HomeMy WebLinkAbout2008 Resolution No. 076tt)NTRAcr NO, ll>J -J.,Jo 'ii
• RESOLUTI ON NO . 7l,
SERIES OF 2008 --
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A RESOLLT ION A CE PTING CHANGES TO THE CITY OF ENG LEWO OD'S
INVESTMENT POLICY PER ORDINANCE 45, SERIES OF 1995 .
WHE REAS , by Ordinance 45 , Seri es of I 995 , the Direct or of Financia l Services, ex offic io
Ci 1yTreasurer, is emp owered to invest all fund s and monie s not immediately needed for
operating expenditure s/expenses of the City except for the Firefighters Pensio n Fund , the
Volunteer Firefighters Fund , the Police Officers Pen sion Fund and the Non-Eme rgency
Employees Pen sion Fund and pursuant to an inve stment policy to be adopted by Council each
year; and
WHEREAS, the passage of thi s Re so lution will authorize changes to the Englewood
lnveslmcnt Policy;
NOW , THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
ENGLEWOO D, COLORADO , THAT:
Section I . The City of Englewood Investment Policy, attached as Exhibit A, submitted by the
Director of Financial Services is hereby approved .
ADOPTED AND APPROVED this 3rd da y of November, 2008.
I, Loucrishia A. Ellis , Ci ly Clerk fou!/9 City of Englewood, Co lorado, hereby cc nify th e
above is a true co py of Resolution No . --,P_, Se ries ol 2008 .
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City of Englewood, Colorado
INVESTMENT POLICY
The Director of Finance an d Admin 1:;trati ve Services of the City of Engl ewood , Colo rado r
charged w ith th e respons ibility to pruden tly and properly manage any and all funds of th e C1 tI
Beca use these funds may be called upon , It l.s essential that absolute malL'r;ty ho rizon s a•
identifiable for the purpo se of liquidity. Moreover, these funds mu, c be fully collateral ized arl
appropriately authori ze d. The following Investment Poli cy add re sses the meth ods, procedure
and practices wh ich must be exercised to er,oure effective and sou nd fiscal management.
SCOPE
This In vestment Polic y shall apply to the investment of all fi nancial assets and all funds of the C l
of Eng lewood (hereafter referred to as the "City") 0v&c which ii exercises financ ial control , excel
th e City of Englewood Firefighters Pension Fund , Volunteer Firefig ht ers Pension Fund , Po lio
Officers Pension Fund , the No n-Emergency Employees Retirement Plan Fund and other q
employee retirement plans . In order to effe ctivol y make use of the Ci ty's cash resou rce s, ,
mon ies shall be pooled into one investment account and account ed for separately . Tit
Inves tment inco me derive d from th is account sh all be distributed lo the various City funds •
accordance with Eng lewood Mun icipal Code , 4• 1 ·2-A.
OBJECTIVES
The City's principal Investment obj ectives are :
• Preservat ir,n of capital and th e protection of investment principal.
• Maintenance of sufficient llquldlly tc m eet anticipated disbursements and cash fiows .
Diversification to avoid inc urring unre asonable risks regarding securities owned .
• Attainmen t of market rate of return equal to or higher than the performance mea s~•
est abl is hed by the Director of Fin anc e and Administrative Service s.
• Conformance with all City, Federal , State and other legal requirements .
DELEGATION OF AUTHORITY
The ultimate respo nsibility and authority fo r inve stment transactions involving the City resides Yih
th e D irecto r of Finance and Admin istrative Services (hereinafter referred to as the "Directo~') YllO
has been designated by th e City Manager as th e Inv estment Officer in accordan ce ~h
Englewood Municipal Code . The Director may appoint other members of the City stall to asisl
him in the cash management an d inve stme nt function . Persons who are au th or ized to tr ansact
bu siness and wire fu nds on behalf of the City will be designated by the Director by the wre
transfer agreement executed with th e City's approved depos itory for bank services (see Aprerdix
I). The Dlr•.ctor shall be responsible for all investm ent de cis ions and activi ties, and shall es tablSh
written administrative procedures fo r th e opera tion of the City's inves tm ent program consis1nnt
with th is Investment Pol icy. The Investment Officer acting wi th in these procedures sha ll not be
held personally liabl e for specific investment transactions.
The D irector may in his discreti or appoint one or more Investment Advisors, registered wi th the
Securities and Exchange ComJT'·· •;Ion un der th e Investment Advisers Act of 1940, to manage a
portion of the City's assets . An .:.pointed Investment Advisor may be gran ted limited Investment
discret ion with in the guidelines of th is In vest ment Po licy with regard to th e City's assets pla ced
und er its mana ge ment. An Inve stme nt Ad vi sor can onl y be appoin ted after con~~•lt ation with fl nd
app roval by the City ~tana ger.
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PRUDENCE
Th e standard of prud ence 10 be used for managing the City's assets is lhe "p rudent lnvesior" rule ,
wh ich slates that a prudent Investor "shall exercise the judgment and care , under the
circ umstances then pre va ll ing , which me n of prudence , disc retion , and intelli ge nce exercise In the
management of the property of another, not in regard 10 spe culat ion but in regard to the
permanent disposition of funds , consid ering the probabl e income as well as the probable safe ly of
capital." (CR<; 15-1-304, Standard for Investments .)
Th e City's ovec.11 Investment program shall be designed and managed with a degree of
professionalism that is worthy of the publ ic tru st. The City recog nizes that no Investment is totally
ris kless and that the inve stment activities of th e City are a matter of ~Jblic record . Accordi ngly ,
the City recogn izes that occas ional measured losses may be des irable In a diversified portfolio
and shall be considered with in the context of the portfolio's overall return, pro vi ded that adequate
diversification has been implemented and It.at the sale of a se curity is in the best long-term
interest of the City .
ETHICS AND CONFLICTS OF INTEREST
All City employees invoiv,ad In the Investment process shall refrain from personal business activity
that cou ld conflict with proper execution of the Investment program , or whi ch could Impair their
ability to make impartial investment decisions . Employees end lnvestm, nt officials shall disclose
to the City Manager any ma1e1!ai financial interest la financial Institutions that conduct business
with the City, ar,d they shall fu rt~er disclose any large personal financlai/,nvestment positions that
could be re lated to the perfonmance of the City's portfolio. Employee, shall subordinate their
pers on al Investment transactions to th ose of the City particularty with ·egard to the timing of
purchases and sales .
ELIGIBLF. INVESTMENTS AtlD TRANSACTIONS
All Inves tments will be made In accordance with the Coi orad,J Reviseo 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 Protecti on Act; cr:s 24 -75-601 , et seq. Funds-Lega l
In vestments; CRS 24 -75-'l03, et seq. Depositories; en d CRS 24-75-701, et seq . Investment
Funds-Local Government Pool ing. Any revisions or extensions of these sections of the CRS will
be assumed to be part of this Invest 11ent Polic y immediately upon being enacted.
