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HomeMy WebLinkAboutItem 17 - Annual Statement of Investment Policy Finance and Management Services www.santa-ana.org/finance Item # 17 City of Santa Ana 20 Civic Center Plaza, Santa Ana, CA 92701 Staff Report June 16, 2026 TOPIC: Annual Statement of Investment Policy AGENDA TITLE Resolution Approving the City's Annual Statement of Investment Policy 2026-2027; Annual Statement of Investment Policy 2026-2027 RECOMMENDED ACTION 1. Adopt a Resolution approving the City's 2026-2027 Investment Policy. RESOLUTION NO. 2026-XXX entitled A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA ANA APPROVING THE CITY'S STATEMENT OF INVESTMENT POLICY 2026-2027 2. Receive and file the Annual Statement of Investment Policy 2026-2027. GOVERNMENT CODE 484308 APPLIES: No DISCUSSION In accordance with State law, the Finance and Management Services Agency submits a resolution annually approving the City's Investment Policy (Exhibit 1) and the Annual Statement of Investment (Exhibit 2). The investment policy outlines the following primary goals: • Comply with all Federal, State, and local laws governing the investment of public funds; • Ensure the safety and preservation of principal; • Maintain sufficient liquidity to meet operational cash flow needs; and • Achieve a reasonable rate of return within the parameters of the Investment Policy and investment portfolio guidelines. The Investment Policy covers all City financial assets, except individual employee retirement funds and deferred compensation. These plans are excluded because they are not part of the City's operating cash or pooled treasury investments. Instead, these assets are held for the benefit of plan participants and are subject to separate fiduciary, legal, and administrative requirements. Annual Statement of Investment Policy June 16, 2026 Page 2 Finance staff reviews the City's policy annually to ensure compliance with applicable laws, industry standards, and best practices. This review evaluates whether new state statutes or regulations should be adopted or whether operational improvements are advisable. The current policy was reviewed and certified by the California Municipal Treasurers Association (CMTA). CMTA re-certification was granted on May 31, 2022. CMTA recommends that policies be reviewed annually and recertified every three to five years, absent significant legislative changes, shifts in industry standards, or major revisions to the policy. The City is scheduled to undergo its next policy recertification review in 2027, in preparation for the 2027-28 fiscal year. Only minor revisions are proposed for FY2026- 27, including: • Reorganization of the Delegation of Authority provisions in Section 5.2 to improve clarity and eliminate duplicative language without changing policy intent. • Streamlining of Section 12.1, Safekeeping and Custody, without modifying any substantive requirements. All remaining revisions are organizational, grammatical, or formatting improvements that do not materially alter the City's investment objectives, controls, or reporting requirements. According to the Local Agency Investment Guidelines published annually by the California Debt and Investment Advisory Commission (CDIAC), there are no federal or regulatory changes affecting the City's investment practices for FY2026-27. ENVIRONMENTAL IMPACT There is no environmental impact associated with this action. FISCAL IMPACT There is no fiscal impact associated with this action. EXHIBIT(S) 1. Resolution 2. Annual Statement of Investment Policy Submitted By: Alexander Trinidad, Executive Director, Finance and Management Services Approved By: Alvaro Nunez, City Manager EXHIBIT 1 RESOLUTION NO. 2026-XX A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA ANA APPROVING THE CITY'S STATEMENT OF INVESTMENT POLICY 2026-2027 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTA ANA AS FOLLOWS: Section 1. The City Council of Santa Ana hereby finds, determines and declares as follows: A. California Government Code §53646, provides that each city may have a written statement of investment policy to govern investment of the City's monies. B. Pursuant to §53646, the City Treasurer shall annually submit a Statement of Investment Policy for City Council consideration. C. The City Treasurer has submitted the attached Statement of Investment Policy to this Council at its regular meeting of June 16, 2026, for its consideration. Section 2. The City Council of the City of Santa Ana has duly considered and approves the City's Statement of Investment Policy submitted by the City Treasurer. Section 3. The City Treasurer shall submit quarterly reports to the City Council stating all investments made in the preceding quarter and that such investments have been made in conformance with the City's investment policy. Section 4. This Resolution shall take effect immediately upon its adoption by the City Council, and the City Clerk shall attest to and certify the vote adopting this Resolution. ADOPTED this day of 12026. Valerie Amezcua Mayor Resolution No. 2026-XX Page 1 of 2 APPROVED AS TO FORM: Sonia Carvalho, City Attorney By: Jonathan T. Martinez Assistant City Attorney AYES: Councilmembers: NOES: Councilmembers: ABSTAIN: Councilmembers: NOT PRESENT: Councilmembers: CERTIFICATION OF ATTESTATION AND ORIGINALITY I, JENNIFER L. HALL, City Clerk, do hereby attest to and certify the attached Resolution No. to be the original resolution adopted by the City Council of the City of Santa Ana on , 2026. Date: Jennifer L. Hall, City Clerk City of Santa Ana Resolution No. 2026-XX Page 2 of 2 EXHIBIT 2 tiNA • � e+13. J U N E 16 202#- ov SAN7,4 � 9 � �� ;IIIlir INVESTMENT POLICY STATEMENT 2026=27 TABLE OF CONTENTS Page Contents CITYOF SANTA ANA..............................................................................................................................1 1.0 POLICY.........................................................................................................................................1 2.0 SCOPE .........................................................................................................................................1 3.0 PRUDENCE..................................................................................................................................2 4.0 OBJECTIVES................................................................................................................................3 5.0 DELGATION OF AUTHORITY........................................................................................................6 6.0 ETHICS AND CONFLICTS OF INTEREST ...................................................................................7 7.0 AUTHORIZED FINANCIAL INSTITUTIONS AND QUALIFIED BROKER-DEALERS.........................8 8.0 AUTHORIZED AND SUITABLE INVESTMENTS.............................................................................8 9.0 PROHIBITED INVESTMENTS AND INVESTMENT PRACTICES................................................15 10.0 INVESTMENT POOLS/MUTUAL FUNDS....................................................................................16 11.0 COLLATERAL IZATION/SECURITY FOR DEPOSIT OF PUBLIC FUNDS ......................................17 12.0 SAFEKEEPING AND CUSTODY..................................................................................................17 13.0 DIVERSIFICATION .....................................................................................................................18 14.0 INTERNAL CONTROLS ..............................................................................................................18 15.0 REPORTING...............................................................................................................................19 16.0 POLICY CONSIDERATIONS ......................................................................................................20 17.0 POLICY REVIEW, CERTIFICATION, AND ADOPTION.................................................................21 CITY OF SANTA ANA ANNUAL STATEMENT OF INVESTMENT POLICY JULY 1, 2026—JUNE 30, 2027 INTRODUCTION: The purpose of this Statement of Investment Policy is to provide specific criteria for the prudent investment of City of Santa Ana (City) funds and to set investment objectives, policies, establish guidelines, and define responsibilities for the investment of idle or unexpended funds for the City. The ultimate investment goal is to enhance the City's economic status while protecting the funds under management and meeting the City's daily cash flow demands. 