24-75-601, et seq. Funds-Legal Investments; CRS 24-75-603, et seq. Depositories ; and CRS 24-75-701 , et seq. Local governments -authority to pool surplus funds. Any revisions or extensions of these sections of the CRS will be assumed to be part of this Investment Policy immediately upon being enacted. As a home rule City, Englewood may adopt a list of acceptable investment instruments differing from those outlined in CRS 24-75-601 , et seq. Funds4 Legal Investments. Funds of the City of Englewood covered by this Investment Policy may be invested in the following types of securities and transactions: 1. U.S . Treasury Obligations: Treasury Bills, Treasury Notes and Treasury Bonds with maturities not exceeding five years from the date of trade settlement. Page2 • • • 2. Treasury Strips (book-entry U.S. Treasury securities whose coupons have been removed) with maturities not exceeding five years from the date of trade settlement 3. Federal Instrumentalities -Debentures, Discount Notes, Medium-Term Notes, Callable Securities and Step-up Securities issued by the following only: Federal National Mortgage Association (FNMA), Federal Home Loan Bank (FHLB), Federal Home Loan Mortgage Corporation (FHLMC) and Federal Farm Credit Banks (FFCB), with maturities not exceeding five years from the date of trade settlement Subordinated debt may not be purchased. 4. Repurchase Agreements with a termination date of 90 days or less utilizing U.S. Treasury and Federal Instrumentality securities listed above, collateralized at a minimum market value of 102 percent of the dollar value of the transaction with the accrued interest accumulated on the collateral included in the calculation. Repurchase agreements shall be entered into only with dealers who: a) are recognized as Primary Dealers by the Federal Reserve Bank of New York, or with firms that have a primary dealer within their holding company structure; and b) have executed a City approved Master Repurchase Agreement (see Appendix II). The Director shall maintain a file of all executed Master Repurchase Agreements. Collateral (purchased securities) shall be held by the City's custodian bank as safekeeping agent, and the market value of the collateral securities shall be marked-to-the-market daily. For the purposes of this section, the term "collaterar shall mean "purchased securities" under the terms of the City approved Master Repurchase Agreement In no case will the maturity of the collateral exceed 1 O years. 5. Reverse Repurchase Agreements with a maturity of 90 days or less executed only against securities owned by the City and collateralized by the same type of security reversed . 6. Flexible Repurchase Agreements with a final maturity of 1 o years or less entered into by the City with approved counterparties. These flexible repurchase agreements may be closed out in varying amounts and at varying times at the option of the City. These agreements are deemed by both parties to be purchases and sales of securities and are not loans. All such flexible repurchase agreements shall meet the following criteria: • • • • Be determined as legal and valid for both parties; Collateral shall be limited to: a) Securities issued by, guaranteed by, or for which the credit of any of the following is pledged for payment: the United States, Federal Farm Credit Bank, Federal Land Bank, Federal Home Loan Bank, Federal Home Loan Mortgage Corporation, Federal National Mortgage Association, Export Import Bank or the Government National Mortgage Association; or b) Securities issued by, guaranteed by, or for which the credit of the following is pledged for payment An entity or organization which is not listed in paragraph a) above, but which is (1) created by, or the creation of which is authorized by, legislation enacted by the United States Congress and which is subject to control by the federal government which is at least as extensive as that which governs an entity or organization listed in paragraph a) above, and (2) rated in its highest rating category by one or more nationally recognized organizations which regularly rate such obligations. Have a fixed rate during the entire life of the agreement; The dollar amounts and periods of time when the City may draw funds out of the repurchase agreement shall be agreed upon in writing by both parties and shall be part of the written repurchase agreement exercised by the City and the approved counterparty ; Page 3 • The City has the option of varying the dollar amount and the timing of the draw down by an agreed upon percentage of the anticipated draw down and a specified number of days. The City and the