As a home rule Cit;, Englewood may adopt a list of acceptable Investment instruments differing
from those outlined in CRS 24-75-601 , et seq. Funds-Legal Investments . Funds of th e Cit y of
Englewood covered by this Investment Policy may be invested in the following types of securities
and transacti ons :
1. IJ .S. Treasury Obligations : Treasury Bills, Treasury Notes and Treasury Bonds with maturities
r,ot exceeding five years from the date of trade settlement.
2 . Treasury Strips (book-entry U.S. Treasury secunt!es whose coupons have been removed)
with matu rities not exceeding five years from the date of trade settlement.
3 . Federal Instrumentalities -DebPnt.,,es , t;,lscount Notes , Medium-Term Notes, Callable
Securities and Ste r-up Securities Issued by the following only : Federal National Mortgage
Association (FNMA), Fede ral Home Loan Bank (FHLB), Federal Home Loan Mortgage
Corporation (FHLMC) and Federal Fanm Credit Ban ks (FFCB), with maturities not exceeding
five years from the date of trade settlement. Federal Instrumentality Secur,ties shall be rate d
in the highest rating category by at least two Nationally Recog nized Statistical Rating
Organizations (NRSROs) that ,ate them , and shall be ra ted not less by any NRSRO that rates
the debt.
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3 . Repurchas9 Agreemonts wi th a termination date of 90 days or less utilizing U .S . Treas ury and •
Federal Instrumentality securities listed above , collateralized al a minimum market value of
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102 pa rce nt of the doll ar va lue of the transa ction with the acc ru ed in tere st acc umula ted on the
coll alC'ral hclu ded in the calculatmn .
Repurchase agreements shall be ent ered into only with dealers who :
a) are recognized as Primary Dealers by the Federal Reserve Ba nk or New Yo rk , or with
firm, that ha ve a pri mary dealer wit hin the ir holdln Q co mpany stru cture: and
b) have execut ed a City app ro ve d Master Repu rch ase A;i ree ment (see App end ix II ). The
Directo r shal l nialn ta in a file of all executed Mas ~ ·• Repu rchas e Agreem en ts.
Pr imary Deal ers app roved as Repurch ase Agreemenl counterparties, if raled , shall have a
shor l-te rm credil rating or at leasl A-1 or the equ ival ent and a long-te rm cre dit ra ting or at least
A or ths equival ent.
Coll at eral (p urchased securities) sha ll be held by lhe City's custodian bank as safekeeping
agenl, and tt,e market value or th e coll ateral se curit ies s~all be marked-to-the-m ark et da il y.
f·or th e purpos es of th is sect ion , the term ·collat eral" sha ll mean "purch ased s~curit ies" under
the terms of the C ity approve d Master Repu rchase A~reement. In no case will the maturity or
the collateral ex ceed 10 years.
5. Reverse Repurchase Agreements with a maturity of 90 days or less executed only agains t
securities owned by the C ity and collaterallzed by Iha salT'1 type of security reversed .
6. Flexibl e Repurchase Agreements with a final maturity or 10 years or les s entere~ into by the
City with approved counterparties . These flexible ro, urcnase agreements may be close d ou t
in varying amounts and at varyin g times at the option ~f the City. These agreements are
deemed by both parties to be, purchases and sales oi securities and are not loans .
All such flexible repurchase agreements shall meet lh e following criteri a:
Be determined as legal and valid for bolh parties;
Collateral shall be limited to :
a) Securities issued by, guaranteed by, or for whir.h the cred it of an y of the following Is
pledged for payment : the Un ited States , Fed ~:al Fa rm Credit Bank, Federal Land
Bank, Federal Home Loan Ba nk, Federal Home Loan Mortgage Corporation, Federal
National Mortgage Associ ation , Export Import Bank or th e Government National
Mortgage Association ; or
b) Securities issued by, guaranteed by, or for which the credit of the following is pledged
for paym ent: An entity or organ lzalion wh ich is not listed in paragraph a) above, but
which is (1) created by, or the creation of which is autho·12ed by, legislation enacted
by the United States Congress and wh ich is subject to control by th e federal
government which is at leas t as ex tensive as that wh ich gove rn s an entity or
organization listed in pamgraph a) above , and (2) rated in its h;~hest rating category
:.,y one or more natlonall y recog nized r.rgan izations wh ich regularly rat e su ch
ol•ligatlon s .
Ha ve a fixed rate during the entire life of th e agreement;
Th e dollar amounts and periods of time when th e City may draw fund s out of th e
repurchase agreement shall be agreed up on in wr iting by both parties and shall be part or
the writte11 repurchase agreement exe rc ised by th e City and the approved counterparty;
The City has th e option of varying th e dollar amount and the ti ming of the draw down by
an agreed upon percen tage or the anticipated draw down and a specifi ed number of days .
Th e City and the cou nterparty to the ag reement will specify the details of th e all owable
variance when the c::greem ent is structured . In additi on , th e City may draw do wn in
exce ss of the var iance up to the rema in in g balance in the agreement for a bon a fide ,
una nti cip ated cash need ;
Coll atera l shal l ha ve a ni nimum mark et valu e (includ ing accrued inte res t acc um ulated) of
at lea st 102 percent or l ,e do ll ar value of th e transaction ;
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• Repurchase agreements shall be entered in\o only with deale r, Nt , are authorized by the •
Director and have executed a City approved Master Re pu rchase Agreem ent ;
• ·,he Director shall main ta in a fil e of all executed Ma st er Repu rchase Agreeme nts ;
·rhe ti tl e to or a pe rfected se curity In terest In securities, along wit h an y neces sary tran sfer
dt•curo.0 1ts , mu st be transferr ed and actu all y delivered to, and shall be held by, th e Cit y's
th i:d-party cu sto dian bank acting as safekeeping ag en t. The market valu e of the
co1 iateral securities sha ll be .narked-to-the-m arket at least weekly ba sed on th e cl osin g
bid price at the time the cus tod ian for th e collatera l iss ues Its mon thl y statem ent to the
City.
For th e purpose of the secti on, the term "collateral" sh all mean "purchased securities" un der
the tenn s of th e City ,•pproved Maste r Rep urcha se Ag reement. In no case will the maturity of
th e coll ateral ex ceed 10 yea rs .
7 . Time Ce,•lficates of c•apo slt with a maxi mum matu rity of five years or savings accounts in
sta t< . natl or.al banks or state or fed erally ch artered savings banks operating in Colorado
that are st r,te approved depositories (as eviden ced by a certificate issued by the State
Ban king Baard ) and are insured by the FD IC . Cert ificates of depos it tha t exceed the FDIC
ins ured a.mount shall be coiiateraiized in accordance with the Colorado Public Deposit
Pro tection Act. The collateral shall have a market val ue eqt,&i to or exceeding 102 percent of
u ,o differ,nce between th e Insu re d am ount and the City's total deposits fo r all funds within the
lnstih;;ion.
