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HomeMy WebLinkAbout1997 Resolution No. 113• • • RESOLUTION NO. __/,jj_ SERIES OF 1997 A RESOLUTION ACCEPTING CHANGES OF THE CITY OF ENGLEWOOD'S INVESTMENT POUCY PER ORDINANCE 45 , SERIES OF 1995, ADOPTED ON FINAL READING SEPTEMBER 5, 1995. WHEREAS, by Ordinance 46, Series of 1995, the Director of Financial Services, ex officio City Treaaurer, is empowered to invest all funds and monies not immetl..iate ly needed for operating expenses of the City and various pension funds , pursuant to an investment policy to be adopted by Council each year; and WHEREAS, the Director of Financial Services has hereto attached a copy of the City's Investment Policy for Council's approvRI. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ENGLEWOOD, COLORADO , THAT: ~-The Investment Policy, attached as Exhibit 1, submitted by the Director of Financial Services is hereby approved. ADOPTED AND APPROVED this 15th day ofDecember, 1997 . &&d.fl Loucriahia A. Ellis , City Clerk I, Loucrishia A. Ellis, City Ckrk of the that the above is a true copy of Resok tion No . • • • COUNCIL COMMUNICATION Date 1:,plda Item Subfect Resolution accepting changes to the City of Englewood's December 15, 1997 11 Ci Investment Polley Initiated By, Financial Services Depallment I Staff Source Frank Gryglewicz, Director COUNCIL GOAL AND PREVIOUS COUNCIL ACTION City Council adopted Ordinance 45, Series of 1995 on final reading September 5, 1995. This ordinance made changes to the City Code regarding the investment of City funds, including the adoption of an investment policy. 1hlt adoption of the Investment Polley insures the City's funds am protected from loss of principal, maintain liquidity, and earn an acceptable rate of return . RECOMMENDED ACTION Staff recommends the City Council approve the attached resolub on making c~anges to the City's Investment Policy . The City of Englewood iG requ ired by City Cc,Je to adopt the Investment Policy (4- 1 ·2). BACKGROUND, ANALYSIS, AND ALTERNATIVES IDENTIFIED No alternatives were identified. FINANCIAL IMPACT Th is wi ll have no direct impact on the City's funds . UST OF ATTACHMENTS Proposed resolution Copy of Investment Policy with changes Clean copy of the Investment Pof,cy • • • City of Englewood, Colorado INVESTMENT POLICY The Director of Financial 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 , ii is essential that absolute maturity horizons are ider:utlf.able for the purpose of liquidity. Moreover, these funds must be fully collateralized and appropriately authorized . The following Investment Policy addresses the methods, procedures end practices which must be exercised to em,ure effective and sound fiscal management. gOPE Th is Policy shall apply to the investmen t of all financial assets and all funds of the City of Englewood (hereafter referred to as th e "City") over which it exercises financial C0Mrel, excapt the City of E~glewood Firefighters Pen sion Fund , Volunteer Firefighters Pension Ftm. Police Officer.; Pension Fund, the Non-Emergency Employees Retirement Plan Fund and Olher City employee retirement plans . In order 10 effectively make use of the City"s cash resources . al monies shall be pooled in to one investment account and ac:count9C for separately. The investment ir.come derived from this account shall be distribeted lo the various City funds in accorda:lce with Englewood Municipal Code, 4-1-2-A. OBJECTIVES The City's principal investment objectiv9 s are : • Preservat ion of capital and the protection of inve~trnent principal. • Maintenance of sufficient liquidity to meet anlic1paled disbursements ano cash ~ows . • Diversification to avoid inc urring unreasonable risks rega rd ing securitias ownec~ • Attainment of market rate of return equal lo or higher lhan the perfom,ance measure established by the Director of Financial Services. • Confer mance with all City. Federal. Stale and other legal reqwremen ts . DELEGATION OF AUTHORITY The ultimate responsibility and authority for investment transactions involving the City resides with the Director of Financial Services (he re ina fter referred 10 as the "Director") who has been designated by the City Manager as the In vestment Officer