HomeMy WebLinkAboutResolution No. 2013-24 RESOLUTION NO.R2013-24
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF FRIENDSWOOD, TEXAS, APPROVING THE PUBLIC
FUNDS MANAGEMENT AND INVESTMENT POLICY.
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF FRIENDSWOOD,
TEXAS:
Section 1. The Public Funds Management and Investment Policy attached hereto and made a
part hereof for all purposes be, and it is hereby, approved as the Official Public Funds
Management and Investment Policy of the City of Friendswood, Texas.
Section 2. The City Secretary is hereby directed to place on said Investment Policy an
endorsement, which shall be signed by the City Secretary, which shall read as follows:
"The Investment Policy of the City of Friendswood, Texas,
approved by City Council the 2nd day of December 2013"
Such Investment Policy, as thus endorsed, shall be kept on file in the office of the City Secretary
as a public record.
PASSED,APPROVED, AND RESOLVED, this the 2nd day of December, 2013.
Kevin M. 14161 and
Mayor
ATTEST: pp
°• ` V °
Melinda Welsh, TRMC
City Secretary
eN y:
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CITY OF FRIENDSWOOD, TEXAS
INVESTMENT POLICY
December 2,2013
I. Policy - It is the policy of the City of Friendswood that, giving due regard to the safety
and risk of investment, all available funds shall be invested in conformance with these
legal and administrative guidelines. The City' s portfolio shall be designed and managed
in a manner responsive to the highest public trust and consistent with this policy.
Investments shall be made in a manner which will provide the maximum security of
principal invested through limitations and diversification while meeting the daily cash
flow needs of the City. The receipt of a market rate of return will be secondary to the
requirements for safety and liquidity. This policy will adopt passive investment
strategies designed to minimize administrative expenses while obtaining market-average
rates of return and incurring minimal risks. It is the intent of the City to be in complete
compliance with local law and the Texas Public Funds Investment Act.
II. Scope - This investment policy applies to all financial assets and funds placed for
investment by the City. The City commingles its funds for investment purposes for
efficiency and investment opportunity. These funds are defined in the City' s
Comprehensive Annual Financial Report (CAFR) and include:
General Fund
Special Revenue Funds
Debt Service Funds
Enterprise Funds
Trust and Agency Funds
And any new funds created by the City, unless specifically exempted by the City Council
and this policy.
Investment income will be allocated to the various funds based on their respective
participation and in accordance with generally accepted accounting principles. This
Investment Policy shall apply to all transactions involving the financial assets and related
activity for all the foregoing funds. However, this policy does not apply to the assets
administered for the benefit of the City by outside agencies under deferred compensation.
III. Objectives - The investment policy of the City shall be governed by these primary
objectives: safety, liquidity and yield. The suitability of each investment decision will be
made on the basis of these objectives.
A. Safety - The foremost objective of the investment program shall be to
assure the safety of the invested funds. Investments shall be undertaken in a
manner that seeks to ensure the preservation of capital while minimizing credit
rate and interest rate risk. Investment for speculation purposes is prohibited.
1. Credit Risk and Concentration of Credit Risk — The City will minimize
credit risk, the risk of loss due to the failure of the issuer or backer of the
investment, and concentration of credit risk, the risk of loss attributed to
the magnitude of investment in a single issuer.
2. Interest Rate Risk—the city will manage the risk that the interest earnings
and the market value of investments in the portfolio will fall due to
changes in general interest rates.
B. Liquidity - Funds will be invested with maturities necessary to maintain
sufficient liquidity to provide adequate and timely working funds.
C. Yield — Return on investment is of least importance compared to the
safety and liquidity objectives described above.
IV. Legal Limitations, Responsibilities and Investment Authority - Authority and
parameters for the investment of public funds in Texas are found in the Public Funds
Investment Act, Chapter 2256, Texas Government Code (the "Act').
The Interlocal Cooperation Act, Chapter 791, Texas Government Code,
authorizes local governments in Texas to participate in investment pools
established thereunder. That statute and reference to authorized investment in
investment pools in the Act, is primary authority for use of investment pools by
political subdivisions of the State of Texas.
