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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 />9.4 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 />10.0 INVESTMENT POOLS/MUTUAL FUNDS <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 />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 and considered: <br />The pool must meet the requirements of state statue description of <br />eligible investment securities, and a written statement of investment <br />policy and objectives. <br />A description of interest calculations and how it is distributed, and how <br />gains and losses are treated. <br />i. A description of how the securities are safeguarded (including the <br />settlement processes), and how often the securities are priced and the <br />program audited. <br />ii. A description of who may invest in the program, size and frequency of <br />minimum and maximum deposits, how many withdrawal transactions <br />are allowed (daily, monthly, quarter, annually, etc.), and whether <br />advance notice is required for withdrawal transactions. <br />iii. A description of how and who in the governing body of the program is <br />Citv of Santa - Annual Page 14 �- <br />Statement of Investment Policy June 30,2025 <br />