HomeMy WebLinkAboutStaff Report 3.D 06/20/2016Agenda Item #3.D
DATE: June 20, 2016
TO: Honorable Mayor and Members of the City Council through City Manager
FROM: William Mushallo, Finance Director
SUBJECT: Resolution to Approve the City of Petaluma Investment Policy and Delegate
Investment Authority to the City Treasurer for Fiscal Year 2016-2017
RECOMMENDATION
It is recommended that the City Council adopt the attached Resolution Approving the City of
Petaluma Investment Policy and Delegating Investment Authority to the City Treasurer for Fiscal
Year 2016-2017.
BACKGROUND
In compliance with State law, the City Treasurer may annually render to the City Council a
Statement of Investment Policy, which the City Council shall consider at a public meeting. The
investments set forth in this policy are pursuant to Sections 53601 and 53635 of the California
Government Code.
DISCUSSION
A good investment policy provides the framework for the cash, treasury and investment
management of the City. The City of Petaluma requires that investments of City funds be
compliant with its Investment Policy. This policy, brought to the Council for review and
consideration, is excluding the following investment types that were also excluded in the adopted
FYI 5-16 policy.
- Repurchase Agreement and Reverse Repurchase Agreement (REPOS)
- Commercial Paper (CP)
- Medium Term Notes (MTN)
- Mutual Funds
- Guaranteed Investment Contract (GIC)
- Negotiable Certificates of Deposit
There are two minor changes to the FY2016-2017 Investment Policy; the LAIF limit has been
updated to the current $65 Million statutory limit and the sentence discouraging investment in
entities that were part of the national foreclosure settlement has been removed. This second
change reflects direction provided during the Council's review of the City's investment policies
last year, based on recognition of the time that has passed since 'the national foreclosure
settlement and the behavior of the affected financial institutions since that time.
The management of the City's investment portfolio requires daily analysis of the City's cash
flow needs, which include not only day-to-day operating requirements, but also the funding of
large capital projects. This requires the City to keep substantial funds in very liquid investments
such as Local Agency Investment Fund (LAIF) and California Asset Management Program
(CAMP). These are low risk investments and do not earn a substantial amount of interest. These
funds are managed internally by the City Treasurer.
The primary objectives of this investment policy are to comply with state laws, safeguard the
principal of funds, meet daily cash flow requirements and achieve a reasonable rate of return
with the maximum security.
The investment policy has for some time provided that the City Council delegates investment
authority to the City Treasurer for a one year period. The proposed resolution adds delegation
language to conform to the policy.
FINANCIAL IMPACTS
None.
ATTACHMENTS
1. Resolution and Exhibit A
2
ATTACHMENT 1
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PETALUMA
APPROVING THE CITY OF PETALUMA INVESTMENT POLICY AND
DELEGATING INVESTMENT AUTHORITY TO THE CITY TREASURER FOR
FISCAL YEAR 2016-2017
WHEREAS, the City Treasurer has rendered to the City Council a Statement of
Investment Policy; and
WHEREAS, the City Council has reviewed and considered the Statement of Investment
Policy at a regularly scheduled meeting of the City Council; and
WHEREAS, the City Treasurer has the responsibility to invest the pooled idle cash from
all City funds pursuant to California Government Code Sections 53601 and 53635; and
WHEREAS, pursuant to the Government Code and Statement of Investment Policy the
City Council must delegate authority to invest or reinvest funds, or to sell or exchange securities
so purchased; and
WHEREAS, the City Council has traditionally delegated investment authority to the City
Treasurer for a one year period. .
NOW, THEREFORE, BE IT RESOLVED that the City Council approves the City of
Petaluma Investment Policy and delegates investment authority to the City Treasurer for Fiscal
Year 2016-2017 as shown in Exhibit A, attached.
ATTACHMENT 2
EXHIBIT A TO THE RESOLUTION
CITY OF PETALUMA, CALIFORNIA
STATEMENT OF INVESTMENT POLICY
For Fiscal Year 2016-2017
William Mushallo
Finance Director/City Treasurer
A
CITY OF PETALUMA, CALIFORNIA
STATEMENT OF INVESTMENT POLICY FOR FISCAL YEAR 2016-2017
POLICY
It is the policy of the City of Petaluma, CA (the "City") to manage public funds in a manner
consistent with the following objectives: comply with all laws of the State of California
pertaining to the investment of public funds; safeguard the principal of funds under its control,
meet the daily cash flow requirements and to achieve a reasonable rate of return with the
maximum security.