8 . Money Market Mutual Fun ds registered under the Investment Company Act of 1940 that ; 1)
ar e "no-load" (i.e.: no comm iss ion or fee shall be charged on purchases or sales of shares );
2) have a constant net ass et value per share of $1.00; 3) lim it assets of the fund to securities
authorized by state statute ; 4) have a maximum stated maturity and we ighted average
maturity In accordance with Rul e 2a -7 of the Investment Com pany Act of 1940; and 5) ha ve a •
ra ting of AAAm by Standard and Po or's , Aaa by Moody's or AANl/1 + by Fitch.
9 . Colorado Lo cal Gove rnmen t Liquid Asset Trust (COLOTRUST) as authorized under CRS 24-
75 -702.
10. F,lme Bankers Acc eptances, rated at least A-1 by Standard & Poor's, P-1 by Moody's and F1
by Fitch at th e ti me of purchase by at least two se rvices tha t rate the m and shall be rated not
le ss by any service that rates them, with a maturity of six months or less is sued on domest ic
banks or branch es of foreign banks domiciled In th e U.S. and operating und er U.S. banking
laws. Accepting ba nks mus t have a senior debt rating of A2 by Moody's an d A by Standard &
Poor's.
11. Prime Commercial Pap er with a maturity of 270 days or less which, at the time of purchase, is
rated at least A-1 by Standard & Peer 's, P-1 by Moody's and F-1 by Fitch.
a) At the time of purchase, the commercial paper must be rated by at le3sl two of the above
stated rating agencies at the stated minimum rating .
b) If more than two of th e above stated agencies rates an issuer, all of those rating agencies
must rat e the issuer In accordance with above stated minimum credit criteria .
c) If the commercial pa per issu er ha s sen!or debt outstanding, th e senior debt must be rated
by each service that publishes a rating on the issuer as at least A2 by Moody's , A by
Standard and Peer's and A by Fitch .
12. Corporate Bonds Issued by a corporation or ban k with a fi nal maturity not exce eding three
yea rs from the date of trade settlem ent, rat ed at least AA-by Standard & Poor's , Aa3 by
Mo ody's, or AA by Fit ch at th e ti me of purchase by each se rvice that rates th e debt.
Authorized corporate bonds sh all be U.S . doll ar denom inated , an d limited to corporations •
organized and operated with in th e Un ited States with a net worth In excess of $250 million .
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OT HER INVESTMENTS
It Is the Intent of the City that th e foregoing list al ,;c•thorized securities be sl r ictlv interpreted . Any
deviation from th is list must be pre-approved by th e '.Jirector In wr iting after :,pproval by the City
Manager.
INVESTMENT DIVERSIFICATION
I! is the inte,t of the City to diversify t~e investment l,,strum ents within the portfol io to avoid
incurring unreasonable risks Inherent in ,,•,er invest ing in spec!fic instruments, indivldual financial
insti tu tions or maturitie s. The asset allocation in the portfolio should , howevar, be flexible
depending upon the outlook for th e economy, the securities market, and !he City's cash flow
needs .
The City may invest to the following m axim um limns within each ca te gory:
50% in Certificates of Deposit
• 40% in Commercial Paper
• 20% in Ban kers Acceptances
• 30% in Corporate Bonds ; 5% in any one Issuer or Its affiliates or subs idia ries
Tests for lim itations on percentages of holdings apply to the composite of the entire portfolio of the
City, not to In dividual portfolios maintained by th e City. Percentage limitations used for
measurements a;e bas ed on the percentage of cost value of the portfolio.
INVESTMENT MATURITY AND LIQUIDITY
Investments shall be limited to maturities not exceeding five years. In addition, the we ighted
average final maturity of the total portfolio shall at no lime exceed 24 months .
SELECTION OF BROKER/DEALERS.
The Director shall mainta in a li st of broker/dealers app rove d for investment purposes (see
Appendix Ill), and It shall be the policy of the C ity to purchase securities only from those
authorized firms .
To be eligible , a firm must meet at least one of the following criteria:
1. be recog nized as a Primary Dealer by the Fe deral Reserve Ban k of New York or have a
primary dealer within their hold in g 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 th eir expertise in pu bli c cash
management an d their ability to provide service to the City's account. Each authorized
broker/dealer shall be required to su bm it and annually update a City approved Broker/Dealer
Information Request form which includes the firm 's most recent financial stat ements. In th e event
that an external investment advisor is no t used in the proce ss of recomm en ding a particular
tra nsaction in the City's µorlfolio , any authorized broker/dealer from wnom a competitive bid is
obtained for the transaction will attest in writing that he/she has received a copy of this policy.
The City may pu rchase Commercial Paper from direct issuers even though th ey are not on the
approved list of broker/dealers as long as they meet the criteria outlined In Item 12 of the Eligible
Investments and Transactions sectio n or th is In vestment Poli cy .
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COMPETITIVE TRANSACTIONS
Each Investment transaction shall be competi tively tr ansacled with aut horized broker/dealers . At
least three broker/dealers shall be contacted fo r each tra nsaction and their bid and offering prices
shall be recorded .
If the City is offered a security for wi,lch there Is no other readily available competitive offering,
then the Director will document '1LIOtations fo r compa rab le or alternat ive securities .
SELECTION OF BANKS AS DEPOSITORIES ANIJ PROVIDERS OF GENERAL BANKING
SERVICES
The C:ty shall maintain a !i •t of banks approved to provide bankin1 ,ervices or from whom I 1e City
may purchase certificates c: deposit. Banks in the Ju dgment OJ the Director no longer offering
adeq1•ate safety to the City will be removed from the 11st. 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 anct Colorado laws and regulations .
The Director shall approve one or more banks lo provide safekeeping and custodial servicef for
the City. A City approved Safekeeping Agreement shall be executed with each custod ian bank
prior to utilizi ng that bank's safekeeping services . To be eligible, a bank shall qua lify as a
depository of public funds In the State of Colorado as defined In CRS 24-7 5-603 and be a Federal
Reserve member financial Institution.
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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 th is Investment Policy.
The p11rchas e and sa le of securities and repurchase agreement transactions shall be setlled 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 modern investment, banking and
commercial practi c'3s.
All investments, except certificates of deposit and local government investment pools purchased
by the City shall be delivered by either book entry or physical delivery and will be held in third-party
safekeeping by the City's designated custod ian bank , Its correspondent bank 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 Federa l Reserve system in a Customer Account for the custodian bank
wh ic h will name th e City as "customer ."
All OTC eligible securities shall be held in the rustod ian 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."
All non-book entry (physical delivery) securities shall be held by the custodian bank's
correspondent bank and the custodian bank shall Issue a safekeeping receipt to the City
evidencing that the se curities are held by the correspondent ban k for the City as "customer ."
