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July 1, 2023 - <br />June 30, 2024 <br /> City of Santa - Annual <br />Statement of Investment Policy Page 15 <br />9.3 Prohibited Investment Practices <br />Assets of the City shall not be invested pursuant to the following investment <br />practices: <br />• Trading of securities strictly for speculation or solely for the realization of <br />short-term trading gains. <br />• A contract providing for the compensation of an agent or fiduciary solely <br />based upon the performance of the invested assets. <br />• If a fiduciary or other third party with custody of public investment <br />transaction records of the City fails to produce records within a reasonable <br />time, when requested by the City, the City shall make no new investments <br />with or through the fiduciary or third party and shall not renew maturing <br />investments with or through the fiduciary or third party. <br /> <br />10.0 INVESTMENT POOLS/MUTUAL FUNDS <br />The Executive Director for FMSA or his/her designee shall be required to investigate all <br />local government investment pools and money market mutual funds, other than the state <br />Local Agency Investment Fund (LAIF), prior to investing and perform at least a quarterly <br />review thereafter while the City is invested in the pool or the money market fund. <br /> <br />The City authorizes pooled investment fund deposits with LAIF, which is authorized under <br />provisions in Section 16429.1 of the California Government Code as an allowable <br />investment for local agencies, even though some of the individual investments of the pool <br />are not allowed as a direct investment by a local agency such as the City of Santa Ana. <br />The City also authorizes pooled investment fund deposits with California CLASS Prime <br />Fund, which is authorized under Section 6509.7 of the California Government Code as an <br />allowable investment for local agencies that have the authority to invest their treasury funds. <br /> <br />Government sponsored investment pools (Local Agency Investment Fund (LAIF), County <br />Pools, Joint Powers Authority Pools, and the State Treasury Voluntary Investment <br />Program Fund), are sources for short-term cash management. <br /> <br />Before seeking City Council approval for participation in one or more additional <br />investment pools/money market mutual funds, the Executive Director for FMSA or his/her <br />designees will conduct a thorough investigation the prospective pool prior to <br />recommending City investment. <br />Before recommending investing in a prospective pool, the following issues must be <br />reviewed: <br />A. The pool must meet the requirements of state statue. <br />B. The pool must provide a written statement of policy and objectives. <br />C. A questionnaire developed by FMSA investment staff and approved by the <br />Treasury and Customer Services Manager or Assistant Director of Finance