counterparty to the agreement will specify the details of the allowable variance when the agreement is structured. In addition, the City may draw down in excess of the variance up to the remaining balance in the agreement for a bona fide, unanticipated cash need; • Collateral shall have a minimum market value (including accrued interest accumulated) of at least 102 percent of the dollar value of the transaction; • Repurchase agreements shall be entered into only with dealers who are authorized by the Director and have executed a City approved Master Repurchase Agreement; • The Director shall maintain a file of all executed Master Repurchase Agreements; • The title to or a perfected security interest in securities, along with any necessary transfer documents, must be transferred and actually delivered to, and shall be held by, the City's third-party custodian bank acting as safekeeping agent. The market value of the collateral securities shall be marked-to-the-market at least weekly based on the closing bid price at the time the custodian for the collateral issues its monthly statement to the City. For the purpose of the section, the term "collaterain shall mean "purchased securities" under the terms of the City approved Master Repurchase Agreement. In no case will the maturity of the collateral exceed 1 o years. 7. Time Certificates of Deposit with a maximum maturity of five years or savings accounts in state or national banks or state or federally chartered savings banks operating in Colorado that are state approved depositories (as evidenced by a certificate issued by the State Banking Board) and are insured by the FDIC. Certificates of deposit that exceed the FDIC insured amount shall be collateralized in accordance with the Colorado Public Deposit Protection Act. The collateral shall have a market value equal to or exceeding 102 percent of the difference between the insured amount and the City's total deposits for all funds within the institution. 8. Money Market Mutual Funds registered under the Investment Company Act of 1940 that 1} are "no-load" (i.e.: no commission or fee shall be charged on purchases or sales of shares); 2) have a constant net asset value per share of $1.00; 3} limit assets of the fund to securities authorized by state statute; 4) have a maximum stated maturity and weighted average maturity in accordance with Rule 2a-7 of the Investment Company Act of 1940; and 5) have a rating of AAAm by Standard and Poor's, Aaa by Moody's or AAA/V1 + by Fitch. 9. Local G overnment Investment Pools as authorized under CRS 24-75-702. 10. Prime Bankers Acceptances, rated at least A-1 by Standard & Poor's, P-1 by Moody's, or F1 by Fitch at the time of purchase by at least two services that rate them, with a maturity of six months or less issued on domestic banks or branches of foreign banks domiciled in the U.S. and operating under U.S. banking laws. Accepting banks must have a senior debt rating of A2. by Moody's and A by Standard & Poor's. 11. Prime Commercial Paper with a maturity of 270 days or less which, at the time of purchase, is rated at least A-1 by Standard & Poor's, P-1 by Moody's, or F-1 by Fitch. a} At the time of purchase, the commercial paper must be rated by at least two of the above stated rating agencies at the stated minimum rating. b) If the commercial paper issuer has senior debt outstanding, the senior debt must be rated at least A2. by Moody's, A by Standard and Poor's, or A by Fitch. 12. Corporate Bonds issued by a corporation or bank with a final maturity not exceeding three years from the date of trade settlement, rated at least AA-by Standard & Poor's, Aa3 by Page4 • • Moody's, or AA-by Fitch at the time of purchase by at least two services. Authorized corporate bonds shall be U.S. dollar denominated and issued by corporations organized and operating within the United States. The City hereby further authorizes investments in dollar denominated securities issued by a corporation or bank that is organized and operating within Canada or Australia. not to exceed 10% per country at the time of purchase. aREI limited to oorparatioRs orgaRizeEI aRd oper:ated witl:1iR the UAiteel States witt:i a Aet wortt:i iR e>Esess of $~5Q FRilliOA. 