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HomeMy WebLinkAbout2006 Resolution No. 079• • • RESOLUTION NO. j:l_ SERIES OF 2006 A RESOLUTION ACCEPTING CHANGES AND UPDATES TO 1lil! CITY OF ENGLEWOOD 'S INVESTMENT POLICY PER ORDINANCE 45, SERIES OF 1995, ADOPTED ON FINAL READING SEPTEMBER 5, 1995. WHEREAS, by Ordinance 45, Series of 1995, the Director of Financial Services, ex officio City Treuurer, ia empowered to invest all funds and monies not immediately needed for operatina expenditwa/expensea of the City except for the Firefighters Pension Fund, the Volunteer Firelighters Fund, the Police Officers Pension Fund and the Non-Emergency Employees Pension Fund and pursuant to an investment policy to be adopted by Council each year; and WHEREAS, the passage of this Resolution will authorize changes and updates to the Englewood Investment Policy; NOW, TiiEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF Tiffi CITY OF ENGLEWOOD, COLORADO , THAT : ~-The City ofEnglewood Investment Policy, attached as Exhibit I, submitted by the Director of Financial Services is hereby approved . ADOPTED AND APPROVED this 16th of October, 2006 . ~fu v ~ I, Loucriahia A. Ellis , City Clerk for the City of Engleweo:d, C above is a true copy of Resolution No . :J.j_, Series of2 . , hereby certify the .. t!l· U,ucriahia A. Ellis, City Cleric • • • City of Englewood, Colorado INVESTMENT POLICY The Director of Finance and Administrative Services of the City of Englewood , Color■dl) 11 charged with the responsibility to prudently and properly manage any and all fund, of the City . Because the se funds may be called upon, it is essential that abaolute maturity horizon, are identifiable for the purpose of liquidity . Moreover, these funds must be fully collatarallzed and appropriately authorized . The following Investment Policy address,,s the mathod1, procadur■1 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 fund, of Iha City of Englewood (hereafter referred to as the 'City') over which it exercise, financial control , except the City of Englewood Firefighters Pension Fund , Volunteer Firefighters Penalon Fund , Police Officers Pens ion Fund , the Non-Emergency Employees Retirement Plan Fund and other City employee retirement plans . In order to effectively make use of the Clty '1 caah raaourcH, all monies shall be pooled into one investment account and accounted for aaparataly . The investment income derived from this account shall be distributed to the variou1 City fund, In accordance with Englewood Municipal Code , 4-1-2-A . OBJECTIVES The City's principal investment objectives are : • Preservatio n of cap ital and the protection of investment princiµal . • Maintenance of sufficient liquidity to meet anticipated disbursement, and caah now,. • Diversification to avoid incurring unreasonable risks regarding aacuritle1 owned . • Attainment of market rate of retum equal to or higher than the par1orrnanca mea,ure established by the Oirector of Finance and Adm inistrative Service,. • Conformance with all City , Federal , State and other legal raqu lr9mant1 DELEGATION OF AUTHORITY The ultimate responsibil ity and authority for Investment tr■n111C1lon1 Involving Iha City raakln with the Oirector of Finance and Administrative Servlcel (h, elnaftar rafffled to H Iha 'Director') who h,.s been designated by the City Manager II the Investment Officer In accordance with f:nglewood Municipal Code . The Director may appoint Olhar members of Iha City 1taff to HIii! him in the cash management and Investment function . PafS0111 who •• authorized to tranuct business and wire funds on behalf of the City will be dnignlllad by Iha Oiracto, by Iha wire transfer agreement executed with the City's approved dapotlto,y for bank aat'Vicn (-Appendix I). The Director shall be responsible for all Investment dac:ilion1 and llcilvltln , and 1hall Htabliah written administrative procedures for the operation of Iha City'• Investment program conll1tant with this Investment Policy. The Investment Officer acting within lhHe procedure, lhlll not be held personalty liable for specific Investment tranaactlon1 . The Director may in his discretion appoint one o, more Investment Advilors , r■g l atarad Wl,h the Securities and Exchange Commlaslon under the lnvHtmanl AdviHrl Aci of 11140, to m•n• • portion of the City's assets. An appointed lnvutment Ad~ may be granted limited lnva1tmant discretion within the guidelines of this lnvaatmant Poffcy with r■ganl to Iha City'• HHII placed under Its management. An Investment Advtso, can only be appolnlad after con1ultation with and approval by the City Manager. PIQOI E )C h i b i t PRUDENCE