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• Shares of Beneficial InteresbMoney Market Shares -no final stated maturity <br />(See also subsection 8.2 generally for additional information on City authorized <br />concentration limits and quality requirements.) <br />14.2 Average Maturity <br />In accordance with the goal of minimizing interest rate risk (see subsection 4.1(b)) <br />the City of Santa Ana will to the extent possible attempt to aim for an average <br />investment portfolio maturity of 3 years. <br />15.0 INTERNAL CONTROLS <br />The Executive Director for FMSA is responsible for establishing and maintaining an <br />internal control structure designed to ensure that the assets of the entity are protected <br />from loss, theft or misuse. The Executive Director for FMSA has developed a system of <br />internal investment controls and a segregation of responsibilities of investment functions in <br />order to assure an adequate system of internal control over the investment function. No <br />investment personnel may engage in an investment transaction except as provided for <br />under the terms of this policy and the procedure established by the Executive Director for <br />FMSA. <br />Internal control procedures address: <br />• Control of collusion <br />• Control of fraud <br />• Control of misrepresentation by third parties <br />• Control of employee error <br />• Separation of transaction authority from accounting and record keeping <br />• Custodial safekeeping <br />• Delivery versus payment <br />• Clear delegation of authority <br />• Conformation of transactions for investment and wire transfers <br />• Written procedures for placing of investment transactions <br />• FMSA Investment Advisory Committee <br />In addition, cash balances are reconciled <br />reconfirmed by the City's accounting staff. <br />activities and holdings on a monthly basis <br />daily by non -investment employees and <br />Accounting staff also verifies investment <br />as part of the FMSA Investment Advisory <br />Committee. The Executive Director for FMSA, at his/her discretion, shall establish a <br />process for annual independent reviews by an external auditor to the extent contemplated <br />by generally accepted auditing standards. <br />City of Santa - Annual Paa 18 July 1, 2018 - <br />Statement of Investment Policy 555-24 June 30, 2019 <br />