Th e City's custodian will be required to furn ish the City with a monthly report of securities held as •
well as an account analysis report of monthly securities acti vity.
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PROVIS IONS FOR ARBITRAG E
The City penod1cally issues debt obl igations which are subject lo the provisions of the Tax Reform
Act of 1986 (section 14BF), Arbitrage Rebate Regula11on s. Due to the legal complexities of
arbitrage law and th e ne cessary immunization of yield levels, the procedures undertaken in the
reinvestment of all or a portion of the proceeds of such deb t issuance may extend beyond those
outlined In th is Investmen t Policy. The Director , upon adv ice from Bond Counsel and financ ial
advisors, may alter provisions of this Investment Policy for arbitrage related Investm en ts as may
be necessary to conform with federal arbitrage regulations . In all cases , howe ver, inves tments
will be in compliance with Colorado Revised Statutes . This section is on ly applicable lo City funds
subject to arbitrage restrictions.
REPORTING
An investment report shall be prepared , al least on a monthly ~•sis, 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 lo 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 sec urities tra nsactions in order to ensure that the City rece ives
competitive pricing.
The City has es tablished reporting an d accounting standards for callable U .S . lnstrLlmentalily
securities. Call able securities may be reti red al the issuer's option prior to the stated maxim um
maturity. All securities hol dl11g reports for the City shall disclose the stated maturity as we ll as the
first call date of each callable security hel d. In the case of callable securities which are purchased
priced lo the firs! call date and , ia the opi nion of the Director, have an overwhel ming probability of
being called on the first call date , weighted average maturity, amortization as well as yiel d shall be
calcu la ted using the first call dale . The Director may, however, choose lo use a further ca ll dale
matur ity do.P. for reporting purpos es when conditions mandate .
PERFORMANCE REVIEW
The D irector and the City Manager shall meet al leas! quarterly lo review the portfolio's adherence
to appropriate risk levels and 10 compare the portfolio 's total return to the established investment
objectives and goals .
The Director shall period ically establish a benchmark yield for the City's investments 1• ~ic:1". shall
be eq ual to the average yie ld on the U.S. Treasury security which most closely corresponds lo th e
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 .
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POLICY REVISIONS •
Th is lnveslment Pol ley wil l be rev iew ed period ically by the Director and may be amended as
conditions warrant by the City Manager and the City Council.
Prepared by:
Isl
Frank Gryglewicz
Director of Finance and Adm inistrati ve
Services
Approved by City Council
September 17, 1990
Amended by City Coun cil
December 16, 1991
Amended by City Council
April 5, 1993
Amended by City Council
Jun e 20, 2005
Prepared by:
Isl ____________ _
Steve Da zzle
Accounting Manager
Amended by C;ily Council
September 5, 1995
Amended by City Council
December 15, 1997
Amended by City Council
February 7, 2000
Amended by City :aun cll
October 16, 2006
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• Stale of Colorado , County of Arapahoe :
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I, Lou crishia A. Ellis , Ci ty Clerk in and for l~e City of Englewood, in th e Stale aforesaid, do hereby
cert ify that the foregoing is a fu ll , true a, d correct copy of th e Inves tme nt Policy as th e same
ap pears upon th e re co rds of my office which are in my custody.
Given under by hand and official seal , this __ .
Isl
Loucrish ia A. Ellis
City Clerk
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APPENDIX I
Author ize d Personne l
Th e rollowlng pe rsons are authorize d trJ conduct investment transactions and wire transfer fun ds
on behalf or the City or Engle wood :
Steve Dazzio, Accounting Manager
Kathy Cassal, Accountan t
Kevin Engels , Accountant
Christine Ha rt, Accour,tant
Frank Gryglewicz, Director of Finance and Administrative Services
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APPENDIX II
Repurchase Agreements
The following firms have executed a Cl!y approved Maste r Repurchase Agreement with the City of
Engl ewood .
Ban c of America Securities , !..LC
Morgan Sta nley DW Inc .
Agreements maintained in separate file .
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APPENDIX Ill
Authorized Broker/Dealers and Financ ial Institutions
The following firms are approved for Inves tment purpos<·s by the City of Englewood .
Banc of America Se curitie s, LLC
Citigroup Globa l Markets, Inc .
Fundamental Ca pital Ma rke ts
J.P. Morgan Securities In c.
Merrill Lynch
Mizuho Securities USA Inc .
Morgan Stanley
UB S Fi nancial Services Inc .
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APPENDIX IV
Designated Custod ial Banks
The following bank is authorized as the designated custodia l bank for the City of Englewood :
We ll s Fargo Bank, NA
Northstar East Bu ilding
608 Second Ave ., 8th Floor
Minneapolis , MN 55479
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COUNCIL COMMUNICATION
Dale : Agenda Item : Subject:
November 3, 2008 9 C i Re5'.'utio n A pprovi ng Pro posed Chan ges 10 th e
City of Englewood In ves tm e nt Poli cy
Initi ated By:
D epa rtment of Finan ce and Administrati ve Serv ices
I Staff Source :
Frank Gryglewicz, D irecto r
COUNCIL GOAL AND PREVIOUS COUNCIL ACTION
Th e Council discussed proposed c hanges to th e Investment Po li cy at th e Study Sess io n held
October 20 , 2008.
RECOMMENDED ACTION
Staff recommends Council ap prove the changes and updates to th e atta ched In vestm ent Policy.
The Inves tment Policy is applicable to th e in vestment of all funds not immediately needed for the
operating ex p endi tures/expens es of the City, except for the Firefigh ,'e rs Pension Fund, the
Volunteer Fi refighters Fund, th e Poli ce Officers Pension Fund , and the Non-Emergency Empl oyees
Pens :o n Fu nd.
FINANCIAL IMPACT
The re is no direct finan cial impa ct to th e City from ad o pting th e propose d c hanges to th e
In vestment Po li cy .
UST OF ATTACHMENTS
In ves tm ent Policy w ith Propose d Changes
Proposed Resoluti o n
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City of En glewood, Co lorado
INVESTMENT POLI CY
T hP Director of Finance and Adm m1 stra1tYe Se rv1 ce s of th e City of Englewood, Colorado 1s
charq sd with the responsibility to prudently and properly manage any and au funds of the C ity
Bec.ause thc!s e funds may be called upon. it 1s esse n11al that absolute maturity honzons are
1dentif1able fo r the purpose of hquid11y . Moreove r, these funds must be fully coltaleralized and
appropri ately authonzed The following In vestmen t Po licy addresses the methods, procedu res
an d practices which must be e11 e1 cised to ensure effed fve and sound fiscal manaq1'"T'O 'll
SCOPE
This Investment Policy shall apply to the inv estm ent of au fina ncial asset:; and all fu~ ·, of the City
of Englewood (hereafter re ferred to as the •city") over which it exercises l 1nanc1al c,,· ":1 1, except
the City of Englewood Firefighters Pension Fund , Volunteer Firefighters Pension I , d, Po l!ee
Officers Pension Fund. the Non -Em ergancy Employees Retirement Plan Fund an, other C ity
employee retirement plans. In order to effectively make use of the City's cash n •• ,c,1 1,~s. all
monies shall be pooled Int o one investmenl account and accounled for separeto\, The
investment mcome derived from this account sha ll be distributed to the various Cny f l"'tls in
accordance with Englewood Mun icipa l Code . 4-1-2-A.