13. General or Revenue obligations of any state in the United States or any political subdivision. institution, or authority of such a government entity. Municipal bonds must be rated A-by Standard & Poor's, A3 by Moody's, or A-by Fitch at the time of purchase by at least two services if the issuer is located in Colorado. Municipal bonds must be rated M-by Standard & Poor's, Aa3 by Moody's or M-by Fitch at the time of purchase by at least two services if the issuer is located outside the state of Colorado. The maximum maturity for municipal bonds is five years. Securities that have been downgraded below minimum ratings described herein may be sold or held at the City's discretion. The portfolio will be brought back into compliance with Investment Policy guidelines as soon as is practical. OTHER INVESTMENTS It is the intent of the City that the foregoing list of authorized securities be strictly interpreted. Any deviation from this list must be pre-approved by the Director in writing after approval by the City Manager. INVESTMENT DIVERSIFICATION It is the intent of the City to diversify the investment instruments within the portfolio to avoid incurring unreasonable risks inherent in over investing in specific instruments, individual financial institutions or maturities. The asset allocation in the portfolio should, however, be flexible depending upon the outlook for the economy. the secu rities market, and the City's cash flow needs. The City may invest to the following maximum limits within each category: • 50% in Certificates of Deposit • 40% in Commercial Paper, 5% in any one issuer or its affiliates or subsidiaries • 20% in Bankers Acceptances, 5% in any one issuer or its affiliates or subsidiaries _• _30% in Corporate Bonds; 5% in any one issuer or its affiliates or subsidiaries • 30% in Municipal Bonds, 5% in any one issuer The aggregate investment in Corporate Bonds. Commercial Paper. and Bankers Acceptances shall not exceed 50% of the portfolio. Tests for limitations on percentages of holdings apply to the composite of the entire portfolio of the City, not to individual portfolios maintained by the City. Percentage limitations used for measurements are based on the percentage of cost value of the portfolio at the time of purchase. INVESTMENT MATURITY AND LIQUIDITY Investments shall be limited to maturities not exceeding five years from the date of trade settlement. In addition, the weighted average final maturity of the total portfolio shall at no time exceed three years. SELECTION OF BROKER/DEALERS. Page 5 The Director shall maintain a list of broker/dealers approved for investment purposes (see Appendix Ill), and it shall be the policy of the City to purchase securities only from those authorized firms. To be eligible, a firm must meet at least one of the following criteria: 1. be recognized as a Primary Dealer by the Federal Reserve Bank of New York or have a primary dealer within their holding company structure, 2. report voluntarily to the Federal Reserve Bank of New York, 3. qualify under Securities and Exchange Commission (SEC) Rule 15c-3 (Uniform Net Capital Rule). Broker/dealers will be selected by the Director on the basis of their expertise in public cash management and their ability to provide service to the City's account. Eash authoricea breker!aealer shall be reeiuirea to submit aAd SAAUally Ypdate a City approved BrokerJDealer Information Reeiuest form whish inclYdes tl=le firm's most resent finansial statements. In the event that an external investment advisor is not used in the process of recommending a particular transaction in the City's portfolio, any authorized broker/dealer from whom a competitive bid Is obtained for the transaction will attest in writing that he/she has received a copy of this policy and shall submit and annually update a City approved Broker/Dealer Information Request form which includes the firm's most recent financial statements . .,. The City may purchase Commercial Paper from direct issuers even though they are not on the approved list of broker/dealers as long as they meet the criteria outlined in Item 11 of the Eligible Investments and Transactions section of this Investment Policy. COMPETITIVE TRANSACTIONS Each investment transaction shall be competitively transacted with authorized broker/dealers. At least three broker/dealers shall be contacted for each transaction and their bid and offering prices shall be recorded. If the City is offered a security for which there is no other readily available competitive offering, then the Director will document quotations for comparable or alternative securities. SELECTION OF BANKS AS DEPOSITORIES AND PROVIDERS OF GENERAL BANKING SERVICES The City shall maintain a list of banks approved to provide banking services or from whom the City may purchase certificates of deposit. Banks in the judgment of the Director no longer offering adequate safety to the City will be removed from the list To be eligible for authorization, a bank shall qualify as a depository of public funds in