in accordance with Englewood Municrpal Code . The Director may appoint other members of the City staff to assis1 him in the CJsh managem13nt 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 lne wire transfer agreement executed with the City's approved depository fo r bank services (see At>pendix I). The Director shall be responsible for all investm ent decis ions and activities, and shaft establish written administrative procedures for the operation of the City's investment program cor.sistent with this Investment Policy . The Investment Officer acting wrlhin these procedures snail not be held personally liable for specific investment tra nsactions . The Director may in his discretion appoint one or more Investment Advisors . registered with the Securities and Exchange Commiss ion under the Investment Advisors Act of 1940, to manage a ponion of the City's assets . An appointed Investment Advisor may be granted linl\ed investment discretion within the guidelines of lhis Investment Policy wilh regard to the Cit/s assets placed under its management. An In vestment Advisor can only be appoin ted after ce>n.s1.:ttauon with and approval by the C ity Manager. Page 1 ?obey 12-97 final • • • PRUOENCE The s:iandard of prudence to be used for managing the City's assets Is the "prudent Investor" rule , whidll state,s , "Investments shall be mede with judgment and care, under circumstances then ~,ailing, which persons of prudence , discretion and intelligence exercise In the management of their own a/Ian, not for spewlalion, but for Investment cons idering the probable safety of the ,r capital as well as the probablo In come to be derived." (CRS 15-1-304) EUGIBLE INVESTMENTS AND TRANSACTIONS All imlestments 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 lnwsunents for Govemmenlal Units ; CRS 24-75-603, et seq. Depositories; and CRS 24-75-701, el seq. Local Govemments-Local Govemment Pooling . As a home rule City, Englewood may adopt a list of acceptable inve stment instruments differing fror 'those ouUined in CRS 24-75-601 , et seq . Funds-Legal Investments for Governmental Unils . Funes of the City of Eng lewood covered by this Investment Pol icy may be inv ested in the following typeS of securities and lr.m,actions : 1. Treasury Obligations (\'-Bi:ls , T-Notes, T-Bonds). 2. reasury Strips (book-entry U.S. Treasury securities whose coupon has been removed) . 3. !Federal Instrumentalities -Debentures , Discount No tes. Medium Term Notes or Callable Secunties issued by the follow in g only : Federa l National Mortgage Association (FNMA), <:ederaJ Home Loan Bank (F HLB), Federal Home Loan Mortgan • : orporation (FHLMC), i'ederaJ Farm Cred it Banks (FF CB ), anc Student Loan Markeling As:mciat cn (SLMA). • '<epurchase Agreements with a terminat ion date of 90 days or lfJss utilizing U.S. Treasury and Federal Ins trumentality securities listed above , collateralized initially al a min imum market .ralue of 102 percent of the dollar value of the transaction wi!h the accrued interest accumulated on the collateral incl uded in the calculation . If the market value of th e colla!eral tails below 101 percent of the dollar value of the transact ion, the collateral will be required to :,e broug ht up to th e 102 percent initial ma inten ance level. "!epurchase agreements shall be entered into only with dealers who : a ) are recogn ized as Primary Dealers by the Markel Reports Divisinn of the Federa l Reserve Bank of New York; and a) have executed a City approved Master Repurchase Agreement (see Ap pend ix II ). Colla teral (p urch ased securities) sha ll be held by the City's custodian bank as safek eeping age nt and the markel val ue of the colla teral secu rities shall be marked-to-the-market da ily ,asec on the bid pri ce fo r the previo us day as re ported in the Wa ll Street Journal . For the purposes of this se,:tion , the term "collateral" shall mean "p urchused securities" under the term s of the City approved Master Repu rchas e Agreement . In no case will the maturity of tn e collateral exceed ten years . Reve,,;e Repurchase Agreements with a mat urity of 90 days or less executed only agai nst secu ntJ es owned by the City and collateralized by lhe same type of security rever sed . Page 2 Policy 12.:,1 final • • • 6. Flexible Repurchase Agreements with a rina1 mallriy al ten years or 18"1 entered into by Iha City with approved counterpar11es . These flexilie repun:hase agreements may be closed out In varying amounts and at varying limes al the opll.