HomeMy WebLinkAbout2015-029 - Approving the City's Statement of Investment PolicyRESOLUTION NO. 2015 -029
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF SANTA ANA APPROVING THE CITY'S
STATEMENT OF INVESTMENT POLICY
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,
2015, 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 Clerk of the Council shall attest to and certify the
vote adopting this Resolution.
Resolution No. 2015 -029
Page 1 of 2
ADOPTED this 16" day of June, 2015.
APPROVED AS TO FORM:
Sonia Carvalho, City Attorney
By: 6 ' 16 .
Lisa Sk
Assistant City Attorney
AYES: Councilmembers: Amezcua Benavides, Pulido, Reyna
Sarmiento (5)
NOES: Councilmembers: None (0)
ABSTAIN: Councilmembers: None (0)
NOT PRESENT: Councilmembers: Martinez Tinaiero (2)
CERTIFICATION OF ATTESTATION AND ORIGINALITY
I, MARIA D. HUIZAR, Clerk of Council, do hereby attest to and certify the attached
Resolution No. 2015 -029 to be the original resolution adopted by the City Council of the
City of Santa Ana on June 16, 2015.
Date: (Idl1dv 15
Resolution No. 2015 -029
Page 2 of 2
Clerk of Council
City of Santa Ana
CITY OF SANTA ANA
ANNUAL STATEMENT OF INVESTMENT POLICY
JULY 2015
INTRODUCTION:
This statement is intended to outline the policies for prudent investment of idle City funds by
providing guidelines for suitable investments effective for fiscal year 2015 -16 while maximizing
the efficiency of the City's Cash Management Program.
Under the direction of the Executive Director, Finance and Management Services / City
Treasurer, the responsibility for the day -to -day investment of the City's funds is delegated to the
Treasury and Customer Services Manager and /or Assistant Finance Director only. The
investment policy applies to all financial assets of the City which are pooled in an actively
managed portfolio. The investment pool or portfolio will be referred to as the "Fund" throughout
this document.
Bond proceeds shall be invested in accordance with requirements and restrictions outlined in the
bond documents. Bond proceeds are not considered part of the Fund nor subject to this
Investment Policy.
The City's Cash Management Program is designed to accurately monitor and forecast
expenditures and revenues, thus enabling the investment of funds to the fullest extent possible.
Maturities are matched as close as possible to coincide with cash requirements.
The investment policies and practices of the City of Santa Ana are based upon Federal, State
and local law and prudent money management. The primary goals of these policies are:
1. To assure compliance with all Federal, State and local laws governing the investment
of monies.
2. To provide for the safety of principal and sufficient liquidity.
3. To provide an investment return within the parameters of this Statement of Investment
Policy.
Officers and employees involved in the investment process shall refrain from personal business
activity that could conflict with the proper execution and management of the investment program,
or that could impair their ability to make impartial decisions. Employees and investment officials
shall disclose any material interests in financial institutions with which they conduct business.
They shall further disclose any personal financial /investment positions that could be related to
the performance of the investment portfolio. Employees and officers shall refrain from
undertaking personal investment transactions with the same individual with whom business is
conducted on behalf of the City.
Exhibit 2
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OBJECTIVES:
SAFETY OF PRINCIPAL - Safety of principal is the foremost objective of the City of Santa
Ana. Each investment transaction shall be undertaken in a manner that seeks to ensure
preservation of capital in the overall portfolio. The objective will be to mitigate credit risk and
interest rate risk.
A. Credit Risk
Credit Risk is the risk of loss due to the failure of the security issuer or backer. Credit risk
may be mitigated by:
- Limiting investments to the safest types of securities;
Pre - qualifying the financial institutions, broker /dealers, intermediaries, and
advisors with which the City will do business; and
Diversifying the investment portfolio so that potential losses on individual
securities will be minimized.
B, Interest Rate Risk
Interest rate risk is the risk that the market value of securities in the portfolio will fall
due to changes in general interest rates. Interest rate risk may be mitigated by:
Structuring the Fund so that securities mature to meet cash requirements for
ongoing operations, thereby avoiding the need to sell securities on the open
market prior to maturity, and
- By investing operating funds primarily in shorter -term securities.