The ltandard of prudence to be uNd for managing the Clty'1 a11et1 la the "prudent lnveator" rule , which ■tatN that a prudent •,ve■tor "■hall exerci■e the judgment ■nd care, under the clrcuml1ancel then p,evalllng , which men of prudence , dllcretlon, and Intelligence exerci ■e In the management of the propel1y of another, not In regard to speculatlo~ but In regard to the permanent dl1po1ltlon of funds , con11dering the probable Income II well as the probable safety of capital ." (CRS 15-1-304 , Standard for lnve■tmentl .) The City's overall lnveatment program ■hall be dealgned and managed with a degree of prohulonallsm that Is worthy of the public trust. The City recognizes that no Investment Is totally riskleu and that the Investment activities of the City are a matter of public record . Accordingly, the City recognizes that occasional meaaurad lo1aea may be desirable In a diversified portfolio and shall be conslderad within the context of the portfolio's overall ratum , provided that adequate diversification has been Implemented and that the sale of a security Is in the best long-term interest of the City . ELIGIBLE INYEBIMENTS AND TRANSACTIONS All lnveatments 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 24-75-801 , et seq . Funds-Legal Investments ; CRS 24-75-803 , et seq . Depositories ; and CRS 24-75-7 01, et seq . Investment Funds-Local Government Pooling . 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 , el seq. Funds-Legal Investments . Funds of the City of Englewood covered by th is Investment Polley 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 5 years from the dale of trade settlement 2. Treasury Strips (book-entry U.S. Treasury securities whose coupons have been removed) with maturities not exceeding 5 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 Assoc iation (FNMA), Federal Home Loan Bank (FHLB), Federal Home Loan Mortgage Corporation (FHLMC) and Federal Farm Credn Banks (FFCB), with maturities not exceeding 5 years from the date of trade settlement. 4. Repurchase Agreements with a term ination 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 collate,:,I incl uded In th calculation . Repurchase agreements shall be en tered Into only with dealers who : a) are recogn ized as Primary Dealers by the Federal Fleserve Bank of New York , or with firms that have a primary dealer with in their holding o>mpany structure : and b) have executed a City_ approved Muter Repurch■u Agreement (see Appendix II). Th& Director ■ha ll maintain a flit of all executed Mater R~purchase Agreements . Primary Dellerl ar,proved • Repurchlaa Agreement counterpartiea, ij rated, shall have a ■hort-term Cl9dlt rating of ■t Ital A-1 or the equivalent and a long-term cradlt rating of al least • A or the equivalent Pogo2 • • • Collatel'II (purchued aecurltiet) 1hall be held by the Clty'1 custodian bank II aafekeeplng agent, and th■ market value of the collatar1I HCUrltiet lhall be marked-to-the-market dally . For the purpol■S of this HCllon, the term 'coll■ter1r lhall mean 'purchased aecurltle1' under the term, of th■ City approved M11ter Rapurch■H Agreement In no case will the maturlty of the collateral exceed ten yeara . 5. Reverse Repurchase Agreements with a matu~ of 90 days r less executed only against securities owned by the City and collaterallzed by the same type r,f socu~ reversed. 6. Flexible Repurchase Agreements with a final matu lty , ten yearr. or less entered into by the City with approved counterparties . These flexible rape . · ,se agreements may be closed out In varying amounts and at varying times at the option ;,' tfle City. These agreements ans deemed by both parties to be purchase ; and sales of s~curil:Rs · nd are not loans . All such flexible nspurchase agreements shall meet the following crileria: 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 Ban•. Federal Land Bank , Federal Home Loan Bank , Federal Home Loan Mortgage Corporation . F~,:~..,,I National Mortgage Association, Export Import Bank or the Govemr ,1·1nt. :li&t.