>n al the City. These agreements are deemed by both par11es to be purchases and sales al securities and are not loans . All such flexible repurchase 9!lreements shalt ,,_ the folowing criteria : Be detennlned as legal ~nd valid for both pa-ties; Collateral shall be ilmiled to: a) SectJrilles icsued by, guaranteed by, or for which the credit of any of the following Is pledged for payment: the United States, Federal Fann Credit Bank. Federal Land Bank. Federal Home Loan Bank, Federal Home Loan Mor1gage Corporalion, Federal National Mor1gage Associatkln, Export lfT'9C)rt Bank or the Govemmenl National Mor1gage Association : or b) Securilies issued by, guaranteed by , or for whlCh the credit of the following is pledged for payment: An entity or organization whic:i is not listed in pllragraph a) above, but which is (1) created by, or the creation of "'11ich is authorized by, legl•lalion enacted by the Uniled Slates Congress ana whlCl is subject to contro, by the federal govemment which is al least as exiens:,,,e as that which governs an entity or organization listed in paragraph a) above . and (2) rated in its h,ghes: raling category by one or more nationally recognized ~nizations which regularly rate such obligations. Have a fixed rate during the enlire life of the ~t The dollar amounts and periods of time when the City may draw funds oul of lhe repurchase agreement shall be agreed upon in writing by both parties and shall be par1 of the written repurchase agreement exercised by r:ie 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 percenlage of the~~ down and a specified number of days .. The C ity and lhe counterparty to the agr-,,eni 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 reman,ng balance in the agreemenl for a bona fide, unanticipated cash need: Collateral shall have an original minimum market value (includin g accrued inleresl accumulated) of al least 102 percent of the ooilar value of the transaction. Once a repurchase agreement is established, the collamral mamtained shall be no less than 101 percent of the dollar value of the transaction at a l times: Repurchase agreements shall be enlered into only with dealers who are authorized by the Finance Director an d have executed a City appn:,ved Master Repurchase Agreenent; The lilie to or a perfected security interest in securities. along with any necessary transfer documents. must be transferred and actually def.vered to. and shall be he'd by , the City's third-party custodian bank acting as safekee<>ing agent. The market value of the collateral securilies shall be marked-lo-th~t monthly based on the closing bid price al the time the custodian for th e collateral issues r.s rr,onthiy statement to the City. For the purpose or the section. the Jenn "collateral" sha:t mean "pu rchased securities· under the terms or the City approved Master Rept..rehase Agreement. In no case will the maturity of the collateral exceed ten years . 7. Time Certificates of Deposit or savings accounts m state or national banks operating in Colorado which are slate approved deposrtones (as ev1aenced by a certificate issued by the Slate Ba n king Board) and are insured by the FD IC Cernficates of deposit which exceed the FDIC in sured amount shall be collateralized in acc::,rdance with the Colorado Public Deposit Protection Act. The collateral will aave an r,rtiaJ ,iarxet valu e equal to or exceeding 102 percent of the difference between the inssred amccnt ano the City's total deposits for ail funds within the institution. If the market value of the colla teral fall s below 101 percent of the dollar Paoe 3 Polic y 12-97 final • • • value of the lra~sactlon, the collateral will be required to be brought up to the 102 percent Initial maintenance . 