55D - RESO STATEMENT INVESTMENT POLICY

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6.0 ETHICS AND CONFLICTS OF INTEREST 6.1 Investment Officials and Officers Investment officials, officers, and employees involved in the investment process shall refrain from personal business activity that could conflict with the proper execution and management of the investment program, or that could impair their ability to make impartial decisions. Investment officials, officers and employees shall disclose any material interests in financial institutions with which they conduct business. They shall further disclose any personal financial/investment positions that could be related to the performance of the investment portfolio. Investment officials, officers and employees shall refrain from undertaking personal investment transactions with the same individual with whom business is conducted on behalf of the City of Santa Ana. 6.2 Statement of Economic Interests Investment officials and officers authorized to approve investment decisions shall be required to submit an annual Statement of Economic Interests, also known as a Form 700 in accordance with California Government Code, Section 1090 et seq. The Form 700 provides transparency and ensures accountability in two ways: 1) It provides necessary information to the public about official's/officer's personal financial interests to ensure that officials and officers are making decisions in the best interest of the public and not enhancing their personal finances. 2) It serves as a reminder to the public official of potential conflicts of interest so the official or officer can abstain from making or participating in governmental decisions that are deemed conflicts of interest. 7.0 AUTHORIZED FINANCIAL INSTITUTIONS AND QUALIFIED BROKER-DEALERS 7.1 Authorized Financial Institutions The City shall transact business only with banks, savings and loans and registered investment securities dealers. 7.2 Qualified Broker -Dealers The purchase by the City of any investment other than those purchased directly from the issuer, shall be purchased either from an institution licensed by the State as a Broker -Dealer, as defined in Section 25004 of the Corporations Code and registered with Financial Industry Regulatory Authority (FINRA), or a member of a Federally regulated securities exchange, a National or State -Chartered Bank, a Federal or State Association (as defined by Section 5102 of the Financial Code), or a brokerage firm designated as a Primary Government Dealer by the Federal Reserve Bank, and who is registered with FINRA. City of Santa - Annual July 1, 2018 - Statement of Investment Policy d1M 1 3 June 30, 2019