HomeMy WebLinkAboutResolution No. 2019-31 RESOLUTION NO. R2019-31
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 City Council has reviewed 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. The
Policy shall record any changes made to the Policy previously adopted.
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 7th day of October 2019"
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 7th day of October 2019.
/
ike For, an
Mayor
ATTEST:
4 0
Melinda Welsh, TRMC 00
City Secretary
ar
•. .•
CITY OF FRIENDSWOOD, TEXAS
INVESTMENT POLICY
October 7,2019
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.
3. Collateralization — The City requires collateralization of all uninsured
collected balances of invested funds and any accrued interest on funds
invested; acceptance, substitution, release and valuation of collateral for
City investments shall be in accordance with the Public Funds Collateral
Act, Chapter 2257, Texas Government Code.
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 and Liaison/Deputy Investment
Officer shall comply with training requirements of the Public Funds Investment Act
(PFIA). Investment Officer(s) must obtain 10 hours of PFIA training within 12
months of assuming investment responsibilities and 8 hours of PFIA training every
two years thereafter. The investment training session shall be provided by an
independent source approved by the City Council or Investment Committee. 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 Deputy Director of Administrative Services—Finance
shall serve as designated liaison/deputy investment officer in the event
circumstances require timely action and the Investment Officer is not available.
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, to the Texas Ethics Commission and the City's governing body, 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. In accordance with Texas Government Code 573 and for the
purposes of this section, if Investment Officer(s)is related within the second degree
by affinity or consanguinity to an individual seeking to transact investment business
with the City, the Investment Officer(s) will file a disclosure statement of this fact
in writing with the Texas Ethics Commission and the City's governing body.
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 Type 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 from 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 fraud 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 funds.
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. Compliance and management controls of the
City's investment policy will be included in this annual review.
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 and approval 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 only 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 its successor), or
collateralized, in accordance with Section 2256.010, the Texas Government Code F_
and Chapter 2257 the Public Funds Collateral Act, 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.
C. No-load money market mutual funds 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,.019 and
.0204, Texas Government Code.
E. Commercial Paper in accordance with Section 2256.013, of the Local
Government Code. The stated maturity must be 365 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—Rating status of investments of the City's portfolio
will be reviewed quarterly by the Investment Officer(s). 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 15 C3-1 (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 registration with Financial Industry Regulatory Authority
(FINRA) 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. At least three (3) competitive
offers/bids must be obtained prior to purchase or sell of securities and certificates of
deposits. 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 funds 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. Market value of the City's investments will be
reviewed and calculated on a monthly basis. The quarterly investment report will include
the market value of the portfolio.
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.
XVII. 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 — In accordance with Section 2256.0208, 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
highly liquid local government investment pools. 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. In addition, the City's portfolio will have a maximum dollar-
weighted average maturity of 3 years or less based on the stated maturity date (if
applicable) of each investment.
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.
F. Performance Benchmarks—Comparative data such as coupon rates,market price,
market value, interest rates and rating agencies will be used to gauge performance
of the City's investment portfolio.
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.
Exhibit A
TEXAS PUBLIC FUNDS INVESTMENT ACT
CERTIFICATION BY BUSINESS ORGANIZATION
This certification is executed on behalf of the City of Friendswood (the Investor) and
(the Business Organization)pursuant to the Public
Funds Investment Act, Chapter 2256, Texas Government 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 the Business Organization that:
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, Texas Government Code; and
The Qualified Representative of the Business Organization has received and reviewed the
Investment Policy furnished by the Investor; and
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.
Qualified Representative of the Business Organization
Signature:
Name:
Title:
r
Date:
LIST OF AUTHORIZED DEPOSITORIES AND QUALIFIED BROKERS
AUTHORIZED TO ENGAGE IN INVESTMENT TRANSACTIONS
WITH THE CITY OF FRIENDSWOOD
1. BOK Financial Securities, Inc.
2. FTN Financial Securities Corporation
3. Hilltop Securities
4. Wells Fargo Brokerage Services, LLC
5. Wells Fargo Bank
6. Lonestar Investment Pool
7. TexPool
8. Texas Class
9. Cantor Fitzgerald& Company
The above list of broker/dealers and financial institutions were approved by the Investment
Committee at a regular meeting, and are qualified to engage in investment transactions with the
City of Friendswood, as required by the Texas Public Funds Investment Act, Chapter 2256,
Section .025.
Name: Katina Hampton, Investment Officer
Date: October 7, 2019
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