~-,.., Mortgage Association; or b) Securilies issued by, guaranteed by, or tor which the credit of the followin t1 ·,• plrdgaJ for payment: An entity or organization which is not listed in paragraph a, ohova, but which Is (1) created by, or the cnsation of which is authorized by , legislation enacted by the Un :led States Congnsss 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 entins Ille of the agreement; The dollar amounts and periods of time when the City may draw funds out of the re~urchase agreement shall be agreed upon in writing by both parties and shall be part of the written nspurchase agreement exercised by the City and the approved counterparty ; The City has the option of varying the dollar amount and the timing of the draw down by an agreed upon percentage of the~ 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 agnsement Is structunsd . It :ddltion, the City may draw down in excess of the variance up to the remaining balance in the agreement for a bona fi de, unanticipated cash need; Collateral shall have a minimum market value (Including accrued intensst accumulated) of at least 102 percent of the dollar value of the transaction; Repurchase agreements shall be entensd 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 Agnsements; The title to or a perfected aecurlty 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 cuntodlan ban• acting as safekeeping agent The market value of the collateral ser.:urltles shall be merked·to-th~-market at least weekly based on the closing bid prlce at the time the custodian for the collatensl luuas Its monthly statement to the City . Pogo 3 For the purpose of the section, the term 'collateral" shall mean 'purchased securities ' under • the term, of the City approved Master Repurchase Agreemenl In no case will the ma turity of the collateral exceed ten yeara . 7. Time Certificates of Deposit with a max imum maturity of 5 ye■ra 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 l11ued by the State Banking Board) and are Insured by the FDIC . Certificates of deposit that exceed :c~ FDIC Insured amount shall be collateralized In accordance with the Colorado Public G, .. ,oslt Protection Act. The collateral shall have a market value equal to or exceeding 10 2 ·,,arc~nt of the difference between the insured amount and the City 's total deposits for all f .... os within thA institution. B. 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 pc,~hases ~r sales of shares); 2) have a constant net asset value per share of $1 .00; 3) limit as.,:,; of tl,a fund to securities authorized by state statute ; 4) have a max imum stated matu my an.I weighted average maturity in accordance with Rule 2a-7 of the Investment Compan ~ Ac, of 1940 ; and 5) have a rating of AAAm by Standard and Poor's , Aaa by Moody's or AAAN1 + by Fitch . 9. Colorado Local Government Liquid Asset Trust (COLOTRUST) 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 and F1 by Fitch at the time of purchase by at least two service s that rate them and shall be rated not 19ss by any service that rates them, with a maturil\' of six months or less issu ed on domestic oanks or branches of foreign banks domicHed in the U.S. and operati,ig under U.S. banking ;3ws . 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 maturi~• 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 and 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 more than two of the above stated agencies rates an issuer, al. of those rating agencies must rate the issuer in accordance with above stated minimum credit criteria. c) If the commercial paper issuer has senior debt outstanding , the senior debt must be rated by each service that publishes a rating on the is suer as at least A2 by Moody 's, A by Standard and Poor's and 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 settlen :ent, rated at least AA-by Standard & Poor's , Aa3 by Moody's, or AA by t'itch at the time of purchase by each service that rates the debt. Authorized corporate bonds shall be U.S. dollar denominated , and limited to corporations organized and operated within the United States with a net worth in excess of $250 million . OTHER INVESTMENTS It is the intent of the City that the foregoing list of authorized securities be strictly interpreted . Any deviation from this 11st must be pre-approved by the Director in writing after approval by the City Manager. INVESTMENT DI\IERSIFICATION • tt Is the intent of the City to dlveraify 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 Page-1 • • • depending upon the outlook for the economy, the securities marliet, and the City's cash flow need1 . The City may Invest to the following maximum limlta within each category: • 50% In Certificates of Deposl : • 40% in Commerclel Paper • 20% In Bankers Acceptances • 30% In Corporate Bonds ; 5% In any or.e issuer or Its affiliates or subsidiaries Tests for limitations on percentages of holdings apply to the composite of the entire portfolio of th e 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 . INVESTMENT MATURITY AND LIQUIDITY Investments shall be limlted to maturities not e~ceeding five years . In addition , the weighted average final maturity of the total portfolio shall at no time exceed 24 months SELECTION OF