55B - RESO - ANNUAL STATEMENT OF INVESTMENT POLICY

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CITY OF SANTA ANA STATEMENT OF INVESTMENT POLICY JULY 2015 -2016 Page 6 2. Retained an investment adviser registered or exempt from registration with the Securities and Exchange Commission with not less than five (5) years experience investing in the securities and obligations authorized by subsection (a) to (k), inclusive, and subdivisions (m) to (o), inclusive, of Section 53601 of the Government Code and with assets under management in excess of five hundred million dollars ($500,000,000). The purchase price of shares of beneficial interest, (mutual funds) purchase pursuant to this subdivision shall not include any commission that these companies may charge. J. Ineligible investments. Investments not described herein are ineligible investments. The City shall not invest any funds in inverse floaters, range notes, or interest only strips that are derived from a pool of mortgages. In addition, the City shall not invest any funds in any security that could result in zero interest accrual if held to maturity. However, prohibited securities that are in the City's portfolio, as of the date of this policy adoption, may be held until their maturity dates. DEPOSITORY SERVICES Money must be deposited in state or national banks, state or federal savings associations or state or federal credit unions in the state. It may be in inactive deposits, active deposits or interest - bearing active deposits. The deposits cannot exceed the amount of the bank's or savings and loan's paid up capital and surplus. The bank or savings and loan must secure the active and inactive deposits with eligible securities having a market value of one hundred ten percent (110 %) of the total amount of the deposits. State law also allows as an eligible security, first trust deeds having a value of one hundred fifty percent (150 %) of the total amount of the deposits. A third class of collateral is letters of credit drawn on the Federal Home Loan Bank (FHLB). The Executive Director, Finance and Management Services / City Treasurer may waive, at his or her discretion, security for that portion of a deposit which is insured pursuant to federal law. Currently, the first two hundred fifty thousand dollars ($250,000) of a deposit is federally insured. It is to the City's advantage to waive this collateral requirement for the first $250,000 because we receive a higher interest rate. QUALIFIED DEALERS AND INSTITUTIONS: The City shall transact business only with banks, savings and loans and registered investment securities 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, who is a member of the Financial Industry Regulatory Authority (FINRA), or a member of a Federally regulated 55B -10