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segregation of responsibilities for investment functions to ensure adequate <br /> internal control over these functions. No investment personnel may <br /> engage in an investment transaction except as provided under this policy <br /> and the procedure established by the Executive Director for FMSA. <br /> Internal control procedures address: <br /> • Control of collusion <br /> • Control of fraud <br /> • Control of misrepresentation by third parties <br /> • Control of employee error <br /> • Separation of transaction authority from accounting and record <br /> keeping <br /> • Custodial safekeeping <br /> • Delivery versus payment <br /> • Clear delegation of authority <br /> • Confirmation of transactions for investment and wire transfers <br /> • Written procedures for placing investment transactions <br /> • FMSA Investment Advisory Committee <br /> In addition, cash balances are reconciled daily by non-investment <br /> employees and reconfirmed by the City's accounting staff. Accounting staff <br /> also regularly verify investment activities and holdings, and the FMSA <br /> Investment Advisory Committee reviews them. The Executive Director for <br /> FMSA, at his/her discretion, shall establish a process for annual <br /> independent reviews by an external auditor, to the extent contemplated <br /> by generally accepted auditing standards, as part of the City's annual <br /> audit. <br /> 15.0 REPORTING <br /> Government Code Section 53646(b)(1) previously mandated that annual <br /> investment policies and quarterly reports be rendered to the legislative body <br /> (for the City of Santa Ana, the City Council). AB 2853 amended <br /> Government Code Section 53646, making these requirements permissive <br /> rather than mandatory. Although the Annual Statement of Investment <br /> Policy and Quarterly Reports to the City Council are no longer required, we <br /> believe it is both prudent and consistent with the spirit of the City's Sunshine <br /> Policy to continue providing these documents. The Executive Director for <br /> FMSA shall therefore continue to render to the City Council an annual <br /> Statement of Investment Policy and to the City Manager and the City <br /> City of Santa-Annual Page 19 July 1. 2026 - <br /> Statement of Investment Policy June 30,2027 <br />