1.0 POLICY The policy of the City of Santa Ana is to invest idle or unexpended funds within the scope of this investment policy prudently and suitably, so that it will provide, within the parameters of this investment policy, the highest reasonable investment return relative to the risk being assumed while maintaining maximum security and meeting all cash flow demands. This policy is intended to comply with Federal law and the California Code regarding the investment of public funds. In instances where this policy is more restrictive than Federal or State law, this policy shall control. This policy is fixed and general in nature; it defines authorized investments and guides the investment decisions and security selection process. The City's Investment Policy will be regularly reviewed and adjusted to create an investment portfolio suitable for the City under current conditions. 2.0 SCOPE 2.1 Applicability of Investment Policy This investment policy applies to all funds and investment transactions of the City. These funds are accounted for in the Annual Comprehensive Financial Report (ACFR), which includes the following: • General Fund • Special Revenue Funds • Capital Projects Funds (includes restricted bond proceeds) • Enterprise Funds (includes restricted bond proceeds) • Trust and Agency Funds • Internal Service Funds • Any new fund created by the City of Santa Ana, unless specifically exempted City of Santa-Annual Page 1 July 1. 2026 - Statement of Investment Policy June 30,2027 The restricted bond proceeds are invested in compliance with this investment policy and applicable bond resolutions. Individual employee retirement contribution funds and deferred compensation are excluded from this policy. 2.2 Pooling of Funds Except for cash in certain restricted and special funds, the City of Santa Ana will consolidate cash balances from all funds to maximize investment earnings and increase efficiency in investment pricing, safekeeping, and administration. Investment income will be allocated to the various funds based on their respective participation and in accordance with generally accepted accounting principles. 3.0 PRUDENCE 3.1 Standard of Care— Prudent Investor The City investment program shall be managed professionally and prudently, worthy of the public trust and review. The standard of prudence to be used by City Investment Officials shall be the "prudent investor rule" standard. It shall be applied in the context of managing the overall investment portfolio. The "prudent investor rule," pursuant to California Government Code Section 53600.3, provides that investments shall be made with judgment and care. When investing, reinvesting, or managing public funds, a trustee shall act with care, skill, prudence, and diligence under the circumstances then prevailing. Investment officers acting in accordance with written procedures and this investment policy, and exercising due diligence, shall be relieved of personal responsibility for an individual security's credit risk or market price changes, provided that deviations from exceptions are reported in a timely fashion and that the liquidity and the sale of securities are carried out in accordance with the terms of this policy. The California Government Code governs the City, Sections 16429.1 and Title 5, Division 2, Part 1, Chapter 4, entitled Financial Affairs, commencing with section 53630. Each investment transaction and the entire portfolio must comply with California Government Code, Sections 53600 and 53635 et seq., and this policy. 3.2 Written Investment Procedures City Investment Officials shall establish written procedures, consistent with this investment policy, for the operation of the investment program. Procedures should include, but not be limited to: authorized personnel, segregation of duties, internal controls, wire transfer City of Santa-Annual Page 2 July 1. 2026 - Statement of Investment Policy June 30,2027 agreements, daily cash flow review, basis for awarding bids, portfolio inventory, and reporting. The procedures document is intended to provide guidance for staff and to ensure continuity in the event of an interruption to the services of the Treasury and Customer Services Manager and/or Assistant Finance Director. 4.0 OBJECTIVES The primary objectives, in priority order, for the City of Santa Ana's investment activities shall be Safety, Liquidity, and Yield: 4.1 Safety of Principal Safety of principal is the foremost objective of the City of Santa Ana; care must be taken to ensure the preservation of capital and the protection of principal. Each investment transaction shall be undertaken to ensure the preservation of capital in the overall portfolio. The objective is to mitigate credit and interest rate risk by following the guidelines below. A. Credit Risk Credit Risk is the risk of loss arising from the failure of the security's issuer or backer to redeem the outstanding debt on the stated maturity date. Credit risk also encompasses the overall market perception of the issuer's financial strength and capacity. The City of Santa Ana will minimize credit risk by: i. Limiting investments to authorized investments as set forth in Section 8 of this investment policy; ii. Pre-qualifying the financial institutions, broker- dealers, intermediaries, and advisors with which the City will do business; iii. Diversifying the investment portfolio so that potential losses on individual securities will be minimized. iv. Holding a minimum percentage of the total portfolio in highly marketable short-term treasuries, checking with interest, government pooled account, or a combination of all three. The minimum percentage shall be set monthly by the FMSA Investment Advisory Committee based on a rolling twenty-four-month analysis of the City's minimum cash position requirements adjusted for any exceptional anticipated cash City of Santa-Annual Page 3 July 1. 2026 - Statement of Investment Policy June 30,2027 outflows. B. Market or Interest Rate Risk Market or interest rate risk is the risk that the market value of securities in the portfolio may fall due to changes in general interest rates. The City of Santa Ana will minimize interest market interest rates by: i. Structuring the investment portfolio so that securities mature to meet cash requirements for ongoing operations, thereby avoiding the need to sell securities on the open market priorto maturity, and ii. By investing operating funds primarily in shorter-term securities, money market mutual funds, or similar investment pools and limiting the average maturity of the portfolio to 3 years using the securities' stated final maturities. 4.2 Liquidity The investment portfolio shall remain sufficiently liquid to meet all reasonably anticipated operating requirements. This is accomplished by structuring the portfolio so that securities mature in concert with cash needs, meeting anticipated demands (static liquidity). Furthermore, since all possible cash demands cannot be anticipated, the portfolio should consist largely of securities with active secondary or resale markets (dynamic liquidity). The City's cash flow shall be updated daily and considered before investing in securities, thereby reducing the need to sell investments for liquidity. 