SCOPE
This investment policy applies to all financial assets of the City. These funds are accounted for
in the City Comprehensive Annual Financial Report and include:
General Fund
Special Revenue Funds
Debt Service Funds
Capital Project Funds
Enterprise Funds
Internal Service Funds
Permanent and Private Purpose Trust Funds
This Policy shall also apply to funds of the Petaluma Community Development Commission
(PCDC), City acting in its capacity as Successor Agency, Petaluma Public Financing Authority,
City of Petaluma Public Financing Corporation and any other fund under the control of the City
Treasurer.
PRUDENCE
Investments shall be made with care, skill, prudence, and diligence under the circumstances then
prevailing, including, but not limited to, the general economic conditions and the anticipated
needs of the City, that a prudent person acting in a like capacity and familiarity with those
matters would use in the conduct of funds of a like character and with like aims, to safeguard the
principal and maintain the liquidity needs of the City.
The City Treasurer and authorized individuals acting in accordance with written procedures and
the 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
expectations are reported in a timely fashion and appropriate action is taken to control adverse
developments.
OBJECTIVE
The primary objective in priority order, of the City's investment activities shall be:
1. Safety: Safety of principal is the foremost objective of the investment program.
Investments of the City shall be undertaken in a manner that seeks to ensure the
preservation of capital in the overall portfolio.
2. Liquidity: The City's investment portfolio will remain sufficiently liquid to enable the
City to meet all operating requirements which might be reasonably anticipated.
3. Return on Investments: The City's investments shall be designed with the objective of
attaining a rate of return throughout budgetary and economic cycles, commensurate with
the City's investment risk constraints and the cash flow characteristics of the portfolio.
DELEGATION OF AUTHORITY
Under the City Charter Section 24, the City Treasurer is appointed by the City Manager with the
approval of the City Council. The City Treasurer is also the City's Finance Director. Pursuant to
the Government Code, the City Council delegates the authority to invest or to reinvest funds, or
to sell or exchange securities so purchased, to the City Treasurer for a one-year period. The City
Treasurer is charged with the responsibility for carrying out the policies of the City Council and
shall assume full responsibility for investment transactions until the delegation of authority is
revoked or expires. No person may engage in an investment transaction except as provided under
the limits of this Investment Policy.
The daily cash management, investment transactions and account reconciliations are the primary
responsibilities of the City Treasurer. These activities are also carried out by other members of
the Finance Department under the direction of the City Treasurer. The City Treasurer shall
establish procedures for the operation consistent with this investment policy.
ETHICS AND CONFLICT OF INTEREST
Officers and employees involved in the investment process shall refrain from personal business
activities that could conflict with proper execution of the investment program or which could
impair their ability to make impartial decisions. Officers and employees involved in the
investment process shall abide by the Conflict of Interest Code, (California Government Code
Section 1090 et seq.) and the California Political Reform Act (California Government Code
Section 81000 et seq.).
SOCIALLY RESPONSIBLE INVESTING
The City strives to make socially responsible investments and monitors issuers' business activity.
Investments are encouraged in entities that support community well-being through safe and
environmentally sound practices and fair labor practices. Investments are encouraged in entities
that support quality of rights regardless of sex, race, age, disability or sexual orientation.
Investments are discouraged in entities that manufacture tobacco products. In addition,
investments are encouraged in entities that offer banking products to serve all members of the
local community, and investments are discouraged in entities that have had past criminal or
regulatory violations.
PERMITTED INVESTMENTS
California Government Code Sections 53601 et. seq., and 53635 govern the investments
permitted for purchase by the City. Within the investments permitted by the Code, the City seeks
to further restrict eligible investments to the investments listed below.
Percentage limitations, where indicated, apply at the time of the purchase. Rating requirements
where indicated apply at the time of purchase. In the event a security held by the City is subject
to a rating change that brings it below the minimum specified rating requirement, the City
Treasurer shall notify the City Council of the change. The course of action to be followed will
then be decided on a case-by-case basis, considering such factors as the reason for the rate drop,
prognosis for recovery or further rate drops, and the market price of the security. Investment
maturities shall be based on review of cash flow forecasts. Maturities will be scheduled so as to
permit the City to meet all projected obligations.
No investment shall be made in any security, other than a security underlying a repurchase or
reverse repurchase agreement, that at the time of the investment has a term remaining to maturity
in excess of five years (except for bond proceeds), unless the City Council has granted express
authority to make that investment no less than three months prior to the investment.
ELIGIBLE INVESTMENTS
A. State of California Local Agency Investment Fund (LAIR The City may invest in
LAIF up to statutory limits.
B. Sonoma County Investment Pool. The City may invest in the Sonoma County
Investment Pool. A maximum of $10 million may be invested in this category.
