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five years or less. Purchase of securities authorized by this subdivision shall not <br />exceed 10 percent of the agency's surplus moneys that may be invested pursuant to <br />this section. <br />N. Shares of beneficial interest otherwise known as money market shares issued by <br />diversified management companies that are money market funds registered with <br />the Securities and Exchange Commission under the Investment Company Act of <br />1940. The company shall have met either of the following criteria: <br />1. Attain the highest ranking or the highest letter and numerical rating provided <br />by not less than two NRSROs, and <br />2. Retained an investment adviser registered or exempt from registration with <br />the Securities and Exchange Commission with not less than five (5) years' <br />experience investing in the securities and obligations authorized by <br />subsection (a) to (k), inclusive, and subdivisions (m) to (o), inclusive, of <br />Section 53601 of the Government Code and with assets under management <br />in excess of five -hundred, million dollars ($500,000,000). The purchase price of <br />shares of beneficial interest, (mutual funds) purchased pursuant to this <br />subdivision shall not include any commission that these companies may <br />charge. <br />Investments in this category shall be restricted to money market mutual funds <br />that seek to maintain a Net Asset Value of $1. Money market mutual funds <br />provide daily liquidity; therefore, there is no final stated maturity for this <br />investment category. Investments in mutual funds shall be restricted to funds <br />that have the highest ranking or the highest letter and numerical rating <br />provided by not less than two of the following nationally recognized statistical <br />rating organizations: Moody's, Standard & Poor's or Fitch. Purchases in this <br />category shall not exceed 20% of the book value of the investment portfolio. <br />Purchases in a single mutual fund shall not exceed 10% of the book value of <br />the Portfolio. <br />8.3 Suitability of Investments <br />Suitability, not simply return, is the standard for selecting investments for the portfolio. <br />The Executive Director for FMSA, and all authorized Investment Officials and other <br />supporting FMSA investment staff shall review the following when selecting or <br />recommending investments for the City: <br />• Sufficient liquidity to meet current obligations <br />• Appropriate level of market risk <br />• Diversified portfolio <br />• Legal investments <br />• Market rate of return <br />City of Santa - Annual Page 12 July 1.2024 - <br />Statement of Investment Policy June 30, 2025 <br />