The cash flow is updated on a daily basis and will be considered prior to the investment of
securities, which will reduce the necessity to sell investments for liquidity purposes.
LIQUIDITY - The investment portfolio shall remain sufficiently liquid to meet all operating
requirements that may be reasonably anticipated. This is accomplished by structuring the
portfolio so that securities mature concurrent with cash needs to meet 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).
3. YIELD - The City's Fund shall be designed with the objective of attaining a market - average
rate of return throughout budgetary and economic cycles taking into account the investment
risk constraints and liquidity needs. Return on investment is of least importance compared to
the safety and liquidity objectives described above. The core of investments is limited to
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relatively low risk securities in anticipation of earning a fair return relative to the risk being
assumed. Securities shall not be sold prior to maturity with the following exceptions:
1) a declining credit security could be sold early to minimize loss of principal;
2) a security swap would improve the quality, yield, or target duration in the portfolio; or
3) liquidity needs of the portfolio require that the security be sold.
The market - average rate of return is defined as the average return on three -month U.S.
Treasury Bills.
The City strives to maintain one hundred percent (100 %) investment of idle funds after
consideration for a compensating balance to cover the cost of services provided by the bank.
The funds available for investment are determined by cash flow projections updated daily.
Investments are monitored so that legal limits on types of investments are not exceeded.
AUTHORIZED INVESTMENTS:
The "prudent person" standard shall be applied in the context of managing the overall portfolio.
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 deviations from exceptions are reported in a timely
fashion and the liquidity and the sale of securities are carried out in accordance with the terms of
this policy. Investments shall be made with judgment and care, under circumstances then
prevailing, which persons of prudence, discretion, and intelligence exercise in the management
of their own affairs, not for speculation, but for investment, considering the probable safety of
their capital as well as the probable income to be derived.
The City is governed by the California Government Code, Sections 16429.1 and Title 5, Division
2, Part 1, Chapter 4, entitled Financial Affairs, commencing with Section 53630. Santa Ana
further restricts the permitted investments to those listed below. Within this scope, the City
diversifies its investments by maturity dates and types of investments. Concentration limits are
indicated for all investment categories except Treasury securities, which are considered the
safest investments.
A. United States Treasury Bills, Notes, and Bonds, for which the full faith and credit of the
United States are pledged for payment of principal and interest. Purchases of this
category shall not exceed five years to maturity. There is no percentage limit in this
category.
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B. Obligations issued by a Federal Agency or a United States Government Sponsored
Enterprise. Federal Agency Issues by government- sponsored enterprises (GSEs)
include, but are not limited to: FFCB (Federal Farm Credit Bank), FHA (Federal Housing
Administration), FHLB (Federal Home Loan Bank Board), FHLMC (Federal Home Loan
Mortgage Corporation), FNMA (Federal National Mortgage Association), FICO (Financial
Corporation), GNMA (Government National Mortgage Association), REFCORP
(Resolution Funding Corporation), SLMA (Student Loan Mortgage Administration) and
TVA (Tennessee Valley Authority). Although there is no percentage limitation on these
issues, the "prudent investor" rule shall apply for a single agency name as U.S.
Government backing is implied rather than guaranteed.
C. 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
Fund may be invested in the banker's acceptances of any one commercial bank pursuant
to this section.
D. Commercial paper of "Prime" quality of the highest ranking or of the highest letter and
number rating as provided for by a Nationally Recognized Statistical Rating Organization
(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 has 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 -1" or higher, or the equivalent, by an
NRSRO. Eligible commercial paper shall have a maximum maturity of two hundred
seventy (270) 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 (25 %) of the surplus money which
may be invested.
E. 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. The City's investment in
negotiable certificates of deposit may not exceed thirty percent (30 %) of the cost value of
the Fund. The amount so invested shall be subject to the limitations of Government
CITY OF SANTA ANA STATEMENT OF INVESTMENT POLICY
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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.