4.3 Yield (Return on Investment) The City's investment portfolio shall be designed to achieve a market-average rate of return across budgetary and economic cycles, while accounting for investment risk constraints and liquidity needs. Investment return is to be accorded secondary importance compared to the safety and liquidity objectives described above.The core of the investment portfolio will focus on relatively low-risk securities, with the expectation of earning a reasonable return commensurate with the risk assumed. It is the City's general policy to hold investments until their market value equals or exceeds the security's amortized cost or book value. Securities shall not be sold prior to maturity, except as follows: City of Santa-Annual Page 4 July 1. 2026 - Statement of Investment Policy June 30,2027 A. a declining credit security could be sold early to minimize loss of principal; B. a simultaneous purchase of a security and the sale of another(security swap) to enhance the quality, yield, or target duration in the portfolio; or C. a sale of a specific security prior to its maturity and a capital gain or loss recorded to improve the credit quality, liquidity, or rate of return of the portfolio in response to market conditions and/or City risk preferences; D. general liquidity needs of the investment portfolio require that a security be sold; E. prepayment of City debt or contribution servicing obligation. In the event the City is presented with an option to prepay a City debt or contribution servicing obligation, the following analysis will be conducted to compare the amortized savings that may be realized by exercising such prepayment option and: i. the current portfolio yield; ii. the trend of the debt or contribution servicing obligation; iii. whether variances in the trend are substantial; iv. the City's net cash position; and V. the market value of investment instrument(s) recommended by staff to be liquidated to fulfill a prepayment election. When selling a security before maturity, City Investment Officials and/or officers (see generally subsection 5.1 et seq. - Investment Authority and Responsibility) must be prepared to justify the reasons and explain any gains or losses. Compliance with the investment policy does not measure return but rather manages risk. Policy compliance does not provide a benchmark to meet or exceed, but serves as a model to follow. The City will benchmark its investment performance against an agreed-upon Treasury index. The City shall strive to maintain one hundred percent (100%) of idle funds invested after consideration of a City of Santa-Annual Page 5 July 1. 2026 - Statement of Investment Policy June 30,2027 compensating balance to cover the cost of services provided by the City's depository bank. Daily cash flow projections determine the funds available for investment. Investments are monitored to ensure that legal limits on investment types are not exceeded. 5.0 DELGATION OF AUTHORITY 5.1 Investment Authority and Responsibility The authority to conduct investment transactions rests with the Executive Director of the Finance and Management Services Agency (FMSA), who serves as the chief fiscal officer and City Treasurer. The Executive Director for(FMSA), under the general direction of the City Council, shall be responsible for all investment transactions undertaken and shall establish a system of controls to regulate the investment activities of subordinate officials. 5.2 Delegation of Authority The Executive Director for FMSA, or their designee, shall invest all funds for the City in accordance with the City's adopted investment policy. The Executive Director for FMSA hereby delegates day-to-day responsibility for the investment of City funds to the FMSA Financial Analyst. Managerial and supervisory responsibility for the investment of City funds may be held by either the Assistant Director of Finance and Management Services (Assistant Director) or the Treasury and Customer Services Manager (Treasury Manager). Each designee shall act in accordance with the established policies and internal controls set forth in the investment policy. The Executive Director may engage external investment management advisors to assist in managing the City's investment portfolio in a manner consistent with the City's objectives. Such advisors may be granted discretion to purchase and sell investment securities in accordance with the Policy. Such advisors must be registered with the Securities and Exchange Commission and possess experience in public funds investment management. Such engagement and/or delegation by the Executive Director shall not remove or diminish her/his investment responsibility. 5.3 Assignment of Activities Supporting and ancillary activities, including but not limited to: cash flow analysis, municipal or corporate bond credit worthiness evaluation, investment risk assessment, portfolio analysis, purchase and sale recommendation, safekeeping, policy and investment procedures review recommendation, and monthly and City of Santa-Annual Page 6 July 1. 2026 - Statement of Investment Policy June 30,2027 quarterly reporting, may be assigned to qualified persons within Treasury or within the FMSA Accounting or Administrative Services divisions as deemed appropriate by either the Director and/or Assistant Finance Director. 5.4 Qualified Persons Qualified Persons shall refer to: (1) persons holding either a California Municipal Treasurers Association, California Treasury Certificate and/or Certified California Municipal Treasurer Certificate; or an Association of Public Treasurers of the United States and Canada, Certified Public Finance Administrator Certificate, or a National Association of State Treasurers Certificate in Public Treasury Management; or (2) persons who are performing investment related duties under the guidance and direction of certificate holders. Working together, Investment Officials and Qualified Persons comprise the FMSA investment staff. 5.5 FMSA Investment Advisory Committee To provide a regular departmental forum and consultative body for evaluating investment portfolio performance and strategy, internal procedures and controls, and making recommendations to the Executive Director of FMSA, in their capacity as chief fiscal officer and City Treasurer, an FMSA Investment Advisory Committee is established. All authorized Investment Officials are de facto standing members of the FMSA Investment Advisory Committee. At the discretion of the Executive Director for FMSA, other FMSA investment staff may be authorized to serve on the committee. Meetings shall be held regularly, with the frequency determined by the Executive Director for FMSA. The FMSA Investment Advisory Committee's evaluations and recommendations are subject to approval by the Executive Director of FMSA, who serves as the committee chair. 6.0 ETHICS AND CONFLICTS OF INTEREST 6.1 Investment Officials and Officers Investment Officials, officers, and employees involved in the investment process shall refrain from personal business activities that could conflict with the proper execution and management of the investment program or impair their ability to make impartial decisions. Investment Officials, officers, and employees shall disclose any material interests in financial institutions with which they conduct business. They shall further disclose any personal financial or investment positions that could relate to the performance of the City of Santa-Annual Page 7 July 1. 