V. Delegation of Investment Authority- The Director of Administrative Services is
designated as the Investment Officer of the City and is responsible for the
implementation of these policies, and for assuring that investment management
decisions and activities fully comply herewith. The Investment Officer shall
develop and maintain administrative procedures for the operation of the
investment program, which are in strict accordance with this investment policy, as
approved by the City Council. The Investment Officer shall comply with training
requirements of the Public Funds Investment Act. The investment training
session shall be provided by an independent source approved by the City Council
or Investment Cornmittee. An "independent source" from which investment
training shall be obtained shall include a professional organization, an institute of
higher learning or any other sponsor, other than a Business Organization with
whom the City may engage in an investment transaction. The Investment Officer
shall designate a staff person as a liaison/deputy in the event circumstances
require timely action and the Investment Officer is not available. The
appointment shall be approved by City Council. However, no officer or designee
may engage in an investment transaction except as provided under the terms of
this policy and the procedures established by the Investment Officer and approved
by the City Manager.
VI. Standards of Care - To be observed.
As fiduciaries of the City's assets, City Council retains ultimate responsibility of
the investment portfolio.
A. Prudence The standard of prudence used by the City of
Friendswood shall be the "Prudent Person Rule" and shall be applied in
the context of managing the overall portfolio. This standard states: "the
person designated as Investment Officer shall exercise the judgment and
care, under prevailing circumstances, that a prudent person would exercise
in the management of the person's own affairs." In determining whether
the Investment Officer has exercised prudence with respect to an
investment decision, the determination shall be made taking into
consideration:
1. The investment of all funds under the City' s
control, over which the officer had responsibility; and
2. Whether the investment decision was consistent
with the written investment policy of the City.
B. Ethics - 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, in writing, any material interests, including personal business
relationships, with any financial institution with which it is proposed that the City
conduct business. For the purposes of this section, an investment officer has a
personal business relationship with a business organization if: (1) the investment
officer owns 10 percent or more of the voting stock or shares of the business
organization or owns $5,000 or more of the fair market value of the business
organization; (2) funds received by the investment officer from the business
organization exceed 10 percent of the investment officer' s gross income for the
previous year; or (3) the investment officer has acquired from the business
organization during the previous year investments with a book value of$2,500 or
more for the personal account of the investment officer.
C. Liquidity - To meet the investment objectives of the City, the maturity of
investments shall be targeted to coincide with the cash flow needs of the City.
Funds of the City shall be invested in instruments whose maturities do not exceed
approved periods as determined by their policy. Unless matched to a specific
requirement, the Investment Officer may not invest more than 30% of the
portfolio for a period greater than two (2) years. The Investment Officer may not
invest in any portion of the portfolio for a period greater than three (3) years.
D. Diversification - The investment portfolio shall be diversified to minimize
the risk of loss resulting from over-concentration of assets in a specific maturity,
specific issuer or specific class of securities. Nevertheless, the City recognizes
that in a diversified portfolio, occasional measured interest losses are inevitable,
and must be considered within the context of the overall portfolio' s investment
return. At a minimum, diversification standards by security type and issuer shall
be:
Security Tyne Maximum% of Portfolio
U.S. Treasuries& securities with the
U.S. Government's guarantee Not To Exceed 75%
U.S. Government Agencies and
instrumentalities Not To Exceed 75%
Certificates of Deposit Not To Exceed 75%
Money Market Funds Not To Exceed 30%
Local Government Investment Pools Not To Exceed 75%*
*(No more than 50% shall be invested in any single pool.)
E. Yield - The core of investments shall be limited to relatively low risk securities in
anticipation of earning a fair return relative to the risk being assumed. The
earnings fiom investments shall be used in a manner that best serves the public
trust and interests of the City in compliance with applicable covenants or other
legal restrictions.
F. Safekeeping and Custody -To protect against potential fiaud and embezzlement,
the cash and investments of the City of Friendswood shall be secured by the City,
or through third party custody and safekeeping procedures as herein designated.
The third party custodian shall be required to issue safekeeping receipts to the
City listing each specific security, description, maturity, cusip number, yield
and/or coupon and other pertinent information. Each safekeeping receipt shall
clearly indicate that the instrument is held for the City of Friendswood. All
safekeeping arrangements shall be documented by the Investment Officer.
All investment transactions shall be executed on "delivery vs. payment" basis to
ensure that securities are deposited in the eligible financial institutions prior to the
release of finds.
