Item 24 - Annual Statement of Investment Policy

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City of Santa - Annual Page 8 July 1, 2021 - Statement of Investment Policy June 30, 2022 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. 7.3 Selection Process - City of Santa Ana Broker-Dealer Questionnaire The City’s FMSA investment staff shall investigate all institutions which wish to do business with the City as a Qualified City of Santa Ana Broker-Dealer, in order to determine if they are adequately capitalized, make markets in securities appropriate to the City's needs, certify having read and understood the City of Santa Ana Annual Statement of Investment Policy and agreeing to abide by the conditions set forth therein. This will be done by having the Financial Institutions complete and return the appropriate City of Santa Ana Broker-Dealer Questionnaire, along with their most current FINRA Report and Audited Financial Statement (available within one- hundred, twenty (120) days of the Institution's fiscal year-end). Audited Financial Statements may be made available online. Financial Institutions currently certified as Qualified City of Santa Ana Broker-Dealers shall complete and return the appropriate City of Santa Ana Broker-Dealer Questionnaire bi-annually, but shall be subject to the Audited Financial Statement and FINRA annual reporting requirements annually. However, if the interaction with a currently certified Qualified City of Santa Ana Broker-Dealer is limited to investment trades through an electronic trading platform, then the Broker-Dealer is exempt from completion of a questionnaire, but shall remain subject to the Audited Financial Statement and FINRA reporting requirements annually. 7.4 Selection Criteria In selecting external Broker-Dealers, past performance, stability, financial strength, reputation, area of expertise, and willingness and ability to provide the highest investment return at the lowest cost to the City within the parameters of this Investment policy and the California Government Code shall be primary considerations. FMSA investment staff will only conduct business with registered representatives of broker-dealers that have a minimum of three (3) years continuous