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2022-R-34 - Investment Policy Amendment RESOLUTION NO. 2022-R-34 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EDGEWATER, FLORIDA, UPDATING THE CITY OF EDGEWATER'S INVESTMENT POLICY; REPEALING ALL RESOLUTIONS IN CONFLICT HEREWITH AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, pursuant to the City Charter, the City Manager has the responsibility for managing an investment program for the City; WHEREAS,the City Manager requests that City Council update the existing Investment Policy that the City of Edgewater approved during the Council meeting held on March 3, 2014 pursuant to the adoption of Resolution#2014-R-04. WHEREAS, in an effort to be consistent with current laws and policies, City Council wishes for the City of Edgewater to update/modify the existing City of Edgewater Investment Policy. NOW, THEREFORE, BE IT RESOLVED by the City Council..of the City of Edgewater, Florida: Section 1. The City Council hereby updates/modifies iLhe Cify :of 'Edgew—ater Investment Policy and all investments as provided for therein shall b6-invested--in accoFd'ance with said policy,a copy of which is attached and incorporated herein as Exhibit"A'%' Section 2. All conflicting investment policies are superseded by this policy. Section 3. All resolutions or parts of resolutions in conflict herewith are hereby repealed. (Resolution/#2022-R-34) Section 4. This resolution shall take effect upon adoption. After Motion to approve by 0CLtnOLUA Ferry-,n I k e-A with Second by I L';L e vote on this resolution was as follows: AYE NAY Mayor Mike Thomas X Councilwoman Christine Power Councilwoman Gigi Bennington Councilwoman Debbie Dolbow Councilman Jonah Powers k PASSED AND DULY ADOPTED this day of, ��l l- ,(,.OA , 2022. CITY COUNCIL OF THE CITY OF EDGEWATER, FLORIDA r''1 G'9 ; ti✓ Mika-Tho Mayor ATT-STI >a ( y • � r i�G`� .� Bonnie Zlotnik, MC City Clerk For the use and reliance only by the City of Edgewater, Florida Approved as to form and legality by: Aaron R.Wolfe,Esquire City Attorney Doran,Sims,Wolfe&Yoon Approved by the City C�tpil of the City of Edgewater at a meeting held on this H day of Novi_1a-e1 .2022 under Agenda Item No 8—j_ (Resolution/#2022-R-34) EXH WIT KA" (Resolution/#2022-R-34) Investment Policy City of Edgewater, Florida I Cl lv of ED G .R EWATE c. 1951 MaFGh Qr 2 ^November 14, 2022 Resolution No. 20114 R 042022-R-34 n. City of Edgewater?0442022 /100,*N. Table of Contents Page I. PURPOSE 3 II. SCOPE 3 III. INVESTMENT OBJECTIVES 3 IV. DELEGATION OF AUTHORITY 4 V. STANDARDS OF PRUDENCE 4 Vl. ETHICS AND CONFLICTS OF INTEREST 4 VII. INTERNAL CONTROLS AND INVESTMENT PROCEDURES 4 VIII. CONTINUING EDUCATION 5 IX. AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS 5 X. MATURITY AND LIQUIDITY REQUIREMENTS 5 XI. COMPETITIVE SELECTION OF INVESTMENT INSTRUMENTS 5 XII. AUTHORIZED INVESTMENTS AND PORTFOLIO COMPOSTION 6 XIII. PERFORMANCE MEASUREMENTS 12 XIV. REPORTING 13 XV. THIRD PARTY CUSTODIAL AGREEMENTS 13 XVI. INVESTMENT COMMITTEE 14 XVII. INTERNAL LOAN PROGRAM 14 XVIII. INVESTMENT POLICY ADOPTION 14 City of Edgewater Page 2 of 13 Investment Policy of the City of Edgewater, Florida I. PURPOSE The purpose of this Investment Policy (hereinafter"Policy") is to set forth the investment objectives and parameters for the management of the funds of the City of Edgewater, (hereinafter"City"). This Policy is designed to ensure the prudent management of public funds, the availability of operating and capital funds when needed, and an investment return competitive with comparable funds and financial market indices. II. SCOPE In accordance with Section 218.415, Florida Statues, this Policy applies to all cash and investments held or controlled by the City and shall be identified as"general operating funds"of the City with the exceptions of the City's Pension Funds and funds related to the issuance of debt where there are other existing policies or indentures in effect for such funds. Additionally, any future revenues, which have statutory investment requirements conflicting with this Policy and funds held by state agencies (e.g., Department of Revenue), are not subject to the provisions of this Policy. III. INVESTMENT OBJECTIVES Safety of Principal The foremost objective of this investment program is the safety of the principal of those funds within the portfolios. Investment transactions shall seek to keep capital losses at a minimum, whether they i''1 are from securities defaults or erosion of market value. To attain this objective, diversification is required in order that potential losses on individual securities do not exceed the income generated from the remainder of the portfolio. From time to time, 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 to achieve optimal investment return, provided any of the following occurs with respect to the replacement security: A. The yield has been increased,or B. The maturity has been reduced or lengthened, or C. The quality of the investment has been improved. Maintenance of Liquidity The portfolios shall be managed in such a manner that funds are available to meet reasonably anticipated cash flow requirements in an orderly manner. Periodical cash flow analyses will be completed to ensure that the portfolios are positioned to provide sufficient liquidity. Return on Investment Investment portfolios shall be designed with the objective of attaining a market rate of return throughout budgetary and economic cycles, taking into account the investment risk constraints and liquidity needs. Return on investment is of least importance compared to the safety and liquidity objectives described above. The core of investments is limited to relatively