VII. Internal Controls - The City Council shall establish an annual process of independent
review by an external auditor. This review shall provide internal control by assuring
compliance with policies and procedures.
VIII. Investment Committee -Upon adoption of this policy an Investment Committee shall be
established. Members include three unpaid private sector financial professionals
(example: banker, broker, CPA) appointed by the City Council to serve staggered three-
year terms. The Investment Committee shall serve in an advisory capacity only. The
Committee shall perform such duties assigned to it by this Policy and such other duties as
may, from time to time, be assigned to it by the City Council.
The Investment Committee shall meet at least quarterly. It may meet more often as
desired. Two members may request a meeting. Two members constitute a quorum.
The Investment Committee is charged with the duty of determining general investment
strategies for the City and monitoring results. It shall include in its deliberations such
topics as economic outlook, investment strategies, portfolio diversification and maturity
structure, potential risks to City funds, the target rate of return on the investment portfolio
and annual review of authorized depositories, brokers/dealers.
IX. Authorized Investments - Specific security instruments are authorized under the
provisions of the Public Funds Investment Act. The conservative philosophy employed
by the City is to choose investments in a manner which ensures safety, while promoting
diversity of market sector and maturity. The choice of high-grade government
instruments is designed to provide for the safety of principal, return an acceptable yield
and assure marketability. City funds may be invested in the following:
A. Obligations of the U.S. Government, its agencies and instrumentalities and
government sponsoring enterprises (GSEs), not to exceed three (3) years to stated
maturities, excluding collateralized mortgage obligations (CMOs).
B. Certificates of deposit or other financial institution deposits issued by a
depository institution that has its main office or a branch office in Texas,
guaranteed or insured by the Federal Deposit Insurance Corporation, or
collateralized, in accordance with Section 2256.010, the Texas Government Code,
and not to exceed three (3) years to stated maturity. Both principal and interest
earned on the investment will be guaranteed, insured or collateralized as stated
above.
C. No-load money market mutual Rinds that are registered and regulated by
the Securities and Exchange Commission subject to the limitations contained in
Section 2256.014, Texas Government Code.
D. Local Government Investment Pools, such as TexPool Investment Pool
(TexPool), Lone Star Investment Pool (LSIP) and Texas CLASS investment pool,
provided such pools comply with Chapter 2256, Sections .016, .017, .018 and
.019, Texas Government Code.
E. Commercial Paper in accordance with Section 2256.013, of the Local
Government Code. The stated maturity must be 270 days or fewer from the date
of its issuance, rated not less than A-1 or P-1 or an equivalent rating by at least
two nationally recognized credit rating agencies or one national recognized credit
rating agency and is fully secured by an irrevocable letter of credit issued by a
bank organized an existing under the laws of the United State or any state.
X. Loss of Required Minimum Rating - All prudent measures, consistent with the City's
investment policy, will be exercised to liquidate investments downgraded below the A-1
or P-1 required by this policy.
XI. Existing Investment Exemption — The City is not required to liquidate an investment
which was an authorized investment type at the time of purchase.
XII. Authorized Financial Dealers and Institutions - The Investment Officer shall maintain
a list of financial institutions authorized to provide investment services. In addition, a list
shall also be maintained of approved security broker/dealers selected by credit worthiness
who are authorized to provide investment services in the State of Texas. These may
include primary dealers or regional dealers that qualify under Securities & Exchange
Commission Rule 150-1 (uniform net capital rule).
All financial institutions and broker/dealers who desire to become qualified bidders for
investment transactions must supply the Investment Officer with the following: audited
financial statements, proof of National Association of Security Dealers certification and
proof of state registration.
A written copy of the investment policy shall be presented to any person offering to
engage in an investment transaction with the City. For purposes of this subsection, "a
business organization includes investment pools. The qualified representative of the
business organization offering to engage in an investment transaction with" the City
"shall execute a written instrument" (Exhibit "A") "to the effect that the business
organization has: (1) received and reviewed the investment policy of the City; and (2)
acknowledged that the business organization has implemented reasonable procedures and
controls in an effort to preclude investment transactions conducted between" the City
"and the organization that are not authorized by"the City's "investment policy, except to
the extent that this authorization is dependent on an analysis of the makeup of the City' s
"entire portfolio or requires an interpretation of subjective investment standards."
