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CITY OF SANTA ANA STATEMENT OF INVESTMENT POLICY <br />JULY 1, 2016 — JUNE 30, 2017 <br />Page 10 <br />SAFEKEEPING OF SECURITIES: <br />In accordance with California Government Code Section 53601, to protect against potential <br />losses caused by collapse of individual securities dealers, all securities owned by the City except <br />securities used as collateral for repurchase agreements, shall be kept in safekeeping with <br />"perfected interest" by the City's custodial bank or a third party bank trust department, acting as <br />agent for the City under the terms of a custody agreement executed by the bank and by the City. <br />All securities, excepting investments in the State Pool or money market mutual funds, will be <br />received and delivered using standard delivery versus payment. <br />INTERNAL CONTROLS: <br />The Executive Director for FMSA is responsible for establishing and maintaining an internal <br />control structure designed to ensure that the assets of the entity are protected from loss, theft or <br />misuse. The Executive Director for FMSA has developed a system of internal investment <br />controls and a segregation of responsibilities of investment functions in order to assure an <br />adequate system of internal control over the investment function. Internal control procedures <br />address wire controls, separation of duties, delivery of securities to a third party for custodial <br />safekeeping, and written procedures for placing investment transactions. Cash balances are <br />reconciled daily by non - investment employees and reconfirmed by the City's accounting staff. In <br />addition, the City's accounting staff also verifies investment activities and holdings on a monthly <br />basis. The Executive Director for FMSA, at his /her discretion, shall establish a process for <br />annual independent reviews by an external auditor to the extent contemplated by generally <br />accepted auditing standards. <br />REPORTING: <br />Government Code Section 53646 previously mandated that annual investment policies and <br />quarterly reports be rendered to the legislative body (for the City of Santa Ana - the City Council). <br />AB 2853 amended Government Code Section 53646 making these requirements permissive <br />rather than mandatory. Although the Annual Investment Policy and Quarterly Reports to City <br />Council are no longer required, we believe it to be both prudent and in keeping with the spirit of <br />the City's Sunshine Policy that these documents continue to provided. The Executive Director <br />for FMSA shall therefore continue to render to the City Council a statement of investment policy <br />and a report to the City Council and City Manager containing detailed information on all <br />securities, investments, and moneys of the City. The report will be submitted on at least a <br />quarterly basis and provided to the Council within thirty (30) days following the end of the <br />quarter. <br />55C -20 <br />