55C - RESO - STATEMENT OF INVESTMENT

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CITY OF SANTA ANA STATEMENT OF INVESTMENT POLICY JULY 1, 2016 — JUNE 30, 2017 Page 9 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 and registered with Financial Industry Regulatory Authority ( FINRA), or a member of a Federally regulated securities exchange, a National or State - Chartered Bank, a Federal or State Association (as defined by Section 5102 of the Financial Code), or a brokerage firm designated as a Primary Government Dealer by the Federal Reserve Bank, and who is registered with FINRA. The City's investment staff shall investigate all institutions which wish to do business with the City as a Qualified City of Santa Ana Broker - Dealer, in order to determine if they are adequately capitalized, make markets in securities appropriate to the City's needs, and agree to abide by the conditions set forth in the City of Santa Ana Annual Statement of Investment Policy. This will be done by having the Financial Institutions complete and return the appropriate City of Santa Ana Broker - Dealer Questionnaire, along with their most current FINRA Report and Audited Financial Statement (available within one - hundred, twenty (120) days of the Institution's fiscal year -end). The Treasury and Customer Services Manager shall maintain a list of Financial Institutions authorized to provide investment services to the City, along with their FINRA Report. Financial Institutions previously certified as Qualified City of Santa Ana Broker - Dealers shall complete and return the appropriate City of Santa Ana Broker - Dealer Questionnaire bi- annually, but shall be subject to the Audited Financial Statement and FINRA annual reporting requirements. However, if the interaction with the Broker - Dealer is limited to investment trades through an electronic trading platform, then the Broker - Dealer is exempt from completion of a questionnaire. In selecting external Broker - Dealers, past performance, stability, financial strength, reputation, area of expertise, and willingness and ability to provide the highest investment return at the lowest cost to the City within the parameters of this Investment Policy and the California Government Code shall be primary considerations. Investment staff will only conduct business with registered representatives of broker - dealers that have a minimum of three (3) years continuous experience working for a primary dealer or five (5) years continuous experience working for a non - primary dealer. Investment staff will only purchase or sell securities from registered representatives that possess an active Series 7 license, an active Series 66 license, or an active Series 63 license, and who submit a FINRA form U4 (employment history) and a current FINRA form U5 Disclosure Statement and have completed the City's Broker - Dealer questionnaire. 55C -19