XIII. Competitive Bidding Requirement - Securities and certificates of deposits may be
purchased or sold only after a reasonable review of the offers/bids, to verify that the City
is receiving fair market value/price for the investment. Comparison of investment pools
will occur to confirm that the City receives fair market value/return on investments.
XIV. Methods to Monitor the Market Price of Investments - The market price of
investments acquired with public fiends will be monitored through one of the following
methods: (1) accessing financial information provided by the safekeeping custodian via
communication software; (2) obtaining pricing information as provided in financial
publications, such as the Wall Street Journal; and (3) obtaining pricing information from
qualified broker/dealers or financial institution representatives.
XV. Reporting - The Investment Officer shall prepare and submit to the City Manager and
City Council a quarterly report of investment transactions for all funds of the City.
Quarterly investment reports will be reviewed annually by an independent auditor. The
report shall include all information as required by Section 2256.023 of the Act.
XVI. Limitation of Personal Liability - The Investment Officer and those delegated
investment authority under this policy, when acting in accordance with the written
procedures and this policy and in accord with the Prudent Person Rule, shall be relieved
of personal responsibility and liability in the management of the portfolio provided that
deviations from expectations for a specific security's credit risk or market price change
or portfolio shifts are reported in a timely manner and that appropriate action is taken to
control adverse market effects.
XVIL Investment Strategy - The City of Friendswood shall maintain a portfolio which
involves investment strategy considerations, designed to address the unique
characteristics of the fund groups represented in the portfolio. The objectives of each
fund group must be considered in context of the structure of the overall portfolio.
A. Operating Funds - Investment strategies for operating funds have as their
primary objective to assure that anticipated cash flows are matched with adequate
investment liquidity. The secondary objective is to create a portfolio structure
which will experience minimal volatility during economic cycles. This may be
accomplished by purchasing high quality, short to medium term securities which
will complement each other.
B. Capital and Special Projects Funds - Primary strategy for these fund
types is to assure that anticipated cash requirements are matched to ensure
adequate liquidity at the time of payment. A portion of investments (at least 10%)
should be highly liquid to allow for flexibility and unanticipated project outlays.
The stated final maturity date of any security held should not exceed the estimated
project completion date.
C. Debt Service Fund - Investment strategies for debt service funds will
have as their primary objective the assurance of investment liquidity adequate to
cover the debt service obligation on the required payment date.
D. Overall Short-term Strategy - The City uses a consolidated cash system
for cash and investments where cash is commingled and ownership tracked by
equity accounts. From this a considerable amount is available for investment in a
highly liquid local government investment pool. Interest earnings are apportioned
back based on equity in the pool. Use of the pool enables short-term interfund
borrowing during the course of the year using "due-to/due-from" accounting
methodology. This gives considerable flexibility to the immediate cash needs of
an individual fund.
E. Bond Proceeds - Exclusive of all other City investments, up to 100% of the
proceeds from a bond sale may be invested in a separate pooled (LGIP) account,
and are not subject to the liquidity and diversification limitations found elsewhere
in this policy.
XVIII. Intent - It is the stated intent of this Policy to adhere by and to be in conformance with
the statute known as the Public Funds Investment Act, Chapter 2256, Texas Government
Code, as amended by House Bill 2799 enacted by the 75th Texas Legislature. Specific
interpretation of a section contrary to this intent shall not void the remaining Policy.
XIX. Adoption - This Investment Policy shall be formally adopted by Resolution of the City
Council. The Policy shall be reviewed on an annual basis by the City Manager and City
Council.
TEXAS PUBLIC YUNDS INVESTMENT ACT
CERTIFICATION BY BUSINESS ORGANIZATION
This certification is executed on behalf of the City of Friendswood(the Investor)and
Bose, Inc. (the Business Organization)pursugnt to the Public
Funds Investment Act,Chapter 2256,Texas Government Cade(the A01),in connection with
investment transactions conducted between the Investor and the Business Organization,
The undersigned Qualified Representative of the Business Organization hereby certifies on
behalf of the Business Organization that:
1. The undersigned is a Qualified Rcprosentativoo£theBushless Organization,offering to
enter in oninvostment transaction with the Investor as such terms are used in the Public
Funds Investment Act,Chapter 2256,Toxas Government Code,and
2, The Qualified Representative of the Business Organization has received and reviewed the
Investment Policy furnished by the Investor;and
3, The Qualified Representative of the Business Organization has implemented reasonable
procedures and controls in an effort to preclude investment transactions conducted
between the Business Organization and the Investor that are not authorized by the City of
FriendswoodI a Investment Policy,except to the extent that this authorization is
dependent on an analysis of the makeup of the City's entire portfolio or requires an
interpretation of subjective investment standards.