BROKER/DEALERS . The Director shall ma inta in 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 Fede r~I Reserve Bank of New Yo rk 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 Commissi on (SEC) Rule 1 Sc-3 (Uniform Net Capital Rule). Broker/dealers will be selected by the Director on the basis of their expertise in publ ic cash management and the ir ao ili!y to provide service to the City's account. Each authorized broker/dealer shall be required to submit and annually update a City appro•,ed Broker/Dealer Information Request form which Includes the fir.n 's most recent financ ial statements . Broker/Dealers shall attest in writing that they have rece ived a copy of this Investment Policy . The City may purchase Commercia l 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 12 of the Eligible Investments and Transactions section of this Investment Policy . CQv ,PEI!IIYE TRAN~ E11ch Investment transaction shall be competitively transacted with authorized broker/dealers . At leust three broker/dealers shall be contacted fo r each transacticn and their bid and offering prices sh,1II be recorded . II the City is offered a security for which th•re is no other readily available competttive offering , then the Director will document quotation s for comparable or alternative securities . SELECTION OF BANKS AS DEPOSrrORIES AND PROVIDERS OF GENERAL BANKING ~ The City shall maintain a list of banks approved to provide banking sarvlcas or from whom the City may purchase certificates of deposit Banks In the judgment of the Director no longer offering Page 5 1.dequate 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 ;;th applicable Federal and Colorado laws and regulations . The Director shall approve one or more banks to provide safekeeping and custodial services for th e 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 Stale of Colorado as defined in CRS 24-75-603 and be a Federal Reserve memoer financial institution . Custodian banks will be selected on the basis of their ability lo provide service lo the City 's account and the competitive pricing of their safekeeping related services . The City's designated custodian bank is set fo ,th in Appendix IV of this Investment Policy . 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 modern investment , banking and commercial practices . All investments , except certificates of deposit and local government investment pools purchased by the City shall be delivered by either bock entry or physical delivery and will be held in third-party safekeeping by the City's designated custodian bank. its correspondent bank or the Depository Trust Company (DTC). 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 staling that the secu•ilies are held in the Federal Reserve system in a Customer Account for the custodian bank whic ,1 will name the City as ·customer." All OTC eligible securiti~s 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." 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 lo the City evidencing that the securities are held by the correspondent bank 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 lo the provisions of the Tax Reform Act of 1986 (section 148F), Arbitrage Rebate Regulations . Due to the legal complexities of arbitrage law and tho 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 01Jllined in this lnveslmer,t Policy . The Director, upon advice from Bond Counsel and financial acvisors, may alter p:ovisions of this Investment Policy for arbitrage nslated Investments as may be necessary to conform with federal arbitnsge regulations . In all cases, however, lnveatments • • will be In compliance with Colorado Revised Statutes . This section Is only applicable to City funds • subject to arbitrage restrictions . P1ge6 • • • REPORTING An lnveatment report shall b6 prepared, at least on a monthly basis, listing the Investments hbld by the City, the current market valuatlon of the investments and performance results . The monthly lnveatment report shall be submitted In a timely manner to the City Mana~er anJ the City Council. A record shall be maintained by the Department of Finance and Administrative :lervlces of all bids and offerings for securities transactions In order to ensure that the Cr.y receives competitive pricing . The City has established reporting and accounting standards for callable U.:l. l ns\nlmentallty securities . Callable securities may be retired at the Issuer's option prior lo 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 wtlich are purchased priced to the first call dale and, in the opinion of the Director, have an overwhelming probability of being called on the first call dale, weighted average maturity , amortization as well as yield shall he calculated using the first call dale . The Director may, however, choose to use a further call d· :e maturity datti for reporting purposes when conditions mandate . PERFORMANCE REVIEW The Director and the City Manager shall meet at least quarterly le review the r.