2026 - Statement of Investment Policy June 30,2027 investment portfolio. Investment Officials, officers, and employees shall refrain from engaging in personal investment transactions with the same individual with whom they conduct business on behalf of the City of Santa Ana. 6.2 Statement of Economic Interests Investment Officials and officers authorized to approve investment decisions shall submit an annual Statement of Economic Interests, also known as Form 700, in accordance with California Government Code Section 1090 et seq. The Form 700 provides transparency and ensures accountability in two ways: 1) It provides necessary information to the public about officials' and officers' personal financial interests to ensure that officials and officers are making decisions in the best interest of the public and not enhancing their personal finances. 2) It serves as a reminder to the public official of potential conflicts of interest so the official or officer can abstain from making or participating in governmental decisions that are deemed conflicts of interest. 7.0 AUTHORIZED FINANCIAL INSTITUTIONS AND QUALIFIED BROKER- DEALERS 7.1 If the City utilizes a SEC registered external investment advisor, the advisor shall maintain a list of authorized broker-dealers and complete the appropriate due diligence required by the SEC. The external investment advisor may use its own list of approved broker/dealers and financial institutions for investment purposes on behalf of the City. The investment advisor shall submit the list of approved broker-dealers to the City's FMSA investment staff annually. The Executive Finance Director may restrict the use of a broker/dealer which may be deemed unsuitable. 8.0 AUTHORIZED AND SUITABLE INVESTMENTS 8.1 Allowable Investment Instruments—State Law California Government Code Section 53601 establishes allowable investment instruments for all local agencies, along with maximum maturities, maximum specified percentages of the total portfolio, and minimum quality requirements. Section 53601.1 authorizes local agencies to invest in financial futures or financial option contracts in any of the allowable investment categories enumerated in section 53601. The City may invest in any of the investments City of Santa-Annual Page 8 July 1. 2026 - Statement of Investment Policy June 30,2027 described in the table in Figure 1. Where the table does not specify a limitation on the term or remaining maturity at the time of the investment, no investment shall be made in any security, other than a security underlying a repurchase or reverse repurchase agreement or securities lending agreement authorized by this section, that at the time of the investment has a term remaining to maturity in excess of five years, unless the legislative body has granted express authority to make that investment either specifically or as a part of an investment program approved by the legislative body no less than three months prior to the investment. 8.2 Authorized Investments The City of Santa Ana further restricts permitted investments to those listed below, and, where applicable, the Investment Advisory Committee may reduce the maximum specified percentages of the total portfolio (concentration limits)and may increase minimum quality requirements. Within this scope, the City diversifies its investments by investment type, maturity dates, concentration limits, and quality requirements. A. United States Treasury Bills, Notes, and Bonds for which the full faith and credit of the United States is pledged for payment of principal and interest. Purchases of this Category shall not have maturities exceeding 5 years.There is no percentage limit in this category. B. Obligations issued by a Federal Agency or a United States Government-Sponsored Enterprise. Federal Agency issues include, but are not limited to, GNMA (Government National Mortgage Association), FFCB (Federal Farm Credit Bank), FHLB (Federal Home Loan Bank), FHLMC (Federal Home Loan Mortgage Corporation), FNMA (Federal National Mortgage Association), FHA(Federal Housing Administration), and TVA (Tennessee Valley Authority). Although there is no percentage limitation on these issues, purchases in this category shall not have more than 5 years to maturity, and the "prudent investor"shall apply to a single agency name, as U.S. Government backing is implied rather than guaranteed. C. Supranational Obligations in United States dollar-denominated senior unsecured, unsubordinated obligations issued or unconditionally guaranteed by the International Bank for Reconstruction and Development, International Finance Corporation, or Inter-American Development Bank, with a maximum remaining maturity of five years or less, and eligible for purchase or sale within the United States. Investments under this subdivision shall be rated "AA" or better by a Nationally Recognized Statistical Rating Organization City of Santa-Annual Page 9 July 1. 2026 - Statement of Investment Policy June 30,2027 (NRSRO). They shall not exceed thirty percent (30%) of the cost value of the investment portfolio. D. Bills of exchange or time drafts drawn on and accepted by a commercial bank, otherwise known as banker's acceptances, which are eligible for purchase by the Federal Reserve System. Purchases of banker's acceptances may not exceed one hundred eighty (180) days or forty percent (40%) of the cost value of the Fund, which may be invested pursuant to this section. However, no more than thirty percent (30%) of the City's cost value of the investment portfolio may be invested in the banker's acceptances of any one commercial bank pursuant to this section. E. Commercial paper of"prime"quality of the highest ranking or of the highest letter and number rating as provided for by an NRSRO. The entity that issues the commercial paper shall be organized and operating within the United States, as a general corporation, shall have total assets in excess of five hundred million dollars ($500,000,000), and have debt other than commercial paper, if any, that is rated "A" or higher by NRSRO. The entity is organized within the United States as a special purpose corporation, trust, or limited liability company; has program wide credit enhancements including, but not limited to: over-collateralization, letters of credit, or a surety bond; has commercial paper that is rated "A-V or higher, or the equivalent, by an NRSRO Eligible commercial paper shall have a maximum maturity of two hundred seventy (397) days or less. The City may purchase no more than ten percent (10%) of the outstanding commercial paper of any single corporate issue. Purchases of commercial paper may not exceed twenty-five percent (40%) of the investment portfolio. F. Repurchase Agreements. For purposes of this section, the term "repurchase agreement" means a purchase of securities by the local agency pursuant to an agreement by which the seller will repurchase the securities on or before a specified date and for a specified amount and will deliver the underlying securities to a third-party custodian. The City may invest in repurchase agreements with primary dealers of the Federal Reserve with which the City has entered into a Securities Industry and Financial Markets Association (SIFMA) Master Repurchase Agreement (MRA), which specifies terms and conditions of repurchase agreements. The market value of securities used as collateral for repurchase agreements shall not be allowed to fall below one hundred two percent (102%) of the value of the City of Santa-Annual Page 10 July 1. 