7569-06
ORDINANCE NO. 7569-06
AN ORDINANCE OF THE CITY OF CLEARWATER,
FLORIDA AMENDING THE CITY OF
CLEARWATER POOLED CASH INVESTMENT
POLICY; PROVIDING AN EFFECTIVE DATE.
WHEREAS, the City of Clearwater has established the Poled Cash
Investment Policy; and
WHEREAS, the City has authority to amend the policy as permitted by
law; and
WHEREAS, the City has determined that it is in the best interest of the
City to amend the Pooled Cash Investment Policy; now therefore
BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF
CLEARWATER, FLORIDA
Section 1: The Pooled Cash Investment Policy is hereby amended to
read as follows:
(1) SCOPE
The statement of investment policy and guidelines applies to all investments
of the City's pooled cash, which includes cash and investment balances of the
following funds:
. General
. Special Revenue
. Debt Service
. Capital Projects
. Enterprise
. Internal Service Funds
. Trust Funds
The policies set forth do not apply to the Employee Pension and Deferred
Compensation Funds of the City of Clearwater, deposits for defeased debt, or
assets under Bond Trust Indenture Agreements.
Ordinance No. 7569-06
(2) INVESTMENT OBJECTIVES
A. Safety of principal is regarded as the highest priority in the handling of
investments for the City. All other investment objectives are
secondary to the safety of capital. Each investment transaction shall
seek to first ensure that capital losses are avoided.
From time to time, however, securities may be traded for other similar
securities to improve yield, maturity or credit risk. For these
transactions, a loss may be incurred for accounting purposes,
providing any of the following occurs with respect to the replacement
security:
· The yield has been increased, or
· The maturity has been reduced, or
· The quality of the investment has been improved
B. The City's investment strategy will provide sufficient liquidity to meet
the City's operating, payroll and capital requirements. To accomplish
this the portfolio will be "Iaddered" with maturates each month except
for those months in which significant Ad ValOrem taxes are received.
To the extend possible, the City will attempt to match its investments
with anticipated cash flow requirements. Unless matched to a
specific cash flow requirement, the City will not directly invest in
securities maturing more than 15 years from the date of purchase.
And unless, specifically matched against a debt or obligation not
more than 10% of the portfolio will have maturity greater than 10
years.
C. The City's investment portfolio shall be designed with the objective of
attaining a market rate of return throughout budgetary and economic
cycles, taking into account the City's investment risk constraints and
the cash flow characteristics of the portfolio.
(3) PERFORMANCE MEASUREMENT
The benchmark yield for the operating portfolio will be the weighted average
yield determined by using the following maturity distribution and the related U.S.
Treasury yields. Treasury yields are considered benchmark for risk less investment
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Ordinance No. 7569-06
transactions and, therefore comprise a minimum standard for the operating
portfolio's rate of return. The investment program shall seek to augment returns
above this threshold, consistent with risk limitations identified herein.
Average Treasury Rates Percentage Distribution
Overnight rate
3 month Treasury Bill rate
6 month Treasury Bill rate
1 year Treasury Bill rate
3 year Treasury Note rate
5 year Treasury Note rate
10 year Treasury Note rate
15 %
15 %
15%
15 %
15 %
15 %
10%
Total
100%
(4) PRUDENCE AND ETHICAL STANDARDS
The standard of prudence to be applied by the investment officer shall be
the "Prudent Person" rule, which states: "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 derived." The "Prudent
Person" rule shall be applied in the context of managing the overall portfolio.
(5) AUTHORIZED INVESTMENTS
1. The City shall limit investments, as authorized in Florida Statutes to:
a. Direct obligations of the United States Treasury. Investments in this
category would include but not be limited to the following: United
States Treasury Bills, Notes and Bonds, and securities issued by the
Small Business Administration, Government National Mortgage
Association (Ginny Mae), Veterans Administration, and Federal
Housing Administration.
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Ordinance No. 7569-06
b. Federal agencies and instrumentalities. Investments in this category
would include but not be limited to the following: obligations of the
Federal Home Loan Banks System (FHLB) or its distinct banks and
Financing Corporation (FICO), Federal Farm Credit Bank, Federal
National Mortgage Association (Fannie Mae), Federal Home Loan
Mortgage Corporation (Freddie Mac), Student Loan Marketing
Association (Sallie Mae), Financial Assistance Corporation and
Federal Agriculture Mortgage Corporation (Farmer Mac).
c. Securities and Exchange Commission registered money market
funds with the highest credit quality rating from a nationally
recognized rating agency.
d. Interest-bearing time deposits or savings accounts in qualified
public depositories as defined in Florida Statutes. 280.02.
e. Collateralized Mortgage Obligations (CMO) and/or Real Estate
Mortgage Investment Conduits (REMIC), with the highest credit
quality rating from a nationally recognized rating agency with an
estimated maturity and class or tranche not to exceed 7 years, which
are backed by securities otherwise authorized in this policy.
f. Repurchase Agreements and reverse repurchase agreements
collateralized by securities otherwise authorized in this policy.
g. The Local Government Surplus Funds Trust Fund or any
intergovernmental investment pool authorized pursuant to the Florida
Interposal Cooperation Act as provided in Florida Statutes. 163.01.
h. Securities of, or other interests in, any open-end or closed-end
management-type investment company or investment trust
registered under the Investment Company Act of 1940, 15 U.S.C.
ss. 80a-1 et seq., as amended from time to time, provided that the
portfolio of such investment company or investment trust is limited to
obligations of the United States Government or any agency or
instrumentality thereof and to repurchase agreements fully
collateralized by such United States Government obligations, and
provided that such investment company or investment trust takes
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Ordinance No. 7569-06
delivery of such collateral either directly or through an authorized
custodian.