C. California Asset Management Program Trust (CAMP). The City may invest in the
shares in the California Asset Management Trust, so long as the portfolio is rated among
the top two rating categories by one of the nationally recognized rating agencies. A
maximum of $50 million may be invested in this category.
D. Certificates of Deposit. FDIC insured or fully collateralized time certificates of deposit
in financial institutions located in the United States including a Placement Service such
as Certificate of Deposit Account Registry Service (CDARS). Collateralized certificates
of deposit shall be handled in accordance with California Government Code section
53530 et seq. The City, at its discretion, may waive the collateralization requirements for
any portion of the deposit that is covered by federal deposit insurance. As noted above
the City may also invest in fully insured certificates of deposit utilizing a placement
service such as CDARS, as provided under California Government Code section
53601.8. The maximum teim for certificates of deposit shall be two years. Investments
in certificates of deposit are further limited to 30% of surplus funds.
E. Banker's Acceptances. Banker's acceptances issued by domestic or foreign banks,
which are eligible for purchase by the Federal Reserve System. Purchases of banker's
acceptances may not exceed 180 days maturity. Eligible banker's acceptances are
restricted to issuing financial institutions with short-term paper rated in the highest
category by one or more nationally recognized rating services. Investments in banker's
acceptances are further limited to 40% of the portfolio with no more than 30% of surplus
invested in the banker's acceptances of any one commercial bank.
F. U.S. Government Issues. United States Treasury notes, bonds, bills, or certificates of
indebtedness, or those for which the faith and credit of the United States are pledged for
the payment of principal and interest.
G. Federal Agency Securities. Federal agency or United States government-sponsored
enterprise obligations, participations, or other instruments, including those issued by or
fully guaranteed as to principal and interest by federal agencies or United States
government-sponsored enterprises.
H. Money Market Funds. Shares of beneficial interest issued by diversified management
companies that are money market funds registered with the Securities and Exchange
Commission (SEC) under the Investment Company Act of 1940 (15 U.S.C., Sec. 80a-1,
et seq.).
The City may invest in shares of beneficial interest issued by a company which shall have
met either of the following criteria:
a. Attained the highest ranking or the highest letter and numerical rating provided by
not less than two nationally recognized rating services.
(or)
b. Retained an investment adviser registered or exempt from registration with the
SEC with not less than five years experience in managing money market mutual
funds with assets under management in excess of five hundred million dollars
($500,000,000).
The purchase price of shares of beneficial interest purchased pursuant to this subdivision
shall not include any commission that the companies may charge. Investments in Money
Market Funds are further limited to 20% of the portfolio.
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ELIGIBLE INVESTMENTS FOR BOND PROCEEDS
Bond Proceeds shall be invested in securities permitted by the applicable bond documents. If
the bond documents are silent as to the permitted investments, bond proceeds will be invested
in securities permitted by this Policy.
With respect to maximum maturities, the Policy authorizes investing bond reserve fund proceeds
beyond the five years if prudent in the opinion of the City Treasurer.
INELIGIBLE INVESTMENTS
As provided in California Government Code section 53601.6 and this policy, the City shall not
invest any funds in:
• Inverse Floaters
• Range Notes
• Mortgage Derived Interest -Only Strips
• Any security that could result in zero interest accrual if held to maturity.
The purchase of any security not listed above, but permitted by the California Government Code,
is prohibited unless the City Council approves the investment either specifically or as a part of an
investment program approved by the Board. Exclusion of these investment vehicles is consistent
with the City's overall objectives of achieving reasonable returns on public funds while
minimizing risk and capital losses. Although the potential exists for greater yields with these
vehicles, there is the potential level of risk that can exceed their benefits.
To provide for the optimum yield in the City's portfolio, the City's procedures shall be designed
to encourage competitive bidding on transactions from an approved list of broker/dealers.
The City Treasurer, or the City's investment advisor, shall maintain a list of authorized
broker/dealers and financial institutions that are approved for investment purposes. This list will
be developed after a comprehensive credit and capitalization analysis indicates the firm is
adequately financed to conduct business with public entities. It shall be the policy of the City to
purchase securities only from those authorized institutions or firms.
If the City has engaged the services of a registered investment advisory firm, the firm is
authorized to conduct investment transactions on the City's behalf with their own list of
approved broker/dealers and financial institutions. The investment advisor's approved list must
be made available to the City.
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SAFEKEEPING AND CUSTODY
All security transactions entered into by the City of Petaluma, CA shall be conducted on a
delivery -versus -payment (DVP) basis. This procedure ensures that securities are deposited with
the third -party custodian prior to the release of funds. A third parry custodian designated by the
City Treasurer and evidenced by safekeeping receipts will hold securities.