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 repurchase agreement and shall be adjusted no less than quarterly by the tri-
party custodial agent. The investments in repurchase agreements shall be in compliance
if the underlying securities are brought back up to one hundred two percent (102 %) no
later than the next business day. Securities that can be pledged for collateral shall
consist only of investments permitted within this policy with a maximum maturity of five (5)
years. If there is a default of the broker, the collateral securities can be sold. Since the
securities are valued daily, it is likely that the sale proceeds will equal or exceed the value
of the repurchase agreement amount. Purchases in this category shall not exceed ninety
(90) days or twenty percent (20 %) of the cost value of the Fund.
G. 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. Although there is no percentage
limitation on this fund, the "prudent investor" rule shall apply for a single agency name.
H. Medium Term Corporate Notes issued by corporations organized and operating within the
United States or by depository institutions licensed in 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 its equivalent or better by a nationally recognized rating service.
Purchases in this category shall not exceed three (3) years to maturity or fifteen percent
(15 %) of the cost value of the Fund. Purchases in a single issuer in this category shall
not exceed five percent (5 %) of the cost value of the Fund.
I. Shares of beneficial interest issued by diversified management companies that are
money market funds registered with the Securities and Exchange Commission under the
Investment Company Act of 1940. The company shall have met either of the following
criteria:
1. Attain the highest ranking or the highest letter and numerical rating provided by not
less than two NRSROs, or
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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
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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. The Executive Director, Finance and
Management Services / City's Treasurer's staff shall investigate all institutions which wish to do
business with the City, 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's Investment Policy and Investment Portfolio Guidelines. This will be done
annually by having the Financial Institutions complete and return the appropriate questionnaire,
and an audited Financial Statement must be provided within one hundred twenty (120) days of
the Financial Institution's fiscal year -end.
SAFEKEEPING OF SECURITIES:
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 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. All securities will be received and delivered using standard delivery versus payment.
INTERNAL CONTROLS:
The Executive Director, Finance and Management Services / City Treasurer is responsible for
establishing and maintaining an internal control structure designed to ensure that the assets of
the entity are protected from loss, theft or misuse. The Executive Director, Finance and
Management Services / City Treasurer has developed a system of internal investment controls
and a segregation of responsibilities of investment functions in order to assure an adequate
system of internal control over the investment function. Internal control procedures address wire
controls, separation of duties, delivery of securities to a third party for custodial safekeeping, and
written procedures for placing investment transactions.
Cash balances are reconciled daily by non - investment employees and reconfirmed by the City's
accounting staff. In addition, the City's accounting staff also verifies investment activities and
holdings on a monthly basis. The Executive Director, Finance and Management Services / City
Treasurer shall establish a process for annual independent review by an external auditor to the
extent contemplated by generally accepted auditing standards.
REPORTING:
Under the provisions of Section 53646 of the Government Code the Executive Director, Finance
and Management Services / City Treasurer shall continue to render a report to the City Council,
City Manager, and the internal auditor containing detailed information on all securities,
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investments, and moneys of the City. The report will be submitted on at least a quarterly basis
and provided to the Council within thirty (30) days following the end of the quarter.
The report will contain the following information on the funds that are subject to this investment
policy: 1) the type of investment, name of the issuer, date of maturity, par and cost in each
investment, 2) the weighted average maturity of the investments, 3) any investments, including
loans and security lending programs, that are under the management of contracted parties, 4)
the market value and source of the valuation, 5) a description of the compliance with the
statement of investment policy, and 6) a statement denoting the City's ability to meet its pool's
expenditure requirements for the next six months.
POLICY REVIEW:
This investment policy shall be reviewed at least annually to ensure its consistency with the
overall objectives of preservation of PRINCIPAL, LIQUIDITY, AND YIELD and its relevance to
current law, financial and economic trends, and to meet the needs of the City of Santa Ana.
Francisco Gutierrez
Executive Director / City Treasurer
Finance & Management Services Agency
WH