Colorado as defined in CRS 24-75-603. SAFEKEEPING AND CUSTODY The safekeeping and custody of securities owned by the City shall be managed in accordance with applicable Federal and Colorado laws and regulations. The Director shall approve one or more banks to provide safekeeping and custodial services for the City. A City approved Safekeeping Agreement shall be executed with each custodian bank prior to utilizing that bank's safekeeping services. To be eligible, a bank shall qualify as a depository of public funds in the State of Colorado as defined in CRS 24-75-603 and be a Federal Reserve member financial institution. Custodian banks will be selected on the basis of their ability to provide service to the City's account and the competitive pricing of their safekeeping related services. The City's designated custodian bank is set forth in Appendix IV of this Investment Policy. Pages • • The purchase and sale of securities and repurchase agreement transactions shall be settled on a delivery versus payment basis. Ownership of all securities shall be perfected in the name of the City, and sufficient evidence to title shall be consistent with modem investment, banking and commercial practices. All investments purchased by the City shall be delivered by either-book entry er physisal £:leli•,•ePJ and will be held in third~party safekeeping by the City's designated custodian bank, +tE; Garresponr:lent eank or the Depository Trust Company (OTC). All Fed wireable book entry securities owned by the City shall be evidenced by a safekeeping receipt or a customer confirmation issued to the City by the custodian bank stating that the securities are held in the Federal Reserve system in a Customer Account for the custodian bank which will name the City as •customer: All OTC eligible securities shall be held in the custodian bank's Depository Trust Company (OTC) participant account and the custodian bank shall issue a safekeeping receipt evidencing that the securities are held for the City as "customer." The City's custodian will be required to furnish the City with a monthly report of securities held as well as an account analysis report of monthly securities activity. PROVISIONS FOR ARBITRAGE The City periodically issues debt obligations which are subject to the provisions of the Tax Reform Act of 1986 (section 148F), Arbitrage Rebate Regulations. Due to the legal complexities of arbitrage law and the necessary immunization of yield levels, the procedures undertaken In the reinvestment of all or a portion of the proceeds of such debt issuance may extend beyond those outlined in this Investment Policy. The Director, upon advice from Bond Counsel and financial advisors, may alter provisions of this Investment Policy for arbitrage related investments as may be necessary to conform with federal arbitrage regulations. In all cases, however, investments will be in compliance with Colorado Revised Statutes. This section is only applicable to City funds subject to arbitrage restrictions. REPORTING An investment report shall be prepared, at least on a monthly basis, listing the investments held by the City, the current market valuation of the investments and performance results. The monthly investment report shall be submitted in a timely manner to the City Manager and the City Council. A record shall be maintained by the Department of Finance and Administrative Services of all bids and offerings for securities transactions in order to ensure that the City receives competitive pricing. The City has established reporting and accounting standards for callable U.S. Instrumentality securities. Callable securities may be retired at the issuer's option prior to the stated maximum maturity. All securities holding reports for the City shall disclose the stated maturity as well as the first call date of each callable security held. In the case of callable securities which are purchased priced to the first call date and, in the opinion of the Director, have an overwhelming probability of being called on the first call date, weighted average maturity, amortization as well as yield shall be calculated using the first call date. The Director may, however, choose to use a further call date maturity date for reporting purposes when conditions mandate. PERFORMANCE REVIEW Page7 The Director and the City Manager shall meet at least quarterly to review the portfolio's adherence to appropriate risk levels and to compare the portfolio's total return to the established investment objectives and goals. The Director shall periodically establish a benchmark yield for the City's investments which shall be equal to the