The only exceptions to the foregoing are Local Agency Investment Pools, Certificates of Deposit,
and money market funds since the purchased securities are not deliverable. In all cases,
purchased securities shall be held in the City's name.
INTERNAL CONTROL
The City Treasurer shall establish an annual process of independent review by an external
auditor. This review will provide internal control by assuring compliance with the Statement of
Investment Policy and procedures.
PERFORMANCE STANDARDS
The investment portfolio shall be designed with the objective of obtaining a reasonable rate of
return throughout budgetary and economic cycles, commensurate with the investment risk
constraints and the cash flow needs.
The City will measure the portfolio's performance against a market benchmark that is
commensurate with the City's investment risk constraints and the cash flow characteristics of the
portfolio.
REPORTING
The City Treasurer shall provide a quarterly investment report to the City Council, which
provides a clear picture of the status of the current investment portfolio, including transactions.
This report will be formally submitted to the City Council after each quarter at a public meeting.
Schedules in the quarterly Treasurer's Report will include the following:
• Listing of individual securities held at the end of the reporting period.
• Realized and unrealized gains or losses resulting from appreciation or depreciation by listing
the cost and market value of securities over one-year duration that are not intended to be held
until maturity (in accordance with Governmental Accounting Standards Board (GASB)
requirements).
• Average weighted yield to maturity of portfolio on investments as compared to applicable
benchmarks.
• Listing of investment by maturity date.
• Percentage of the total portfolio which each type of investment represents.
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The quarterly report shall state compliance of the portfolio to the investment policy, or manner in
which the portfolio is not in compliance. The quarterly report shall also include a statement
certifying the ability of the City to meet its expenditure requirements for the next six months.
POLICY REVIEW
The 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
and financial and economic trends. The investment policy shall be adopted by resolution of the
City Council on an annual basis. Any amendments to the policy shall be forwarded to the City
Council for approval.
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CITY OF PETALUMA
STATEMENT OF INVESTMENT POLICY FOR FISCAL YEAR 2016-2017
GLOSSARY OF TYPES OF INVESTMENTS
AVAILABLE TO LOCAL GOVERNMENTS
STATE INVESTMENT POOL (LAIF)
The Local Agency Investment Fund (LAIF), a voluntary program created by statute, began in
1977 as an investment alternative for California's local governments and special districts and
continues today under the State of California Treasurer's office. The enabling legislation for the
LAIF is Section 16429.1,2,3 of the California Government Code.
This program offers participating agencies the opportunity to participate in a major portfolio
which daily invests hundreds of millions of dollars, using the investment expertise of the
Treasurer's Office Investment staff at no additional cost to the taxpayer. This in-house
management team is comprised of civil servants who have individually worked for the State
Treasurer's Office for over 20 years.
The LAIF is part of the Pooled Money Investment Account (PMIA). The PMIA began in 1955
and has oversight provided by the Pooled Money Investment Board (PMIB) and an in-house
Investment Committee. The PMIB Board members are the State Treasurer, Director of Finance,
and State Controller.
The LAIF has oversight by the Local Investment Advisory Board (LIAB). The Board consists of
five members as designated by Statute. The Chairman is the State Treasurer, or his designated
representative. Two members qualified by training and experience in the field of investment or
finance, and the State Treasurer appoints two members who are Treasurers, finance or fiscal
officers or business managers employed by any County, City or local district or Municipal
Corporation of this state. The term of each appointment is two years or at the pleasure of the
appointing authority.
All securities are purchased under the authority of the Government Code Section 16430 and
16480.4. The State Treasurer's Office takes delivery of all securities purchased on a delivery
versus payment basis using a third party custodian. All investments are purchased at market, and
market valuation is conducted monthly.
Additionally, the PMIA has Policies, Goals, and Objectives for the portfolio to make certain that
our goals of Safety, Liquidity and Yield are not jeopardized and that prudent management
prevails. These policies are formulated by investment staff and reviewed by both the PMIB and
the LIAB on an annual basis.
The Bureau of State Audits on an annual basis audits the State Treasurer's Office. The resulting
opinion is posted to the State Treasurer's Office website following its publication. The Bureau of
State Audits also has a continuing audit process throughout the year. The State Controller's
Office as well as an in-house audit process involving three separate divisions audit all investment
and LAIF claims on a daily basis.
There is a limitation of $65 million per legal entity within an agency. There is also a maximum
of fifteen transactions, deposits or withdrawals per month.