OBJECTIVES
The City's principal investment objeclives are
Preservation of capital and the protection of investment principa l.
Maintena nce of sufficie nt liquidity to meet anticipated disbursements and ca sh flows ,
Diversifica tion to avoid incurring unreasonable risks regarding securities owned
Attainment of market rate of relum equal to or higher than lhe performance measure
established by the Director of Finance and A:lm1n 1strative Services .
Conformance with all City. Federa l. State and other legal requirements.
DELEGATION OF AUTHO [<ln.
The ultimate responsibility and ~ulhor ity for investment transactions Involving th e City resides with
the Direcior of Finance P.,1d Ar,minlstrat1ve Services (hereinafter referred to as the "Director") who
has been desig.,at~IJ by U 1e City Manager as the Investment Officer In accordance with
Englewood M1!:-,icipal Code. The Direcior may appoint other members of the City slarf to assist
him in !he rc1 sh management and investment function . Person s who are authorized t~ transact
business r..nd wire funds on behalf of the City will be des ignated by th e Director by th e wire
transfer ,,greement executed with !he City's approved depository for bank services (see Appendix
I). The Director shall be responsible for au investment decisions and activities. and shall establish
wntten administrative procedures for the operatio n of the City's Investment program conslstent
with tn ls Investment Policy. The Investment Office r acting within these procedures shall not be
hl!:d perso nally liable for specific Investment transaciions .
The Director may in his discretion appoint one or more Investment Adv isors, registered with the
Securities and Exchange Commission under the lnve,;tment Advisers Act of 1940, to manage a
portion of the City's assets . An appo inled Investment Advisor mi'y be granted lim it ed hivestm ent
discretion within the guidelines of th is Investment Policy with regard 10 the City's assets placed
under Its ma nagement. An Investment Advis or can only be appointed after consullalion with and
approval by lhe City Manager,
Page l
PRUD ENCE
~d of prudence 10 be used for managing the City'& assets 1s the "prudent u,ves1or· rule,
which states tha t a prudent mves tor "sh ell e,cerc ise the jud grnent an d care , und er the
cl rcums l ances !hen preva iling. which men of prudence , discretion , and intelhgence e,cer c1se 1n the
management of the property of another, not in regard to speculation bJI In regard 10 the
pem,one nt disposition of funds , considering the probable income as well es the probable safety of
capi tal." (C R$ 15-1-304, Standard for Investments.)
Th e City's ove rall inves tment program shall be des1gned and managed with a degree of
professlonalism that 1s worthy of the publ ic trust The City recognizes that no 1nves1men1 Is totally
riskle ss and tha t th e Inves tment act lvllles of th e City are a matte r of public rocord. Accord ingly,
the City recognizes that occasional measured losses may be des irable In a diversified pOftfol io
and shall be considered within the context of the portfolio's overall return , prov ided that adeq uale
d1verslfic ation has been implcmenled and that the sale of a security Is In the best long-te,m
in1erest of the City.
ETHI CS AND CONFLICTS OF INTEREST
All CiW em ployees involved in the Investment process Shall refrain from oerso nal business activily
)hat COUid con fli ct with proper ellOCU!lon Of the jnvestment program gt which COUid Impair th ei r
ability to make impartial lnveslment deci sions-Employees and investment omciais shall disclose
10 the Citv Manager any material fi nancial interest in financ1a1 ins)ttutions that conduct bus in ess
w1)h the City and )hey sha ll fudher disclose any (arge Pers on al finaociaVjnvestment oosmons )hp)
could be re lated 10 the performance or the City's oorttoHo EmoloYees 5ha11 subordinate Jheir
Qe!SOQ@I investment transaction s to !hose QI the C~Y p@Oicui arly wiJh regard 10 the hmlng of
purchases and sales
ELIGIBLE INVESTMENTS ANO TRANSAC TI ONS
All h1vestmen ts wltl be made in accordance with the Colorado Re vi sed Statutes (CRS) a!-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 . el seq , Funds-Legat
lnvestmen1s : CR S 24-75-603. et seq , Depositories: and CRS 24-75-701 . et seq. Investm ent
Funds-Local Government Pooling. Any revision s or extens io ns of these sections of the CRS will
be assumed to be part of this Invest ment Polley immediately upon be ing enacted .
As a home rule Ci ty, Englewood may adopt a list of acceplable Investment instruments differing
fro m those ouUlned in CRS 24-75-601 , et seq. Fund s-Legal lnvtistments. Funds of the City of
Englewood covered by this Investment Policy may be lnves led in the following lypes of securities
and transaction s:
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1. U.S. Treasury Obligations: Tr:)asury Bills, Treasury Note s and Treasury Bonds with maturities
not e,cceeding ~_ye ~r~_,ro~.me ~!~~.C?U~~~~-~~m~n,en!. ..... ·I~•-•-'"-"'-'-'-----~
2. Treasury S1nps (book-entry U.S. Treasury securities whose coupons ha ve been removed)
wilh maturities not exceeding~y-~~-~s .~~9!!'!.~h~.g?.~~.9.f.~a.~~.sJ:!:IU~.rn !:!.i:i~ [ Deleted: s
::================:: 3, Federal lnstrumentalilies -Debentures , Discount Noles , Medlum:.T.~rm ... ~(?1 es1 ~?.ll~b!~... { Del eted:
Sccurilies and Step-up Secu rities iss ued by the following only: Federal National Mortgage '-"'="'-------'
Associat ion (FNMA), Federal Home Loan Bank (FH LB), Federal Home Loan Mortgage
Corporatio n (FHLMC) and Federal Fa rm Credit Banks (FFC B). wit h maturities not eJ1ceedfng
~years.l rOrf!.!h.~.~c,I~~ 9f tr~.~.s~lll!!l!:l~f'.t: Federal l nstrume nlality Securi11e s shall be ra 1ed ... { Deleted : s
in the highest raJma eateaorv bv at least two Nat1ona11v Recogn ized Stahslical Rating ~--------'
Organizations (NRSRO sl Jha t rate th em and shall be rated not iess bY any NRSRO tha t rates
llliili
3. Repu rchase Agreements with a termination dale of 90 days or less utllizi ng U.S. Tre as ury and
Federal lnstrumenlalily securities listed above . colla teralized at a m inimum market value of
P1ge2
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102 pe rcent of 1he dollar value of the transaction with the accruod interest accumulated on the
collateral in cluded in !he calculat1on
Rep l•rchase agreem ents shall be entered mto only wrt h dealers who
a ) a,e recogmzeo as Primary Dea lers by the Federal Reserve Bank of I ,ew York, or with
firms Iha! have a pnmary dealer w1thm their hold rng co mpany struc1ure, and
b) have executed a City app ro \/ed Master Repurchase Agreement (see Appendix II ) The
Orr ecto , shall mainta in a file of all e1<ecuted Master Repurchase Agreements
Primary Dealers approved as Repurchase Agreen•eri counterpaMJes , lf rated , shall have a
short-term credit raung of at least A-1 or th e equ1valen1 and a long -term credit ralmg of at least
A or the equivalent
Collateral (p Jtchased ,;ecuritie s) shall be held by !h e City's cus todian bank as sa fekeepi ng
agent, and !he market value of the coll ater al secu rities shall be marked-to-the-market daily .