average yield on the U.S. Treasury security which most closely corresponds to the portfolio's actual effective weighted average maturity. When comparing the performance of the City's portfolio, all fees and expenses involved with managing the portfolio should be included in the computation of the portfolio's rate of return. Pages - POLICY REVISIONS This Investment Policy will be reviewed periodically by the Director and may be amended as conditions warrant by the City Manager and the City Council. Prepared by: Prepared by: I Isl Frank Gryglewicz Kevin Engels Director of Finance and Administrative Accounting Manager Services Approved by City Council Amended by City Council September 17, 1990 September 5, 1995 Amended by City Council Amended by City Council December 16, 1991 December 15, 1997 Amended by City Council Amended by City Council April 5, 1993 February 7, 2000 Amended by City Council Amended by City Council June 20, 2005 October 16, 2006 Amended by City Council Amended by City Council November 3, 2008 October 3, 2011 Amended by City Council Amended b~ Cit)'. Council February 18, 2012 Februa~ 19, 2013 State of Colorado, County of Arapahoe: I, Loucrish ia A. Ellis, City Clerk in and for the City of Englewood, in the State aforesaid, do hereby certify that the foregoing is a full, true and correct copy of the Investment Policy as the same appears upon the records of my office which are in my custody. Given under by hand and official seal , this __ . Loucrishia A. Ellis City Clerk Page9 APPENDIX I Authorized Personnel The following persons are authorized to conduct investment transactions and wire transfer funds on behalf of the City of Englewood: Kevin Engels, Accounting Manager Kathy Cassai, Accountant Christine Hart, Accountant Frank Gryglewicz, Director of Finance and Administrative Services Page 10 e APPENDIX II Repurchase Agreements The following firms have executed a City approved Master Repurchase Agreement with the City of Englewood. Banc of America Securities, LLC Morgan Stanley OW Inc. Agreements maintained in separate file. Page 11 APPENDIX Ill Authorized Broker/Dealers and Financial Institutions The following firms are approved for investment purposes by the City of Englewood. Barclays Capital Citigroup Global Markets, Inc. Goleman, Sachs & Co Jefferies & Company, Inc. J.P. Morgan Securities Inc. Merrill Lynch, Pierce, Fenner & Smith Inc Mizuho Securities USA Inc. Morgan Keegan & Company, Inc. Morgan Stanley Smith Barney Raymond James & Associates RBC Capital Markets Corporation UBS Financial Services Inc. Wl:!AElOFlich Secl:!riUes, lno. Page 12 APPENDIX IV Designated Custodial Banks The following bank is authorized as the designated custodial bank for the City of Englewood: Wells Fargo Institutional Retirement and Trust 17 40 Broadway MAC# C7300~105 Denver, CO 8027 4 Page 13 G COUNCIL COMMUNICATION Date Agenda Item Subject November 3, 2014 9 C ii Resolution Approving Proposed Changes to the City of Englewood Investment Policy Initiated By Staff Source Department of Finance and Administrative Services Frank Gryglewicz, Director COUNCIL GOAL AND PREVIOUS COUNCIL ACTION • City Council approved Resolution 79, Series of 2006 accepting changes and updates to the City's Investment Policy on October 16, 2006. • City Council approved Resolution 84, Series of 2011 accepting changes and updates to the City of Englewood's Investment Policy • On October 20, 2014 City Council discussed proposed changes and updates to the existing Investment Policy and requested staff prepare and present a resolution accepting the proposed changes. RECOMMENDED ACTION A. Staff recommends Council adopt a resolution approving the changes and updates to the attached W' Investment Policy. The Investment Policy is applicable to the investment of all funds not immediately needed for the operating expenditures/expenses of the City, except for the Firefighters Pension Fund, the Volunteer Firefighters Fund, the Police Officers Pension Fund, and the Non-Emergency Employees Pension Fund. The Investment Policy focuses on four main tenets: • Preservation of Capital • Liquidity to Meet Disbursement Needs • Diversification to Reduce Risk • Obtain a Market Rate of Return The changes involve clarifying language, restricting over-investing in one issuer, adding additional investment opportunities, and requiring broker/dealers provide financial information. These changes support or strengthen the four main tenets of the Investment Policy. FINANCIAL IMPACT There is no direct financial impact to the City from adopting the proposed changes to the Investment Policy. LIST OF ATTACHMENTS Proposed Resolution