Qualified Itepresentative of the Business Organization
Signature:
Name: A
Title;
Date;
Page 9
COASTAL SECURI'T`IES, INCO
www.eonstslseeurities.com
TE,XA.S PUBLIC FUNDS INVESTMENT ACT
CE,RTIFICAT ION BYBUSINI;SS ORGANIZATION
This certification is executed on behalf of the City of Friendswood(the Llvestot)and
Coastal Securities, LTn __.(the Business Organization)pursuant to the Public
Funds Investment Act,Chapter 2256,Texas Govermnent Code(the Act),in connection with
investment transactions conducted between the Investor and the Business Organization.
The undersigned Qualified Representative of the Business Organization hereby certifies on
behalf of(lie Business Organization that:
1, The undersigned is a Qualified Representative of the Business Organization offering to
enter in au investment(ransaction with the Investor as such terms are used in the Public
Funds Investment Act, Chapter 2256,Texas Government Code; and
2, The Qualified Representative of the Business Organization has received and reviewer[the
Investment Policy furnishes(by the Investor;and
3, The Qualified Representative of the Business Organizationhas implemented reasonable
procedures and controls in an effort to preclude investment transactions conducted
between the Business Organization and the Investor that are not authorized by the City of
Friendswood,s investment Policy,except to the extent that this authorization is
dependent on an analysis of the makeup of the City,s entire portfolio or requires an
interpretation of subjective investment standards.
Qualified Representative of the Business Organization
Nance: Tony D. Sehaly
Title: Managing Director- Fixed Income Securities
Date: January 21, 2014
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Aft3 RER FlNA/SIPC 920 ATFmomi CITY w,tY•11"11kom.HoumN,rrP„ s 77024
HouTON.AUSTIN.SAN Awomo.NEw ORLEANS PROW:713-435-4300.800-489-3232
TEXAS PUBLIC FUNDS INVESTMENT ACT
Cii ATIFICATION BY BIISINBSS ORGANIZATION 3
This certification is executed on behalf of the City of Friondswood(tho Investor)and
First Southcveet Company (the Business Organization)pursaal?ito tile Public
Funds Investment Act, Chapter 2256,Texas Govermnent Code(the Act),in connecflon with
investment transactions conducted between the Investor and the Business Organization.
The undersigned Qualified Reprosontative of the Business Organization hereby certifies on
behalf of the Business Orgatdzatioa that:
1. The undersigned is a Qualified Representative of the Business Organization offering to
enter in an Investment transaction will,tho Investor as such terms are used in the Public
Funds Investment Act,Chapter 2256,Texas Oiovernmont Code,and
2. The Qualified Representative of the Business Ohgattiration has received and reviewed the
Investment Policy ftnnished by the Investor;and
3. The Qualified Representative of the Business Organization has implemented reasonable
procedures and controls in an effort to preclude investment transactions conducted
between the Business Organization and the Investor that are not authorized by the City of
Friendswood,s Investment policy,except to the extent that this authorization is
dependent on an analysis of the makeup of the City,s entire portfolio or requires an
interpretation of subjective investment standards,
i
Qualified Representative of the Business Organization
Signature: 44—ea—la�-�
Natno: Linda Callaway
Title: Senior Vice Msident
Date: March 24, 2014
Page 9
Bxhibit A
TEXAS PUBLIC FUNDS INVUSTMIINT ACT
CERTIFICATION BY BUSINESS ORGANIZATION
This certification is executed on behalf of the City of Priendswood(the Investor)and
Wells Fargo Securities LLC (the Business Organization)pursuant to the Public
Funds Investment Act,Chapter 2256,Texas Government Code((be Act),in connection with
investment transactions conducted between the Investor and the Business Organization,
The undersigned Qualified Representative of the Business Organization hereby certifies on
behalf of the Business Organization that:
I. The undersigned is a Qualified Representative of the Business Organization offering to
enter In an Investment transaction with the Investor as such terms are used in the Public
Funds Investment Act, Chapter 2256,'I'exas Government Code; and
2• The Qualified Representative of the Business Organization has received and reviewed the
Investment Policy furnished by the Investor;and
3, The Qualified Representative of the Business Organization has implemented reasonable
procedures and controls in an effort to preclude investment transactions conducted
between the Business Organization and the Investor that are not authorized by the City of
Frfendswood I s hrvesgnent Policy,except to the.extent that this authorization is
dependent on an analysis of the makeup of the City,s entire portfolio or requires an
interpretation of.subjective investment standards.
