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CITY OF SANTA ANA STATEMENT OF INVESTMENT POLICY <br />JULY 2007-2008 <br />QUALIFIED DEALERS AND INSTITUTIONS: <br />The City shall transact business only with banks, savings and loans <br />and registered investment securities dealers. The purchase by the <br />City of any investment other than those purchased directly from the <br />issuer, shall be purchased either from an institution licensed by <br />the State as a broker-dealer, as defined in Section 25004 of the <br />Corporations Code, who is a member of the National Association of <br />Securities Dealers, or a member of a Federally regulated securities <br />exchange, a National or State-Chartered Bank, a Federal or State <br />Association (as defined by Section 5102 of the Financial Code), or a <br />brokerage firm designated as a Primary Government Dealer by the <br />Federal Reserve Bank. The City's Treasurer's staff shall <br />investigate all institutions which wish to do business with the <br />City, in order to determine if they are adequately capitalized, make <br />markets in securities appropriate to the City's needs, and agree to <br />abide by the conditions set forth in the City of Santa Ana's <br />Investment Policy and Investment Portfolio Guidelines. This will be <br />done annually by having the Financial Institutions complete and <br />return the appropriate questionnaire, and an audited Financial <br />Statement must be provided within one-hundred, twenty (120) days of <br />the Institution's fiscal year-end. <br />SAFEKEEPING OF SECURITIES: <br />To protect against potential losses caused by collapse of individual <br />securities dealers, all securities owned by the City except <br />securities used as collateral for repurchase agreements, shall be <br />kept in safekeeping with "perfected interest" by a third party bank <br />trust department, acting as agent for the City under the terms of a <br />custody agreement executed by the bank and by the City. All <br />securities will be received and delivered using standard delivery <br />versus payment procedures. <br />INTERNAL CONTROLS: <br />The Executive Director, Finance and Management Services is <br />responsible for establishing and maintaining an internal control <br />structure designed to ensure that the assets of the entity are <br />protected from loss, theft or misuse. The Executive Director, <br />Finance and Management Services has developed a system of internal <br />investment controls and a segregation of responsibilities of <br />investment functions in order to assure an adequate system of <br />internal control over the investment function. Internal control <br />procedures address wire controls, separation of duties, delivery of <br />securities to a third party for custodial safekeeping, and written <br />procedures for placing investment transactions. <br />Cash balances are reconciled daily by non-investment employees and <br />reconfirmed by the City's accounting staff. In addition, the City's <br />19E-10 <br />