8. Time Certificates of Deposit or savings accounts In state or federally chartered savings and loans operating In Colorado which are insured by the FDIC . Deposits which exceed the FDIC insured amount shall be collateralized In accordance with the Colorado Public Deposit Protection Act. This collateral will have an lnlllal market value equal to or exceeding 102 percent of the difference between the insurect amount and the Cily's total deposit for all funds within Iha Institution. If the market value of lhe collateral falls below 101 percent of the dollar value of the lransectlon, the collateral will be required to be brought up to the 102 percent lnlllal maintenance level. 9. Colorado Loc,,I Government Liquid Asset Trust (COLOTRUSD. 10. Pr ime Bankers Acceptances with a malurily of six months or less issued on domestic banks or branches of foreign banks domiciled In the U.S. and operating under U.S. banklng laws . Accepting banks must have a senior debt rating of A-1 by Moodys and/or A+ by Standard and Poors . 11. Prime Comme rcial Paper with a maturity cf 100 days or le ss which, al the lime of purchase , is ra ted at least A-1 + by Standard and Poors, P-1 by Mcod ys, F-1 by Filch OR D-1+ by Duff and Phelps . a) At the time of purchase, tho commercial paper must Ile rated by at least two of the above stated rating agencies at the stated min :mum rating. b) If more than two of the above stated agencie s rates an issuer , all of those rating agencies must rate the issu er in accordance with above sta ted min imum cred it criteria . c) If the commercial paper is suer has senior debt outstanding , the senior debt must be rated by each service that publishes a rating on the issu er as at least A-1 bl' Moodys, A+ by Standard and Poors , F-1 by Fitch, OR A-1 by Duff and Phelps . OTHER INVESTMENT$ It Is the intent of the City that the fo regoing li st of authorized securities be strictl y interpreted . Ally dev iati on from this list must be pre-approved by the Directo r in wri ting after approval by the City Manager . INVESTMENT DIVERSIFICATION It is th• intent of the City to diversify lhe investment instruments within the portfolio to avoid incurrin~ unreasonao le risks inherent in o·,er investing in spec ific instru ments , individual financial institutions or matcrities . The asset allocation in the portfol io shou ld , however , be Hexible depending upon the outlook for the economy, the securit ies market, and the Ci:Y 's cash How needs . The City may invest to the following maximum li mits with in each category : 100% in U.S. Treasury Obligat ions but not less than 50% • 50 % in Certificates of Oeposrt • 50% rn allowable Federal Instrumentalities • 40% in Repurchase Agreements collatnralized by allowable Federal Instrumental ities 100% ir P.,,purchase Agreements colla ·oralized by U.S. Treasury Obligations • 20% in Barkers Acceptances • 20 % ,n Commercial Paper Page4 Po lic y t 2-97 finnl • • • INVES[MENT MATURITY MD UQUIOITY lnveslments shall be limited ID maturities not exceeding three years . In addltlon , the weighted average matu rlty of lhe total po,ilfollo shall at no lime exceed eighteen months. The City shall at all limes maintain 15% of Its lolal li!wmtment portfolio in instruments maturlng In 120 days or less . OTHER INVESTMENT OUIDEUNES All investment transactions mtllS1 be ""'eculed with broker/dealers and finan cial insti1utlons that have been authorized by the Oily, and each transaction must be competitively transacted with at least two aulhorize<1 brokerldlealers financial institutions. In addition, before any repurchase agreements shall Im execullld with an authorized broker/dealer or llnancial Institution, a City approved Master Repurchase Agreemen t must be signed between the City and that broker/dealer or fi nancial Institution . The Director shall ma intain a file of all Master Repurchase Agreements . The purchase and sale of al s«:urities shall be on a deli\'ery versus payment or payment versus delivery bas is. For Instance, for securities purchases, me nies will not ca re leased by the City's safekeep ing bank until secuities a-e received at the Federal Reserve Bank for further credit to the City's safekeeping ban k. In tt.,e case of securities sale,,, mon ies will be received by the City's safe keeping bank via the Federal Reserve Ban k as the s,,curities are simultaneously released lo the purchaser. In this mamer the City