Qualified Representative of the Business Organization
Signature:.
Name: Teresa M. Yancey
Title: Director, Regional Sales Manager
Date: 03/25/14
Page 9
Federated
r�YJl!n� �viJ/� WOAUO-CLASS I�ESTM9NT MANAGEA
An 6wentmnn Abrv,rc for PuAl,c Flubix
TEXAS PUBLIC FUNDS INVESTMENT ACT
ACKNOWLEDGE,ME NT AND CERTIFICATION
OF INVESTMENT POLICIES
This Acknowledgement and Certification is executed on behalf of the Texas Local Government
Investment Pools,TexPool and TexPool Prime(collectively, "TexPool"),and Federated Investment
Counseling, as investment adviser to TexPool("Adviser"),pursuant to Section 2256.005(k),Texas Government
Code, in connection with investment transactions conducted between the City of Friendswood("Investing
Entity") and TexPool.
The undersigned,who is a qualified representative of both TexPool and Adviser(the"Qualified
Representative")hereby certifies on behalf of TexPool and Adviser that, as of the date of this letter:
(i.) The Qualified Representative is duly authorized to execute this Acknowledgment and
Certification on behalf of TexPool and Adviser; and
(ii.) The Qualified Representative has received and reviewed the Investing Entity's investment policy
attached hereto as Exhibit A(the"Policy"); and
(iii.) TexPool and Adviser have implemented reasonable procedures and controls in an effort to
preclude investment transactions conducted between the Investing Entity and TexPool that are
not authorized by the Policy,except to the extent that this authorization is dependent on an
analysis of the makeup of the Investing Entity's entire portfolio or requires an interpretation of
subjective investment standards.
TEXPOOL FEDERATED INVESTMENT COUNSELING
�Ll
rgnature: Steven A. Aiedman ignature: Steven A,Friedman
Authorized Signatory Assistant Vice President
Date:_ t r zo `'r Date: ) -.,-4 \ ae 5 -A-
i
TEXAS PUBLIC FUNDS INVESTMENT ACT
CERTIFICATION BY BUSINESS ORGANIZATION
i
This certification is executed oil behalf of the City ofFriendswood(the Investor)and
Texas CLASS (the Business Organization)pursuant to thepublie
Funds Investment Act,Chapter 2256,Texas Government Code(the Act),in connection with
investuenttransaetions conducted behveen due Investor and the Business Organization,
The undersigned QuallfiedRepresantative of the Business Organization heroby certifies on
behalf of the Business Organization that:
1, The undersigned is a Qualified Representativo of the Business Organization offering to
enter in an Investment transaction with tine Investor as such terms are used in file Public
Funds hivestmentAct,Chapter 2256,Texas Government Code;and
2• The QUalifted Representative of theBusiness Orgaaizatiolr has received attd reviewed the
luvestment Policy furnished by tine lrvestor;and
3. The Qualified Representative of the Business Organization has fniplemented reasonable
procedures and controls in all effort to preclude Investment transactions conducted
between the Business Organization and file Investor that are not authorized by tine City of
Friendswood's investment Policy,oxcepttotile extent that this authorization is
dependent on all analysis of the makeup of tile City's entire portfolio orrequires an
interpretation of subjective investment standards,
Qualified Representative of the Business Organization
greg.wrighwpublictrust
advfsors.com
$lgnatllt'e: .= w�ezn�anxwi¢i¢s�mw
Naurc: Greg Wright
Title: Texas CLASS Administrator
Date: 2/4/14
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