2026 - Statement of Investment Policy June 30,2027 repurchase agreement. It shall be adjusted at least quarterly by the tri-party custodial agent. The investments in repurchase agreements shall comply if the underlying securities are brought back up to one hundred two percent (102%) no later than the next business day. The underlying collateral shall be limited to United States Government Treasury Bills, Notes, and Bonds, or obligations issued by a Federal Agency or United States Government-sponsored enterprises obligations. Upon the written approval of the Executive Director for FMSA, substituted securities may be pledged as collateral. They shall consist only of investments permitted under this investment policy, with a maximum maturity of five (5)years. If the broker defaults, the collateral securities can be sold. Since the securities are valued daily, the sale proceeds are likely to equal or exceed the repurchase agreement amount. Purchases in this category shall not exceed one (1) year or twenty percent (20%) of the cost value of the investment portfolio. Retail repurchase agreements and reverse agreements shall not be authorized for purchase G. Negotiable certificates of deposit issued by a nationally or state-chartered bank, a savings association or a federal association (as defined by Section 5102 of the Financial Code), a state or federal credit union, or by a state-licensed branch of a foreign bank. However, the City shall not invest in negotiable certificates of deposit issued by a state or federal credit union if a member of the City Council or any City personnel with investment decision making authority also serves on the board of directors, or any committee appointed by the board of directors, or the credit committee or the supervisory committee of the state or federal credit union issuing the negotiable certificates of deposit. Effective January 1, 2026, the maximum percentage of the portfolio shall revert to thirty percent (30%). Investments made pursuant to Government Code Section 53635.8 remain subject to a maximum of thirty percent (30%) of the cost value of the investment portfolio. The amounts so invested shall be subject to the limitations of Government Code Section 53638, which generally provides that the deposit shall not exceed the shareholder's equity of any depository bank, or the total net worth of any depository savings association or federal association, or the total of the unimpaired capital and surplus of an insured industrial loan company. Purchases in this category shall not have more than five (5) years to maturity. City of Santa-Annual Page 11 July 1. 2026 - Statement of Investment Policy June 30,2027 H. Local Agency Investment Fund - State Pool. The City may invest in the Local Agency Investment Fund (LAIF) established by the State Treasurer under California Government Code Section 16429.1 for the benefit of local agencies. LAIF provides daily liquidity; therefore, there is no final stated maturity for this investment category. Although there is no percentage limitation on this fund, the "prudent investor" rule shall apply for a single agency name. In keeping with LAIF deposit-limit investments, City LAIF investments shall not exceed $75 million per active account, unless the State Treasurer authorizes a higher deposit limit for regular accounts during the term of this Statement of Investment Policy, in which case City LAIF investments may increase to that limit. I. California Cooperative Liquid Assets Securities System (CLASS) Prime Fund—Joint Powers of Authority Pool. The City may invest in the California CLASS Prime Fund established by a joint exercise of powers entity authorized under California Government Code Section 6509.7 for the benefit of all public agencies in the State of California that have authority to invest their treasury funds. The California CLASS Prime Fund provides daily liquidity; therefore, there is no final stated maturity for this investment category. Although there is no percentage limitation on this fund, the "prudent investor" rule shall apply for a single agency name. The California CLASS Prime Fund does not limit a maximum or minimum investment balance; therefore, its investments may increase or decrease based on pool performance, daily cash flow needs, etc. J. Municipal Bonds. The City may invest in notes or bonds of any of the fifty(50)states, as well as the debt of any local agency within the State of California. Notes, warrants, or other evidence of indebtedness of any local agency within this state, including bonds payable solely from the revenues of a revenue- producing property owned, controlled, or operated by the local agency, or by a department, board, agency, or authority of the local agency. Investments in this category shall be restricted to instruments that have a rating of "A" or higher, or the equivalent, by at least one of the following nationally recognized statistical rating organizations: Moody's, Standard & Poor's, or Fitch. Purchases in this category shall not have more than five (5) years to maturity. There is no percentage limit in this category. City of Santa-Annual Page 12 July 1. 2026 - Statement of Investment Policy June 30,2027 K. Medium Term Corporate Notes (MTN) are defined as all corporate and depository institution debt securities with a maximum remaining maturity of five years or less, issued by corporations organized and operating within the United States or by depository institutions licensed by the United States or any state and operating within the United States. Notes eligible for investment shall be rated in a rating category of "A" or higher by a nationally recognized rating service. Purchases in this category shall not exceed five (5) years to maturity or thirty percent (30%) of the cost value of the investment portfolio. Purchases in a single issuer in this category shall not exceed five percent (5%) of the cost value of the investment portfolio. L. A mortgage pass-through security, collateralized mortgage obligation, mortgage-backed or other pay-through bond, equipment lease-backed certificate, consumer receivable pass-through certificate, or consumer receivable-backed bond. Securities eligible for investment under this subdivision shall be rated in a rating category of "AAA" or its equivalent or better by an NRSRO and have a maximum remaining maturity of five years or less. Purchase of securities authorized by this subdivision shall not exceed 10 percent (10%) of the agency's surplus moneys that may be invested pursuant to this section. M. Shares of beneficial interest, otherwise known as money market shares, are issued by diversified management companies that are money market funds registered with the Securities and Exchange Commission under the Investment CompanyActof 1940. The company shall have met either of the following criteria: i. Attain the highest ranking or the highest letter and numerical rating provided by not less than two NRSROs, and ii. 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, City of Santa-Annual Page 13 July 1. 2026 - Statement of Investment Policy June 30,2027 million dollars ($500,000,000). The purchase price of shares of beneficial interest (mutual funds) purchased pursuant to this subdivision shall not include any commission that these companies may charge. Investments in this category shall be restricted to money market mutual funds that seek to maintain a Net Asset Value of $1. Money market mutual funds provide daily liquidity; therefore, there is no final stated maturity for this investment category. Investments in mutual funds shall be restricted to funds that have the highest ranking or the highest letter and numerical rating provided by not less than two of the following nationally recognized statistical rating organizations: Moody's, Standard & Poor's or Fitch. Purchases in this category shall not exceed twenty percent (20%) of the book value of the investment portfolio. Purchases in a single mutual fund shall not exceed ten percent 10% of the book value of the Portfolio. 