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SONOMA COUNTY INVESTMENT POOL
The Sonoma County Treasurer maintains an investment pool in which the County, Schools,
Special Districts and Cities can participate. This investment pool operates in the same manner as
the State pool. The County Treasurer is subject to the same State Government Code regarding
investments as the City. As with the State investment fund, City funds can be withdrawn at any
time and are protected by State Law from seizure or impoundment by any County Officer. The
City does not participate in this pool but retains the option to do so.
CALIFORNIA ASSET MANAGEMENT PROGRAM (CAMP)
CAMP provides California public agencies, together with any bond trustee acting on behalf of
such public agency, assistance with the investment of and accounting for bond proceeds and
surplus funds. For bond proceeds, the objective of CAMP is to invest and account of such
proceeds in compliance with arbitrage management and rebate requirements of the Internal
Revenue Service. The program includes the California Asset Management Trust, a California
common law trust organized in 1989. The Trust currently offers a professionally managed
money market investment portfolio, the Cash Reserve Portfolio, to provide public agencies with
a convenient method of pooling funds for temporary investment pending their expenditure. The
Trust also provides record keeping, custodial and arbitrage rebate calculation services for bond
proceeds. As part of the program, public agencies may also establish individual, professionally
managed investment accounts.
The Pool seeks to attain as high a level of current income as is consistent, with the preservation of
principal. The Pool purchases only investments of the type in which public agencies are
permitted by statute to invest surplus funds and proceeds of their own bonds.
CERTIFICATES OF DEPOSITS (CD)
Certificates of Deposits, sometimes known as "Jumbo Accounts" or "Fixed CD's" are savings
accounts with Banks or Savings and Loans. These accounts are for a specific amount, have a set
interest rate, and set maturity date. There is a substantial interest penalty if the CD is withdrawn
prior to the maturity date.
The State law requires Public Fund CD's to be collateralized by the financial institution at 110%
with US Government notes/bonds or at 150% with quality First Trust Deeds. This collateral can
be waived if Federal Insurance (FDIC) is available. These federal agencies will insure each
account up to $250,000.
The City generally waives the collateralization requirements for the FDIC insurance. The waiver
of collateral is a wide spread practice and will generally generate higher interest rates and provide
the greatest security for the funds from the Federal Insurance Agencies. For deposits in excess of
$250,000, the collateralization requirements are not waived. A Placement Service such as
Certificate of Deposit Account Registry Service (CDARS) is a combination of Certificates of
Deposits managed by a single bank that can access multi-million dollars in FDIC coverage on
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CD investments made through a single bank relationship. The single bank relationship means
avoiding tracking collateral on an ongoing basis, requiring surety bonds, or working directly with
multiple banks.
BANKERS ACCEPTANCES (BA)
A Banker's Acceptance is a time draft of invested funds, which has been drawn on and accepted
for repayment by a bank. This financial instrument is generally used for short term (30 and 180
days) financing of export, import, or storage of goods. By accepting the draft (investment of City
funds), the bank is liable for the payment at maturity. This bank liability makes the Banker's
Acceptance a marketable investment. The State Code limits BA's to not more than 180 days to
maturity and 40% of the local agency's portfolio. In addition, not more than 30% of the local
agency's portfolio may be placed in any one bank.
US TREASURY BILLS
Commonly referred to as T -Bills, these are short-term marketable securities sold as obligations of
the US Government. They are offered in three month, six month, nine month and one-year
maturities. T -Bills do not accrue interest but are sold at a discount, and pay the face value at
maturity.
US TREASURY NOTES
These are marketable, interest-bearing securities sold as obligations of the US Government with
original maturities of one to ten years. Interest is paid semi-annually.
US TREASURY BONDS
These are the same as US Treasury Notes except they have original maturities of ten years or
longer.
FEDERAL AGENCY ISSUES
Many Federal Government Agencies are authorized to issue short term and long term obligations
that are used to finance various programs such as home loans, business loans, farm loans, etc.
These Agencies were created by the Federal Government in the 1930's and have since become
independent quasi -public agencies. The security for their issues is the guarantee of the Agency to
pay. The Federal Government has only an implied liability to the extent that the Agency has an
open credit line to borrow from the U.S. Treasury. It is widely accepted that Federal Agency
issues are almost as secure as U.S. Government notes.
There is an active secondary market available to sell these issues prior to maturity. The issues
are fairly liquid depending on the prevailing market interest rates at the time of sale. Some of the
more common agency notes are issued by the Federal National Mortgage Association (Fannie
Mae), Federal Home Loan Banks, Federal Home Loan Mortgage Corporation (Freddie Mae), and
the Federal Farm Credit Banks.
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