•"tloiio's adherence to appropriate risk levels and to compare the portfolio 's total return to ~, es1"blished Ir .vestment objectives and goals . The Director shall periodically establish a benchmark yield for the City's inv~stments which shall be equal to the average yield on the U.S. Treasury security which most closely corresponds lo the portfolio 's actual effective weighte<i average maturity . When comparing the performance of the City's portfolio , all lees and expenses involved with managing the portfolio should be included in the computation of the portfolio's r.•le of return . 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 financia/ institutions that conduct business with the City, and they shall further disclose any large personal financiaVinvestmenl positions that could be related lo the performance of the City's portfolio . Employees shall subordinate their personal investment transactions to those of the City particularly with regard to the timing of purchases and sales . Pogo 7 PQUCXMYJIIONI • Thll lnveaanent Polley wlll be nivlewed pertodlc:llly by the Director and may be amended H condition• warrant by lhe City Manager and the City Councll. Prapared by: Fnink Gryglewlcz Director of Finance and Administrative Service, Approved by City Council September 17, 1990 Amended by City Council December 16, 1991 Amended by City Council April 5, 1993 Amended by City Council June 20, 2005 Prepared by: Isl ___________ _ Steve Dazzlo Accounting Manager Amended by City Council · September 5, 1995 Amended by City Council December 15, 1997 Amended by City Council February 7, 2000 Amended by City Council ----~2006 Pogoe • • • • • State of Colorado , Cou~ of Arapahoe: I, Loucrilhll A Ellla, City Clerk In and for the City of Englewood, In the State 1loreuld, do hereby certify that the foregoing 11 1 full , true and correct copy c! the lnve,tment Polley 11 the ume appears upon the records of my office which ■re In my cu1tody . Given under by hand and official aeal, this __ . Loucrlshla A. Ellis City Clerk APPENDIX I Authorized Pereonnel The following persona are authorized to conduct Investment transactions and wire transfer funds on behalf of the City of Englewood : Steve Oazzlo, Accounting Manager Jennifer Nolan, Accountant Kathy Casaal, Accountant Kevin Engels, Accountant Christine Hart, Accountant Frank Gryglewicz, Director of Finance and Administrative Services Pogo 10 • • • • • • APPENDIX II Rtpurchaa• Aglffmtnta The following firms hive executed a City approved Master Repurchase Agreemen t wi th the City of Englewood . Banc of America Securities, LLC Morgan Stanley DW Inc . Ag reements maintained In separate file . P1ge 11 APPENDIX Ill Authorized Broker/De1lera and Fln1ncl11I ln ■tltutlon• The following firms are approved for Investment purposrs by the City of Englewood . B,1nc of America Securities , LLC C,tigroup Global Markets , Inc . Fundamental Capital Markets Lehman Brothers Inc . Merrill Lynch Mizuho secu ri ties USA Inc . Morgan Stanley UBS Financial Services Inc . Pogo 12 • • • • • • APPENDIX IV DHlgn ■ted Cuatodlal Bank■ The following bank Is authorized as the designated custodial bank for the Cl~/ of Englewood : Wells Fargo Bank, NA Northstar East Building 608 Second Ave ., 8th Floor Minneapolis , MN 55479 Pogo 13 .. • • • COUNCIL COMMUNICATION Dale Agenda Item Subject October 16, 2006 9 Ci Resolution Appr'lving Proposed Changes to the City of Englewood Investment Policy Initiated By Staff Source Department of Finance and Administrative Frank G ryglewicz, Director Services COUNCIL GOAi. AND PREVIOUS C, >UNCIL ACTION The Council discussed proposed chani;es to the Investment Policy at the study session held October 9, 2006 . RECOMMENDED ACTION Staff recommends Council approve the changes and updates to the attached Investment Policy. The Investment Policy is applicable to the investment of all funds not immediately ne eded for the operating expenditures/expenses c,f the City, except for the Firefighters Pension Fund , the Volunteer Firefighters Fund, the Police Officers Pension Fund , and the Non-Emergency Employees Pension Fund . · FINANCIAL IMPACT There is no direct financial impact to the City from adopting the proposed changes to the Investment Policy. LIST OF ATTACHMENTS Proposed res o lution Amended Investment Policy