8.3 Suitability of Investments Suitability, not simply return, is the standard for selecting investments forthe portfolio. The Executive Directorfor FMSA, and all authorized Investment Officials and other supporting FMSA investment staff shall review the following when selecting or recommending investments for the City: • Sufficient liquidity to meet current obligations • Appropriate level of market risk • Diversified portfolio • Legal investments • Market rate of return The Executive Director of FMSA and his/her designees are not required to invest in all investment options authorized under this Statement of Investment Policy. Selection will be based on cash flow characteristics, exposure to market risk, rate of return, the technical ability of the staff responsible for administering the program, and the availability of time and tools for staff to engage in conservative yet effective management of the City's investment portfolio. City of Santa-Annual Page 14 July 1. 2026 - Statement of Investment Policy June 30,2027 9.0 PROHIBITED INVESTMENTS AND INVESTMENT PRACTICES 9.1 Ineligible Investments- State Law Certain investments, however, are prohibited by California Government Code Section 53601.6. Accordingly, the City shall not invest in any inverse floaters, range notes, mortgage-derived or interest-only strips, or other securities that could result in zero interest accrual if held to maturity. However, prohibited securities purchased and currently held in the City's portfolio as of the date of this policy's adoption, which were previously allowed under the California Government Code but are now prohibited due to changes in the Code, may be held until their maturity dates. 9.2 Disallowed Investments- Higher Perceived Risk Besides investments prohibited by statute, this policy disallows investments in the following due to a higher perceived risk: • Investment agreements- contracts regarding funds deposited by an investor are often separated into those offered by banks and those offered by insurance companies, commonly known as Guaranteed Investment Contracts (GICs) or Guaranteed Investment Agreements (GIAs); • Securities lending agreements- agreements allowing local agencies to earn incremental income on their investment portfolio by loaning securities in their portfolio to financial services companies for a limited time; • Unregistered securities- purchases of private resales of unregistered securities to institutions, such as the Securities Act of 1933, Section 5, Rule 14A securities. 9.3 Prohibited Investment Practices Assets of the City shall not be invested pursuant to the following investment practices: • Trading of securities strictly for speculation or solely for the realization of short-term trading gains. • A contract providing for the compensation of an agent or fiduciary solely based upon the performance of the invested assets. City of Santa-Annual Page 15 July 1. 2026 - Statement of Investment Policy June 30,2027 If a fiduciary or other third party with custody of public investment transaction records of the City fails to produce records within a reasonable time, when requested by the City, the City shall make no new investments with or through the fiduciary or third party. It shall not renew maturing investments with or through the fiduciary or third party. 10.0 INVESTMENT POOLS/MUTUAL FUNDS Government-sponsored investment pools (Local Agency Investment Fund (LAIF), County Pools, Joint Powers Authority Pools, and the State Treasury Voluntary Investment Program Fund) are sources for short- term cash management. Before seeking City Council approval to participate in one or more additional investment pools/money market mutual funds, the Executive Director for FMSA or their designees will conduct a thorough investigation of the prospective pool before recommending City investment. Before recommending investing in a prospective pool, the following issues must be reviewed and considered: The pool must meet the requirements of the state statute describing eligible investment securities and include a written statement of investment policy and objectives. A description of interest calculations and how they are distributed, and how gains and losses are treated. i. A description of how the securities are safeguarded (including the settlement processes), and how often the securities are priced and the program audited. ii. A description of who may invest in the program, size and frequency of minimum and maximum deposits, how many withdrawal transactions are allowed (daily, monthly, quarterly, annually, etc.), and whether advance notice is required for withdrawal transactions. iii. A description of how and who in the governing body of the program is authorized to make program changes, including frequency. The description must include how program participants are informed of program changes and their impacts. iv. A schedule for receiving statements and portfolio City of Santa-Annual Page 16 July 1. 2026 - Statement of Investment Policy June 30,2027 listings. v. A description of how reserves, retained earnings, etc., are utilized by the pool. vi. A model of the fee schedule, and when and how it is assessed. vii. A description of eligibility and/or acceptance of bond proceeds. viii. The pool must contain only the types of investment allowed by the California Code. Upon approval for participation in one or more additional investment pools, the FMSA investment staff shall, on an annual basis, investigate and reconfirm the pool's compliance with items listed above and shall monitor the pool's performance reports. 11.0 COLLATERALIZATION/SECURITY FOR DEPOSIT OF PUBLIC FUNDS Money must be deposited in state or national banks, state or federal savings associations, or state or federal credit unions in the State of California. 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 first trust deeds with a value of one hundred fifty percent (150%) of the total amount of the deposits as an eligible security. A third class of collateral is letters of credit drawn on the Federal Home Loan Bank (FHLB). The Treasurer may, at their discretion, waive security for the portion of a deposit insured under federal law. Currently, the first two hundred fifty thousand dollars ($250,000) of a deposit is federally insured. 12.0 SAFEKEEPING AND CUSTODY In accordance with California Government Code Section 53601, to protect against potential losses caused by collapse of individual securities dealers, all securities owned by the City, except securities used as collateral for repurchase agreements, shall be kept in safekeeping with "perfected interest"by the City's custodial bank or a third-party bank trust department, acting as agent for the City under the terms of a custody agreement executed by the bank and by the City. Perfected interest refers to the establishment of a superior ownership right in and legal control over City of Santa-Annual Page 17 July 1. 2026 - Statement of Investment Policy June 30,2027 the securities assets held by the bank custodian on the City's behalf. It is intended to protect the City from the custodial bank's creditors in the event of a bank default and bankruptcy filing. All securities, excepting investments which are not deliverable (such as LAIF, California CLASS Prime Fund, direct time certificates of deposit, and money market mutual funds), will be received and delivered using standard "delivery versus payment' Delivery versus payment refers to the delivery of securities in exchange for money at the time of delivery, rather than for a signed receipt. 