For the purposes of th is section. the Ierm ·coll ateral" shall mea n "purchased secun\1es · under
the terms of the City approved Master Repurchase Agr eement. In no case will the ma turity of
the collateral exc-?ed JQ_yf!~.f.l~:.
5 Reverse Repurchase Agreements with a matunty of 90 days or less executed only against
securities owned by !he C lly and collaterallzed by the same type of security reversed .
6 Flexible Repurchase Agreements w1lh a fina l malurily of &Y.f!~rs. or les s ~r:it~r~ into by_ lh~.
City Wtl h approved coun terpartles. These flexible repurchase agreements may be closed out
In varymg amounls and at varying times at the opt ion of !tie City. These agreements are
deemed by both parties to be purchases and sales of securities and are not loans .
Alt such flex ible repurchase agreeme nts sha ll meet the following criteria:
Be determined as legal and valid for bolh parties;
Collateral shall be limited to;
a) Secunties issued by, guaranteed by , or for wh ich the crodil c.,f any or the following is
pledged for payment: the United States, Federal Farm Credi! Bank , Fedoral Land
Bank, Federal Home Loan Bank , Federa l Home Loan Mortgage Corporauon, Federal
National Morgage Associat10n , Export Import Bank or lhe Government National
Mortgage Association; or
b} Securities Issued by , guaranteed by , or fo r which the credit of the following Is pledged
for payment An entity or organization wh ich is not listed in paragraph a) above , but
which is (1) c:eated by , or the creation of wh ich is authorized by , legislation enacted
by the United S1ales Congress and which Is subject 10 control by the federal
government which :~ al least as extensive as that which governs an entity or
organtzalion listed in paragraph a) above . and (2) rated tn its hlghesl rating category
by one or more nationally recognized organizations which regularly rale suc.h
obligations
Have a fuced rate dunng the entire life of the agreement,
The dollar amou:its and periods of time when the City may draw funds oul of the
repurchase agreement shall be agreed upon in writ ing by bolh parties and shall be part of
the writte n repurchase agreemenl exercised by tho City and the approved counterpany;
The City has !he ophon of varying the dollar amount and the timing of the draw down by
an agreed upon percentage of !he~ draw down and a specified number of days.
The City and !he counterparty to the agreement will specify the details of the allowable
variance when the agreement is ctruc1ured In oddition , the City may draw down m
excess of the variance up 10 tre remaining balance in the agreemenl for a bona fide,
unant1crpaled cash need :
Collateral shall have a mmimum ma rkel value (1ncludmg accruei;f ;ntsrest accumulated) of
al least 102 percent of th e dollar value of the transac1Ion ;
Pa1>113
{ Deleted:t11n
{ Deleted: 111n
Repurchase agreements shall be entered inlo only with dea lers who are authorized by the •
Director and have exe cuted a City approved Mas ter Repureh ase Agreement.
The Oirect01 sh all maintain a file of all ex ecu ted Mas ter Rep urch ase Ag reemen ts,
The tltle to or a pe rfected se curity in teres t in sec urities, alo ng wit h any necessa ry transfe r
doc um en 1s, must be lra ns ferr ed and aclUaUy delivere d to . an d shall be held by , the City's
third-party cuslod lan brtn k acting as safek eeping agent. The ma :ket valu e of the
collateral se::uril •es shall be marked-10-the-marilet al lea st weekly ba sad on the closing
bid pri ce at the ume the cu stod ian fo r the collate.-al issues lts monthly st al eme nt to th e
Ciy.
For the purpose of the se ction . the term "collat erai-sha ll mean ·purch ased se cur ities -under
the terms of !he City approved Master Repurch ase Agreemon t. In no case will the maturity of
the co llatera l exceed.1.Q.years ... I Deleted i 1an
:· ================:'. I 7 Ti me Certificates of Deposit with a maximum rnatur ily of~ Y.e?i rs .. or ~avi11gs c!~CO Ufil!i 1n. . {c;D:.:•:::'•:::•ed:;:;'c;':_ ____ _,
state or nallona l banks or stale or federally ch arte red savmgs ban ks ope ratin g In Colora do
that are state approved depos itories (as evidenced by a cert ifi cate Iss ued by lhe Sta te
Banking Boa rd) and are Insured by the FDI C. Certificates of depos it th nt exceed the FDIC
insured amou nt shall be col1a te ralized in acco rdance with the Color ado Public Deposit
Protect ion Act. T!i e collatera l shall have a market value equal lo or exceed rng 102 percen t of
the differen ce betwee n the Insured amount and the City's total depos its for all funds with in the
ins titution .
8. Money Market Mutual Funds reg istered unde r the Investment Compa ny Act or 1940 tha t 1)
are "no-load" (i.e.: no commission or frte sh all be charged on ptJ rch ases or sales of shares);
2) have a constant net as set value per sh are of $1 .00; 3) llm lt ass et& of the fund to securities
auth orized by state slat ute ; 4) have a ma xi mum slat ed mat urity and we ighted average
maturily in acco rdan ce wilh Rule 2a-7 of the Investment Company Act of 1940 : and 5) have a
rating of AA.Am by Standard and Poor's. Aaa by Moody's or AAA/\1 1+ by Fitch .
9. Colo rado Local Governme n\ Liquid Asset Trust {COLOTRUST) as autho rized under CRS 24 •
75-702 .
10. Pnm e Bank ers Acceptances , rated at least A-1 by s•andard & Poo r's, P-1 by Moody's an d F1
by Filch at the time of purchase by at least two servio:-s that rate them and sha ll be rated not
le ss by any service thal rates them , with a maturity of six months or less issued on domestic
banks or branches of fore ign bank s domiciled in the U.S. and operating unde r U.S. bankin g
laws . Accepting bank s must have a senior debt ratlrig of A2 by Moody's and A by Standard &
Poo r's..