will always have p,,ssession of either its securities or its mon ies . The City seeks an active, -than passiv,,, management of its portfolio assets . Assets may be sold al a loss only if the Dinlc:mr or the Investment Advis or feels that the sale of lhe security Is in the be st long-term interest d <l'ie City . SELECTION OF BROKER.t>EALERS AND FINANCIAL INSTrTUTIONS ACTING AS BROKER/DEALERS . The Direct or shall ma intain a AISI of authorized broker/dealers and financial institutions which are approved for investment purp,oses (see Append ix Ill), and il shall be Iha policy of the City 10 purchase securities only from !:hose authorized in sutu tions and finms. To be elig ihle. a firm/ban k ITUJSl meet at least one of lhe following crite ria : 1. be racog "•zed as a Primary Dealer by me Markel Repons Div isio n of the Federal Reserve Bank of New Yo rk, 2. report voluntarily to th e M•arket Reports Divis1011 of the Federal Reserve Bank of New York, 3. be approved by the Directer after a comprehensive cred it and capitalization analysis indicates Iha fim-is adequately financed lo conduct business with the City , or 4. be an FDIC member. Brokeri d&alers and other financial 1nsti1u l ions will be selected by the Director on the bas is of lheir expei1ise in pub lic ca::th management and the ir ability to provide service to the City 's account. [ach bro ke r/dea ler , bank or savings and loan that has been authorized by the Director shall be req uired to submit and annually update a City approved Broker/Dealer lnfonmal ion Request fonm which incl udes the firm's most recent finan cial sta ierr.en ts . Th e Director sh all maintain a file of the mos! recent Broi<er/Dealer lhformation Re ques t fonms submitted by each finn approved for investment purposes . Broker'Dealers shall al so attest in writing that they have received a copy of this Pol icy . P;»ge 5 Pol icy 12-97 final • • • SELECTION OF BANKS AND SAVINGS ),.'~U LOANS AS DEPOSITORIES AND PROV]DER$ OF GENERAL BANKING SEF.'£1 E.$. The City shall maintain a 11st uf , Jriz9<1 banks and savings and loans which are approved to provide banking services or from whom the City may pun:hase certifk:alal al deposit . To be eligible for autt,urizatlon , a bank r,r ••vi, ,gs and loan must meet the minimum aedit criteria (described below) of credit analy-.<,s ""''"""d by a commercially av.-talk ra&,g service. Banks or savings and loans failing to meet the minimum criteria, or in the judgrTa1I at the Director no longer offering adequate safety to the City , will be removed from the ,'SI. 'lil!hough a bank or savings and loan Is on the qualified list, It will still be required lo pledge ~ on all deposits and Investments, pursuant to State law . The City shall utilize a commercially avai lable bank rat ing serv.•:~ ISheshunGff, PMA Financial Network) to perform a semiannual credit analys is on be,,,, c ·d , .... -gs and loa>s. The bank rating guidelines will be calculated using publ idy avai ab '0 -~:. -,ocb: · ·lo m.-.iion obtained from the release of the Consolidated Reports of Condition and lnco •r, 11-F1;::: Rt,p0l'tJ from the Federal Reserve or from data reported lo the Comptroller of the Cu :.,-ncy . Data oblaC'1ed trom 'h e bank rating service will Include factors covering the following: overall rating , liquidity potlcy , credit risk policy, interest rate policy , profitability and capital policy. In order to meet the minimum credit criteria, a bank or savings and loan rTKJS rneef the following credit rating requirements : 1. have a Sheshunoff Public Finance Peer Group Rating of 30 or better on a scale at zero lo one hundred with one hu. 1dred heing the highest quality for tho most recen1 repcrtin!J quarter, or 2. have a PMA Financial Network overall rating of three or t,etter on a scae al cne to five with one being the highest quality for the most recent reporting quarter. 