13.0 DIVERSIFICATION The purpose of diversification is to reduce overall portfolio risk, achieve market-rate returns, and enable the City to meet all anticipated cash requirements. The investment portfolio shall consist of various types of securities approved by state statute and this Statement of Investment Policy. Investments shall vary by issuer, asset class, industry, and maturity to meet the City's financial obligations. Diversifying the investment portfolio will help mitigate losses resulting from the failure of any one issuer. Investments shall also be diversified across structures and embedded options within the security. The investments shall be diversified by: • Limiting investments to avoid over-concentration in securities of a specific issuer (excluding treasury bills). • Limiting investment in securities that have higher credit risks. • Limiting certificates of deposit to the maximum federally insured amount. • Investing in securities with varying maturities. • Investing a minimum percentage of the total portfolio as established by the FMSA Investment Advisory Committee in highly marketable short-term treasuries, checking accounts with interest, government pooled account, or a combination of all three (See Section 4.1 (A)(iv)). 14.0 INTERNAL CONTROLS The Executive Director for FMSA is responsible for establishing and maintaining an internal control structure designed to ensure that the entity's assets are protected from loss, theft, or misuse. The Finance Department, with oversight and approval from the Executive Director for FMSA, has developed a system of internal investment controls and a City of Santa-Annual Page 18 July 1. 2026 - Statement of Investment Policy June 30,2027 segregation of responsibilities for investment functions to ensure adequate internal control over these functions. No investment personnel may engage in an investment transaction except as provided under this policy and the procedure established by the Executive Director for FMSA. Internal control procedures address: • Control of collusion • Control of fraud • Control of misrepresentation by third parties • Control of employee error • Separation of transaction authority from accounting and record keeping • Custodial safekeeping • Delivery versus payment • Clear delegation of authority • Confirmation of transactions for investment and wire transfers • Written procedures for placing investment transactions • FMSA Investment Advisory Committee In addition, cash balances are reconciled daily by non-investment employees and reconfirmed by the City's accounting staff. Accounting staff also regularly verify investment activities and holdings, and the FMSA Investment Advisory Committee reviews them. The Executive Director for FMSA, at his/her discretion, shall establish a process for annual independent reviews by an external auditor, to the extent contemplated by generally accepted auditing standards, as part of the City's annual audit. 15.0 REPORTING Government Code Section 53646(b)(1) previously mandated that annual investment policies and quarterly reports be rendered to the legislative body (for the City of Santa Ana, the City Council). AB 2853 amended Government Code Section 53646, making these requirements permissive rather than mandatory. Although the Annual Statement of Investment Policy and Quarterly Reports to the City Council are no longer required, we believe it is both prudent and consistent with the spirit of the City's Sunshine Policy to continue providing these documents. The Executive Director for FMSA shall therefore continue to render to the City Council an annual Statement of Investment Policy and to the City Manager and the City City of Santa-Annual Page 19 July 1. 2026 - Statement of Investment Policy June 30,2027 Council regular reports containing detailed information on all securities, investments, and monies of the City. Pursuant to Government Code 53607, the reports shall include monthly transactions for the reporting period. The reports will be submitted to the City Manager and City Council monthly and formally rendered to the City Council quarterly as part of a scheduled open City Council Meeting agenda within forty-five (45) days following the end of each quarter. The report will contain the following information on the funds that are subject to this investment policy: 1) Type of investment and name of issuer; 2) Date of maturity; 3) Paramount; 4) Dollar amount invested in all securities, investments, and monies held by the City (amortized cost or book value); 5) Weighted average maturity of the investments; 6) Current market value as of the date of report of all funds held by the City and under the management of any outside party that is not also a local agency or LAI F, and the source of the valuation; 7) Source of the market value information; 8) A list of any funds, investments, or programs, including loans, under the management of contracted parties such as LAIF, investment. pools, outside money managers, and securities lending agents); 9) A statement of compliance with the investment policy or an explanation for non-compliance; and 10) A statement of the local agency's ability to meet its pool's expenditure requirements for the next six months, as well as an explanation of why sufficient money will not be available if that is the case. 16.0 POLICY CONSIDERATIONS 16.1 Exemptions Any investment currently held that does not meet the guidelines of this policy shall be exempt from the requirements of this policy, provided it complied with State of California law and the City's investment policy in effect at the time of purchase. At maturity or liquidation, such funds shall be reinvested only as provided by this policy. City of Santa-Annual Page 20 July 1. 2026 - Statement of Investment Policy June 30,2027 16.2 Stabilization Fund Except for cash in certain restricted and special funds, the consolidation of cash balances from all funds and the maintenance of portfolio liquidity (both static and dynamic), as provided for in this policy, together with the monthly affirmation to the City Manager and City Councilmembers of the City's ability to meet its pool's expenditure requirements for the next six months, shall be deemed to functionally meet and exceed the requirements of Article VI., Sec. 610, of the City of Santa Ana Charter as relates to the maintenance of a stabilization fund. 16.3 Amendments In the event this policy is amended prior to the end of its twelve- month fiscal year term, the amended Statement of Investment Policy shall be resubmitted to City Council for review and adoption by City Council Resolution. 16.4 Approval This Statement of Investment Policy is approved by City Council on this 16th day of June, 2026, pursuant to City Council Resolution #2026-XXX. 17 POLICY REVIEW, CERTIFICATION, AND ADOPTION 17.1 Policy Review This Statement of Investment Policy shall be reviewed at least annually to ensure its consistency with the overall objectives of preservation of PRINCIPAL, LIQUIDITY, AND YIELD, and to: 1) reflect changes in applicable California state codes, 2) maintain its relevance to current financial and economic trends, and 3) meet the needs of the City of Santa Ana. 17.2 Policy Certification This certified Statement of Investment Policy will be resubmitted to the Association of Public Treasurers of the United States and Canada (APTUS&C) and the California Municipal Treasurers Association (CMTA) for review and re-certification every five (5) years, or more often in the event of significant legislative changes, changes in industry standards, or substantive non-administrative modifications to the body of the policy statement, exclusive of revisions or additions to appendices or glossaries. In FY 2019-20, the City of Santa Ana received Investment Policy Certifications City of Santa-Annual Page 21 July 1. 2026 - Statement of Investment Policy June 30,2027 from both the APTUS&C at the international North American level and the CMTA at the state level. In FY 2021-22, the City of Santa Ana received a state-level Investment Policy Certification from the CMTA. 17.3 Adoption The Executive Director of FMSA shall present this Statement of Investment Policy annually to the City Council and the City Manager. The City Council shall annually review and adopt this Statement of Investment Policy by resolution at a public meeting. Submitted to the Santa Ana City Council for approval,this 16th day of June 2026. Alex Trinidad, CPA Executive Director & City Treasurer Finance & Management Services Agency City of Santa-Annual Page 22 July 1. 