11. Pnme Commercial Paper with a matur ity of 270 da ys or less which, at the time of purcha se , is
ra ted at least A-1 by Standard & Poor's , P-1 by Mcody's and F-1 by Fitch.
a) At th e time of purchase . the co mmercial paper 1:1ust be rated by at least two 01 the above
stated rating agen cies at lhe stated min imum rat :ng .
b l If more lhan two of the above staled agencies rates an issuer, all of th ose rating sgencies
mu st rate the issuer In accordance with above stated minimum cred it cnte ria.
Cl If the commerci al paper issuer ha s senior debt outstand ing , the senio r debt must be rated
by each service that pub lishes .Jting on the Issuer as at least A2. by Mocdy's, A by
Standa rd and Poor's and A by Fitch.
12. Corporate Bonds l&!i ued by a corporation or bank with a fina l maturity not exceeding three
~ears from the dat e of tr ade setllement , rated at lea st AA-by Standard & Poor's, Aa3 by
Moody's, o r AA by Fitch at the time of purchase by ea ch serv ice that rate s the debt
Aut horized corpor ate bond s shall be U.S dollar den ominated , and limited to corporation s
or ganized and oper aled within the Unit ed States with a nel worth in exce ss of $250 million .
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OTHER INVESTMENTS
It 1s the rn1en1 of the City that the foregoing 11s1 of authonzed securitres be s1nctly int erpreted Any
dev1at 1on from l h1s 11s1 must be pre-approved by the Director In wnhng after approv al by the City
Manage r
INVESTM!:NT DIVERSIFICATION
It is l he intent of the City lo divers ify the 1nvos1ment instruments within lhE: portfolio to avc-:d
mcumng unreasonable risks mherent in over investing m specific 1ns1ruments. individual fir.dn c1al
institutions or inaturit1es The asset allocat1on m the portfolio should, however, be fle xible
depending upon the outloolt for lhe economy, the secu rities market, and th e City 's ca ::.ti flow
needs.
The Cily may mve st to lhe following ,,iax1mum limt ls within each category
50% in Cenificates of Depos it
40% m Commercia l Pape r
• 200/4 in Bankers Accep tances
• 30% in Corpo rate Bonds : 5% in any one is sue r or its affiliates or subsid iaries
Tests for li mitations on percentages of holdings apply to the compos ite of the entire portfolio or the
City, not to individual portfolios ma intained by the City . Percentage limitations used for
measurements are based on the pe rcen tage of cost va lue of the portfolio .
~-(MENT MATURITY AND LIQUIDITY
lnves 1menls shall be limited to maturities rtol exceeding five years In addition , the we ighted
average final maturity of the total portfol io shall at no time e1eceed 24 months.
SELECTION OF BROKER/DEALERS .
The Director shall ma int ain 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 Prima ry Dealer by the Federal Re seNe 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. qu alify under Securities and Ex change Commission (SEC) Rule 15c-3 (Uniform Net C.ipita1
Rule ).
Broker/dealers will be selected by the Director on the bas is of their expertise fn public cash
management and their ability to provide seNice to the City's account. Each authorized
broker/dealer shall be required to submit and annually update a City approved Brok er/Dealer
Info rmation Request form which includes the firm 's mosl recent finan cial statements , In the event
that an ex lernol investment advisor 1s not used 1n the prr cess of recommending ~
transa ction In the City's portlol10 any authorized broker/deale r from whom a competilive bid is
obtained for the transaci ion will attest m writing thal he /she has received a copy of this policy ..
The City may purchase Commerclal P.iper from direct iss uers eve n though they are not on the
approved list of broker/dealers as long as they meet the criteria outlined m Item 12 of the Eligible
Investments and Transactions section of th is Investment Policy .
P1ge S
Deleted: Brok er/DealeB 1t1aU attes1
inwrilingthnlth11y h11verecerveda
copyal thislnv111tm11ntPollcy.
COMPETITIVE TRANSACTIONS
Each Investment transaction shall be competitively transacted with authorized broker/dealers . At
least three broker/daaleri shall be contacte d for each transaction and the ir 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 comparab'e or alte:matlve aecuriti&~
SELECTION OF BANKS AS DEPOSITORIES 4ND PROYJDERS OF 3ENERAL BANKING
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The City shall ma intain a Us! of bank 1 approved to provide banking services or from whom the City
may purdl■se certffic:atea of deposit. Bank s in the judgment of the Director no longer offering
adequate aafaty to the City will be removed from the list. To be ellgfble for authorization, a bank
shall qualify as a depository of public funds In COiorado u defined In CRS 2-4-75-603.
SAFEKEEPJNG AND CUSTODY
The Nfekeeplng and custody of securities owned by the City shall be managed In accordance
with applicable Federal and Colorldo ilwl and regulations.
The Dl ~ector 1h1II approve one or more b1nk1 to provide 11fekeeplng and cu1tod l1 I aervlce1 for
the City. A City approved SofokllOl'ir.g ~t ahlll bo exocu1od with oach cuatodiln bank
prior IO utlllzlng that baN<'I llfekoeplng -·· To bo eligible , I bank ahol qualify II •
depository of public funda In tho Sta1e of Colorldo II defined In CRS 24-75-!103 and be I Federal
RIIHMI member flnanclol lnltltutlon .
Custodian bank.a wilt be Mlected on the baMI of thetr ablffty to provide aeMCe to the City'•
OCCOYnt and tho canpotltive pricing of their 1lfekoeping related Hrvices. The City's de1ignatocl
cuatodlan bank la Ht forth In Append~ IV of this lnvo,tment Polley.
The purchaM and .... of aecurtt.s and repurchaH agreement transactions sh ■n be aettled on a
deMtry wr1u1 payment baall. Ownership of al aeeurities ah■n be perfect~ In the name of the
City , and aulflcient ovklence IO title 1holl be conallhtnt with modam lnvoatmenl banking and
commerc:iaJ practlcn,
Al\ lnvestmenta , except certlicatn of depostt and local government lnvatment pools purchaset4
by tho City ahaN bo detivo<od by olthor book entry or phys ical delivo!y and win be held in thlrt:-party
11fekeeping by the City', de1ignalad cu1tod lo n bank, Ila co"eapondent baN< or the Depoaltory
Trust Company (DTC).
All Fed wlraoblo book entry HCUritln owned by the City 1hall bo evidenced by I alftkeeplng
receipt or a cuatomer confirmatloo llaued to the City by the cuatodlan bank 1t1ting that the
aecuritieI are hekl in the Federal Reserve system In a Customer Accoun l for the custod ia n bank
which wil name the City u •customer."
All IJTC eligible ucuritie1 shall be hold In the custodian bank'1 Depoaltory Trust Company (DTC)
panlciplnt account and the cuatodian bank 1h11 luue a Nfekeeplng receipt evidencing that the
securitlea are held for the City 11 •cuatomer:
All non-book entry (phytlcal deltvery) securities shaft be held by the custod ian bank 's
correspondent bank and the custodian bank shall inue a aafekeeplng receipt to the City
evidencing that the securities are held by the corrnpoildent bank for the City as ·customer."