I. Commercial paper issued by an entity listed above (I.E. FHLB,
FFCB FHLMC etc.) with an investment grade rating from a
nationally recognized rating agency.
6. Maturity and Liquidity Requirements
A. The City will attempt to forecast expected cash outflows and inflows
by major categories. For months that the outflows exceed inflows the
City will have investments maturing that month in excess of the
forecasted deficits.
B. As stated above the City will ladder it's maturates so that there are
maturates each month with the exception of months when the
majority of Ad valorem taxes are received.
C. The City will attempt to keep the weighted average maturity to three
years or less. Due to market conditions and cash needs the average
maturity may temporarily be greater than three years but no greater
than four years.
7. Portfolio Composition, Risk And Diversification
Assets held shall be diversified to control risk of loss resulting from
overconcentration of assets in a specific maturity, issuer, instrument, dealer, or
bank through which these instruments are bought and sold. Diversification
strategies within the established guidelines shall be reviewed and revised
periodically as necessary by the Investment Committee.
8. Authorized Investment Institutions and Dealers
A. Banks - Certificates of deposit purchased under the authority of this
policy will be purchased only from Qualified Public Depositories of
the State of Florida as identified by the State Treasurer, in
accordance with Chapter 280 of the State Statutes.
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Ordinance No. 7569-06
B. Broker/Dealer Approvals and Limitations - Time, practicality, and
general business constraints limit the number of investment
relationships which can be managed on a regular basis. In most
cases, normal investment activity will be limited to no more than ten
dealer relationships. A broker/dealer list will be established by the
Finance Director or designee. This list will be presented to the
Investment Committee for approval. This list will be updated as
needed and approved by the Investment Committee.
9. Third-Party Custodial Agreements
All securities purchased by the City under this policy shall be purchased
using the "delivery versus payment" procedure. For all purchases and sales of
securities the third-party custodial will be notified by fax of the transaction including
all details of the securities purchased or sold. The notification will be signed by two
individuals authorized to make investment decisions.
10. Master Repurchase Agreement
All approved institutions and dealer transacting repurchase agreements
shall be covered by a Master Repurchase Agreement. All repurchase agreement
transactions shall adhere to the requirements of the Master Repurchase
Agreement.
11. Bid Requirements
After the Finance Director or designee has determined the appropriate
maturity based on cash flow needs and market conditions and has selected one or
more optimal type of investment, the security in question shall, when feasible and
appropriate, be competitively bid. Competitive bids or offerings shall be received
from at least three dealers/brokers on all sales or purchases except in situations
where:
A. The security involves is a "new issue" and can be purchased "at the
auction" .
B. The security has a fixed "postal-scale" rate.
C. The security involved is available through direct issue or private
placement.
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Ordinance No. 7569-06
D. The security involved is of particular special interest to the entity and
dealer competition could have an adverse impact with respect to the price
and availability to the City.
It is also realized that in certain very limited cases the City will not be able to
get three quotes on a certain security. For those cases the City will obtain current
market prices one of the following to determine if the transaction is in the City's best
interest:
1. Bloomberg Information Delivery System.
2. Wall Street Journal or a comparable nationally recognized financial
publication providing daily market pricing.
3. Daily market pricing provided by the City's Custody Agent or their
corresponding institution.
12 Internal Controls
The Finance Director shall establish and monitor internal and procedural
controls designed to protect the City's assets and ensure proper accounting and
reporting of the transactions related thereto.
The Finance Director shall establish an Investment Committee that meets on
a regular basis for the purpose of reviewing investment transactions, approving
brokers/dealer changes and other investment activities.
13 Reporting
The Finance Director or designee shall report on at least an annual basis the
following information on the City's investments:
A. Securities by class/type.
B. Book Value
C. Market Value
D. Income Earned
Section 2: All ordinances or parts of ordinances, resolutions or parts of
resolutions in conflict herewith are herby repealed to the extent of such conflicts.
Section 3: This ordinance shall take effect immediately upon adoption.
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Ordinance No. 7569-06
PASSED ON FIRST READING
PASSED ON SECOND AND FINAL
READING AND ADOPTED
[eslie K. Douga - i
Assistant City Attorney
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December 15, 2005
January 19, 2006
-=t~ t( ~
~k V. Hibbard
Mayor
Ordinance No. 7569-06