2026 - Statement of Investment Policy June 30,2027 ALLOWABLE INVESTMENT INSTRUMENTS PER STATE GOVERNMENT CODE(AS OF JANUARY I,2026)"APPLICABLE TO ALL LOCAL AGENCIESg See"Table of Notes for Figure I"on the next page for footnotes related to this figure. TYPE jm;" INVESTMENT Local Agency Bonds 5 years None None 53601(a) U.S.Treasury Obligations 5 years None None 53601(b) State Obligations—CA 5 years None None 53601(c) And Others 53601(d) CA Local Agency Obligations 5 years None None 53601(e) U.S Agency Obligations 5 years None None 53601(f) Bankers'Acceptances 180 days 40%E None 53601(g) Commercial Paper—Non-Pooled Funds' 397 days or less 25%of the Highest letter and (under$100,000,000 of investments) agency's moneys number rating byan 5 3 601(h)(2)(c) NRSRO Commercial Paper—Non-Pooled Funds' (min. 397 days or less 40%of the Highest letter and $100,000,000 of investments) agency's moneys number rating by an 5 3 601(h)(2)(c) NRSRO Commercial Paper— 270 days or less 40%of the Highest letter and PooledFundsi agency'smoneyG number rating by an 53635(a)(1) NRSRO Negotiable Certificates of Deposit 5 years 30%K None 53601(i) Non-negotiable Certificates of Deposit 5 years None None 53630 et seq. Placement Service 5 years 50%1 None 53601.8 and 53635.8 Deposits Placement Service Certificates 5 years 50%1 None 53601.8 and 53635.8 of Deposit Repurchase Agreements I year None None 53601(j) Reverse Repurchase Agreements and 92 days" 20%of the base None" 53601 Q) Securities Lending Agreements value of the portfolio 5 years or "A"rating category or Medium-Term Notes0 less 30'� its equivalent or better 53601(k) Mutual Funds And Money Market N/A 205/.P Multiples R 53601(1)and Mutual Funds 53601.6(b) Collateralized Bank Deposits' 5 years None None 53630 et seq.and 53601(n) Mortgage Pass—Through and 5 years or 20% "AA"rating category or 53601(o) Asset—Backed SecuritiesT IessT its equivalent or better' County Pooled N/A None None 27133 Investment Funds Joint Powers Authority Pool N/A None Multiple' 53601(p) Local Agency Investment Fund(LAIF) N/A None None 16429.1 Voluntary Investment Program Fund' N/A None None 16340 5 years or "AA"rating category or Supranational Obligations 30% 53601(q) less its equivalent or better Public Bank Obligations 5 years None None 53601(r),53635(c) and 57603 City of Santa-Annual Page 23 July 1. 2026 - Statement of Investment Policy June 30,2027 Source Sectfons 19340, 16429.1.27133,53601, Retowrserepurchase agreements or securities lending 53601.6.53601.8, 53630 ed seq.,53635, 53635.8, agreements may exceed the 92-day term tt the agree- and 57803_ merit includas a written codicil guaranteeing a mini- s mum earning or spread for the entire period between Arfunrcipaf Utilities Uistficts ha ve the authority finder the Public Utrfitiez Code Section 12871 to investin the sale Of a secuFity using a reverse repurchase certain secGrib-ev not addressed here. agreement or sec7urrtios fending agreement and the final Faturity dates Of the same security. Section S3601 provides drat the rnaximum term of Reverse repurchase agreements must be made with anyinkestment auth rizad under this section,unless primary dealers of the Federal Reserve Bank of New Otherwise stated,is five years from the settlement dacte.Flowerer,the legisfatikve body may grant ergpress YcAs or with a nationally or statechartered hank that has a significant relationship with the locarag'&ncy authontyto make investments either specificaNy or The local agency must have held the securities used as a part of arr inve-stment program approved by the for the agreements for at Least 30 days- legisLAkie body that exceeds this€rve year remain- ing maturitylimit.Such approval must be issued no a Wedium-tsrm nodes"are defined in S&ctimn 53601 as less than throe months prior to the purchase of any "all corporate and depository insl&rton debt zecurrboz security exceeding the five-year maturity Nmrt_ with a n a wnum remarnrng maturity at five years or Percentages apply to all poFt€olio investments regard- Aess.Rssuod by corporations organized and operating wdthin the United States or by depozdory insti iihons less O€SOur[?e O€funds.For fn£tar7Ce,Cash from a � ��ttAe tlnrdedStatos of anyst�and Operat- reverse repurchase agreement would be sufyect to the restriction& ing wrtWrr the United States_' a No more than 10%invested in any one mutual fund. No more than3a96 Of the ag'el'7G*'£.money may be in bankers'accaoianoes ofany one commercial bank. This lrmitztrorr does not apply to rnonay mankat mutual funds_ Applies to local agencies,other than counties or a o A mutual fund must reserve the highest ranking by not city and county,with less than$l00 mrlffon offrrvest- merrt assets finder management lrrclGdes agencies ' than two nationally r000gnrrod rating agencies or the fund must retain an rnveetment advisor who is defined as a city:a distinct,or other focal agency that registered with the SEC(or exenWt from registrabon), do not pool money in deposits or mveztmerrt with has assets under management in excess ofm500mif other focal agencies,other than local agencies that lion,and has at least tyke years`exparronce irrvesiirrq in have the same goveming body. instruments aGthanized by Sections 53601 and 53635_ ° Local agencies,other than counties or a city and " A money market mutual fund must receive the highest county;may purchase no more than 10%of the out- ranking by not less than two nabonallyrecognmed standing commercial paper and rrfediurrrterm notes statistical rating orgaraizatrons or retain an rmrastrrrent Of arty single issuer. advisor registered with the SEC or exempt from reg " tsswng corporation must be organized and operating istratron and who has not lass than five years'experr- wrfihin the US-have arse&in excess of$500rnNLon. once investing in money market instruments with and debt other than commercial papermuat be m a assets under management in excess of$500 million. rating category of A"orrts equivalent or higher byana nz honaatly recognized stabsticaf rating organization,or the J investments n notes bonds,i r other ol0ate al b under Section 536ai fn)Fequrre that sollateraf be Issuing corporation must be organized mthin the US_ as a speckd purpose corporation,tru.,or LLC have Placed into the custody of a trust company of the bust ode bank that rs not afMaie€iFfraded with the program wade credit enhancements,and have cornmer- cialpaperthatisrated"A-Y"orhigher,ortheegeuwalent. issuer of the secured obfrgation,among other specific by a naticurarfy recognized ztahsLicaati rating orgarNMdon_ collateral requirements_ ' Applies to counties or a city and county,and the City Security type.:authorized under Section 5360I(pJ that are issued or guaranteed by an issuer icien&Yed rnuerstmentassets under management..o€Los Angeles that have mina million more of in subdivisions(bJ Or(0,are net subject to trho limita- Lions placed an privately issued securites authorized lrncludes agencies defined as a county,a city and in Section 5360JfoJ(2)(AJfB). county,or other locat agency that pools money rn asf- deposits or investments with other local agencies, A joint powers whauto iz regizte d must retain an rnvr merit advisor who is registered with the SEC 1'ar rnciudirrg kwat agencies that have the same governing exempt from registration),has assets urtdermanage- body.Local agencies that pool exclusively with MGM in excess of m5f]O rnNliarr,and has at least free Other focal agencies flout have the same govemfng years'experionoefrwesling in instruments authorized body must adhere to the limits set forth in Section by Section 53601,subdivisions(a)to(o). 5360 YthJf2J(CJ- a Local entities can deposit between$200million and r1rr9 Ali FIYJ�1.3h�rSRr.hf'Ff]Fi 7/fAIV!V C R}AAfW.Blau r]a'i J�1