The City's custodian will be req uired to fum l1 h the City with a monthly report of ucuritleI hek:t as
well as an account anatysls report of monthly securities activity ,
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PROVIS ION S FOR A RBITRAGE
The City periodically issues deb! obhg a1 1ons which are sub1e ct 10 the prov rs1ons of lhe Tax Reform
Act of 1986 (se ::,on 148F ), Arbitrage Reb o1 e Regulations Due to the lega l comptex1 t1es of
arbnrage law ano !he necessary Immurnza110n of yield levels, lhe procedures unde naken In the
remvestmenl of all or a portion of the proceeds of such debt issuance may ex1end beyond th ose
oull1ned in this Investment Polley The O1rec1or . upon advice from Bon d Counsel and fm anc1 al
advisors, may alte r prov 1s1ons of this Investment Policy for arb11rage related investments as may
be necessary to conform with federal arb itrag e regula11ons In all cases however investments
will be m co mphan::e with Colorado Revised Statu tes Th is section Is onl)' applicable to City funds
subJect 10 arbitrage res 1nctI ons
REPORTING
~t report shalt be prepared. at least on a monthly basis, hst1ng the investments held
by the City, the current market valua!lon of the mvestmcnts and performance results The
monthly investment re port shall be subm111ed In a timely manner lo the City Manager and the City
Council, A record shall be ma1n1ained by the Department of Finance and Adm1n1:ma11ve Services
of au bids and offenngs for secun11es transac110ns in order 10 ensure that the City receives
competitive pricint:1
The City has estabhshed reportmg and accounting standards fo r callable U S l nstrumentahty
secunttes Callable securities may be reti red at the issuer's option prior l o the stated ma1<mum
matunty, All securrt1es holding reports for tho City shall disclose the stated malurlty as well as th e
f1rst ca ll date of each callable security he ld In the case of callable secuntIes which are purchased
pnced to the firs t call date and , in the op inion of the Director, have an overwhelming probabihty of
being called on the firs t call date. weighted average maturrty, amortization as well as yield sha ll be
cal.:ula1 ed using the f1rsl can date The Director may. howeve1, choose to use a furth er ca ll dale
maturity date for reporting purposes when cond1 11ons mandate
PERFORMANCE REVIEW
Tho Director and tne C,ty Manager shall meet al least quarterly lo review the portfoho's adherence
to appropnale nsk levels and to compare th'J portfoho's 1otal return to the established investment
objectrves and goals.
T he Director sha ll period,cally 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 10 th.;,
portfolio's actual effective weig hted average maturity When comparing lhe performance of the
City's portfoho. an fees and e1<penses involved with managing the portfolio should be included m
the comput.it10n of !he portfolio's rate of return
I ,
Deleted : ETHI CS ANO CQNFLICJS
Qf..!!fil.!!.U.Tl
AIIC11y emplo'tff1 lnwtvec1111tne
111vutment p,oceu ,nan 1elr1m lrom
pe,son1I bu11n,e11 nclMty that could
coofltetwlthproperuecutlonofthe
11111estm1nt orog111m, Of wllici'i could
rnpa1rtn1t1r1Dilrtyto m1kelmp1111al
lfl\lClltflltfll deaaion, Employ901
11ndu1vu11mentoff1C1al111hald11do1e
tOtlMICityMAMg1t1nyrnaternll
l111ana 1I mlem1t In lin llf'ICl.1!
11\IIJIUIIOnlthalCondUClllvsinouwnn
I
thc C1ty, 11ndtht!yshalllur1hef
drsdose any large J)&l'sonal
linana11/in11e1tme ntpo111l0r\1 tn11
could ne related to tile per!Ofmance
ol the C11y'1 ponloho Employees
I
shallsub01"dmale th1tlf person1!
inve1tmen11ransactJon1to lho1eot
lhe C11y pa1!1Clb:lyw,1h1eg1rdto l/'le
11m~~1chase111Msa!nl
PQ si CY REVISIONS
This Investment Policy wil l De reviewed ~rtod1calty by lhe Director and may be amended as
wndlbons warranl by the Crty Manager and the City Council
Prepared by,
I I
Frank Gryglew1cz
Director of FinanCI! and Adm1mstrallve
Services
Approved by City Council
Septe mber 1 7. 1990
Amended by City Council
December 16, 1991
Amended by Cit)• Council
April 5. 1993
Amended by City Council
June 20, 2005
Prepared by .
:i'.-,-•""D,..a,:::~sc-o---------
Accoun 1ing Manager
Amended by Ci ty Coun cil
Sep tembe r 5, 1995
Amended by Clly Coun cil
December 15, 1997
Ame nded by City Coun cil
February 7. 2000
Amended by City Coun cil
October 16, 2006
Page a
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• S1a1e of Colorado . County ol Arnp ahoe
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t, Loucnshm A Ell is. C11V Clerk in and for the Ci1y of Englewood, in the State aforesaid . do he reby
certify that the foregoing Is a full , true and correc\ copy of me lnvost ment Pol icy as the same
appears upon the records of my office which are m my custody
Given under by hand and olfic1al sea l, th1s __
II
Loucnsh1a A Ellis
Cl1y Clerk
Pagel
APPE NDI X I
Authorized Pe rs on ne l
Th J following pe rsons are au thorized to conduct investment transachons and wire tran sfer funds
on behalf uf the City of Englewood
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Steve Oazzlo , Accounhng Manager
I ~athy Cassel, Accou{ltant .
Kev1r1 Enge ls , Accountant
Chns tine Han. Accountar.t
.. • . { Oekted: J~n nlfer Nolnn , Aecoun tant1 )
Fronk Grygle wicz , Dire ctor of Finance and Admlnistral ive Services
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Poge 10
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APPENDIX II
Repurchase Agreements
The following fir ms have execu1ed a Cily approved Mas1e1 Repurchase Agreement w1th !he Ci ty of
Eng le'NOOd
Banc of Amenca Secunhes , LLC
Mo rgan Stanle y OW Inc ,
Agreements maintained m separate file .
Pigo ',1
APPENDIX 111
Authorized Broker/Dealers and Financial Institutions
The iollowing finns are approved for inve slment putp0sAs by the City of Eng lewood .
Banc of Amonca Securities , LLC
Citigroup Global Ma rkets . Inc.
Funda menta l Capital Ma rkets
I J p Morgan Secu,nies Inc .
Merrill Lynch
Mrzuho Securities USA Inc
Morgan Stanle y
UBS Financia l Services Inc
{ De~ted: Lanman 8ro1ner.1nc.
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APPENDIX IV
Designated Custodial Banks
The following ban~ 1s autho nzed ar, the designated custodial bank for the City of Englewood .
We lls Fargo Bank, NA
Northstar East Bu1ldmg
608 Second Ave , 8th Floor
Mmneapohs , MN 55479
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