3. The institution must qualify as a depository of public funds in Colorado as nefined in CRS 22- 40-105. The Director shall ,saints;,, a file of all credit rating analysis reports perfooned 'er the City . SAFEKEEPING AND CUSTODY The safekeeping and c·Jstody of secunl ies owned by the City shall be managed i1 accordance with Colorado law and applicab le Attorney General opinions, Regu lation 3-,-s . LJse of Clearing Corporations and Federal Reserve Book-Entry System . The Director shall approve one or more financial institutions lo provide safekeepiig and custodial services for the City . A City approved Safekeeping Agreement shaB be exr .:uted with each custodian bank prior to utilizing Iha• bank 's safekeeping services . To be eligll:ile ior designation as the City's safekeeping and custodian bank, a finanoal institution shall meet tt,e following criteria: 1. have a Sheshunoff Publ ic Finance Peer Group Rating of 20 or better on a scale of zero to one hundred with one hundred being the highest quality for the most recent reporting quarter, or 2. have a PMA Finanrial Network overall rating of three minus or better on a scale of one to five with one being the highest quality for the most recent reporting quarter. Custodian banks will be selected on the bas is of their ability to prov,rte serv,ce to the City's accoun t and the compet itive pricing of their safekeeping relat ed serv,ces (S&~ Appendix IV). The Director shall req uire each approved safekeeping financial insoruocn cc submrt a copy of its Consolidated Reports of Cond ition an d Income (FFIEC Report ) to the City . ,e Drector shall also maintain a file of lhe credit rating analys is repo rts performed for eac:, approved financia l instituti on. Page 6 Pohc y 12-97 final • • • II ls lhe<Objedive of the City that all owr.ed 1.;..uitl'YJ be perfected In lhe name of the City . All investment securilles , except non-ne,;i?<iable cer lflcales of deposit and money market funds, pun:1,-d by the City will be delive,ed by •1"1er bo<.c~ entry or physical delivery and .viii be held In lh~ ulekeeplng by a City approve<; ,..,,lcdlbn bank, Its correspondent New Yo;k bank or the ~ Trust Corporation (OTC). The Olly's perlecied ownership of all book entry securities shall be evidenced by a safekeeping receip! issued lo the City by the custodian bank who gets as lhe City's safekeeping agent. The safelreeping receipt shall state Iha! the securities are held In the Federal Reserve system either In a CuSllDmer Account/1030 for the custodian bank which will name tne City as •customer" or in a Trust Accow,t/1050 with tha trust department named as agent for lhe City. All non-boat. entry (physical de:ivery) securities shall be held by the custodian bank's com,s;,ondatt bank in New vork City and the custodian bank shall issue a safekeeping receipt lo lhe Ol!y evic!e!lcing that the securilles are held by lhe correspondent bank for t~8 City. The City may ortllize the services of the Deposttory Trust Corporation (OTC) as a depo!litory for delivery of norw-l!Nbfe securities . AD c..s!Ddied secu.~lles Iha! are registered shall be registered in the name of lhe City or in the name of a nominee of the City or in the name of the custodian or its norninee or, ~ in a clearing c:orp01"ation . in the name of lhe clearing corporation or its nominee. The City's custodian will t,,; required lo furnish :·.a City with a monthly report of securities held as well as an account analysis rep01; of monthly securities actlvl(!• . PROVISIONS FOR ARBITRAGE The City peoodically i5sues debt obligations which are subject lo the provisions of the Tax Reform Aa ol 1986 (s,x:lion 148F), Artlitrage Rebate Regulations . Due lo the legal complexities of arbitrage law and the necessary immunization of yield levels, lhe procedures undertaken in the reinvestment of all or a portion of the proceeds of such debt issuance may extend beyond those outlined in th,s Policv. The Direc10r, upon advice from Bond Counsel and financial advisors. may alter ;,T'OVISions of this Policy for arbitrage related investments as may be necessary lo conform wrth ledera! arbitrage regulations. In all cas es, however, investments will be in cnmpliance with Cciorado Revised Starutes . This section is only applicable 10 City funds subject to arbitrage restrrt:t>onS . REPORTING An investment report shall be prepared, al least on a monthly basis, lisl io g lhe investments held by itle City. the c ,rrenl market valuation of th e investments and performance results . The monli11y investment report shall be submitteo in a timely manner :o the City Manage, and the City Council . A record shall be maintained by lhe Department of Financial Services of all bids and offermgs for securities transactions in order to ensure that the City receives compet itive pricing . The City has established reporting and accounting standards for callable U.S . Instrumentality sec:.rrit,es . Callable securities may be retired al Iha issue~s option prior lo the staled maximum man..mty . All securities hold in g reports for the C ity shall disclose the slaleci maturity as well as the fir5t ::all dale of each callable security held. In the case of callable recunlies wh ich are purchased pnced to the first call date and, in the opinion of the Director, have a,1 overwhe;'11 ing probability of being called on lhe first ca ll date. weighted average maturity , amortization as well as yiel d shall be calculated using the first call date . The Director may . however. choose lo use a t Jnher call dale rr,arunty date for rep ortin g purposes when conditions mandate . Page 7 Policy 12-97 final • • • PERFORMANC~ The Director and the City Manager shall meet at /eutqualr.ly to review the portfolio's sdherence to appropriate risk levels and to compare the por1fctiio'• IUtrl return to 11,e "91abllshed h,vestment objectlvos and goals . The Director shall periodically establish a benchmall< yield .for the City's investments which shall be equal to th e averege yield on the U.S. Treasury seariywhich most dosely corresponds to the portfolio's actual weighted average maturtty. When con:paring ttie perfonnance of the City', portfolio , all fees and exper,ses Involved with managr,g lh! portfolio should be induded in the computation of the portfolio's rate of return . ETHICS AND CONFLICTS OF INTEREST Officers and employees involved In the investment process shall refrain from personal business activity that could conOict with proper execution of the ~t program , or which could impair their ability to make impsrtiai investment decisions. En:pioyees and investment officials •hall disclose to lhe City Manager any material financial minst in financial institutions that conduct business with the City, and they shall further di5dose any l.w-ge personal financiaVinvastment positions that could be related to lhe perfonnance ol the City's portfolio . Employees and officers shall subordinate their personal investment transadions to those of the City particular1y with regard to lhe timing or purchases and sales . POLICY REVISIONS This Investment Polley will be reviewed periodically by ilhe Director and may be amended as conditions warrant by lhe City Manager and the City Council . Amended by City Council December 16, 1991 Amendoo by City Council April 5, 1993 Slate or Colorado, County of Arapahoe St..,.,Dazzio Cn.J Ac=untant Amendec oy City Council Sep¢emc:er 5, 1995 Amendeo by City Council Decemcer 15. 1997 I, Loucrishia A. Ell is . City Clerk in and for the City of Englewood, in the State aforesaid, do hereby certify that the foregoi ng is a fu 11, true and cor-ect a,µy of the Investment Policy as the same appears upon lhe records or my office which are in my CJSlody . 1997, //:.2.J..... Poge 8 Policy 12-97 final • • • APPEl~DIX I Authorized Personnel The following peniona are authorized to conduct lnveslment transactions and wire transfer funds on behalf of the City of Englewood : Steve Dazzle , Ch ief Accountant Jennifer Nolan, A=untanl II Frank G,yglewicz, Director of Finan cia l Services Paga9 Policy 12-97 final • • • APPENDIX II Repurchaee Agreements The following flnns have execul8d a City approved Master Repurchase Agreement with the City of EngieWOOd . Merrill Lynch Prudenlial Securitles Smith Barney Agreements maintained in sec-ate fie . Pago 10 Policy !2-97 final • • • APPENDIX Ill Authorized Broker/Dealers and Flnanclal Institutions The follow in g flnns are approved for Investment purposes by the City of Etl{lewood. Kirkpatrick Pettls Merrill Lynch Paine Webber Prudential Securities Smith Barney Page 11 Pobq i:l!-97 final • • • APPENDIX IV Dnlgnated Cuatodlal Banks The lcllowing bank Is authorized as lhe designated custodial bank for the City of Englewood : Weis. F argo Bank Arizona POBcx2ST75 """'-'ix. AZ. 85038-9775 Pag,, 12 Policy 12-97 final