low risk securities in anticipation of earning a fair return relative to the risk being assumed. City of Edgewater Page 3 of 13 IV. DELEGATION OF AUTHORITY In accordance with the City's Charter, the responsibility for providing oversight and direction in regard to the management of the investment program resides with the CityL,, Manager. Responsibility for the administration of the investment program is hereby delegated by the City Manager to the Finance Director, who shall maintain an Investment Procedures and Internal Controls Manual based on this Policy. Specific investment responsibilities may be delegated to additional staff members by the City Manager or Finance Director. �No person may engage in an investment transaction except as authorized under the terms of this Policy. ismn 1 The Finance Director shall be responsible for monitoring internal controls, administrative controls and to regulate the activities of the City's staff involved with the investment program. The City may employ an Investment MaaageF-Advisor to assist in managing some of the City's portfolios. Such Investment Advisor Manager- ust be registered with the SEC under the Investment Advisors Act of 1940. V. STANDARDS OF PRUDENCE The standard of prudence to be used by investment officials shall be the "Prudent Person" standard and shall be applied in the context of managing the overall investment program. Investment officers acting in accordance with written procedures and this investment Policy and exercising due diligence shall be relieved of personal responsibility for an individual security's credit risk or market price changes, provided deviations from expectation are reported to the City Council in a timely fashion and the liquidity and the sale of securities are carried out in accordance with the terms of this Policy. The"Prudent Person" rule states the following: Investments shall be made with judgment and care, under circumstances then ^ prevailing, which persons of prudence, discretion and intelligence exercise in the management of their own affairs, not for speculation, but for investment, considering the probable safety of their capital as well as the probable income to be derived from the investment. While the standard of prudence to be used by investment officials who are officers or employees is the "Prudent Person" standard, any person or firm hired or retained to invest, monitor, or advise concerning these assets shall be held to the higher standard of "Prudent Expert". The standard shall be that in investing and reinvesting moneys and in acquiring, retaining, managing, and disposing of investments of these funds, the contractor shall exercise: the judgment, care, skill, prudence, and diligence under the circumstances then prevailing, which persons of prudence, discretion, and intelligence, acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of like character and with like aims by diversifying the investments of the funds, so as to minimize the risk, considering the probable income as well as the probable safety of their capital. VI. ETHICS AND CONFLICTS OF INTEREST Employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to impartial investment decisions. Also, employees involved in the investment shall disclose to the Investment Committee any material financial interests in financial institutions that conduct business with the City, and they shall further disclose any material personal financial/investment positions that could be related to the performance of the City's investment program VII. INTERNAL CONTROLS AND INVESTMENT PROCEDURES The Finance Director shall establish a system of internal controls and operational procedures that are in writing and made a part of the City's operational procedures. The internal controls should be City of Edgewater Page 4 of 13 designed to prevent losses of funds, which might arise from fraud, employee error, and misrepresentation by third parties, or imprudent actions by employees. The written procedures should include reference to safekeeping, repurchase agreements, separation of transaction authority from accounting and record keeping, wire transfer agreements, banking service contracts, collateralldepository agreements, and "delivery vs. payment" procedures. NG-pe ge4n as--i ^+ 2s authwized ^-ger-the—terMs of tb+s—Retic srn{2t. These procedures are intended to reduce the relatively low risk that material losses may occur and not be detected within a timely period by employees in the normal course of performing their assigned functions. Independent auditors as a normal part of the annual financial audit to the City shall conduct a review of the system of internal controls to ensure compliance with policies and procedures. VIII. CONTINUING EDUCATION The Finance Director management designee and/or appropriate staff shall annually complete 8 hours of continuing education in subjects or courses of study related to investment practices and products. IX. AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS A+Ahm;i=eCity staff and Investment Advisors shall only purchase securities fi +pm fiRanGial inst+tu}�s, WhiGhire—Qualified and '^ es}anent Financial Institutions approved by the City or institutions designated as "Primary Securities Dealers" by the Federal Reserve Bank of New York. }h, a ;City staff anInvestment Advisers shall only enter into repurchase agreements with °^^ a! st' ^s;hut—nualified Financial Institutions or aad Primary Securities Dealers as [sM(31designated by the Federal Reserve Bank of New York. The Finance Director, management designee and/or the Investment Advisors shall maintain a list of financial institutions and broker/dealers that are approved for investment purposes and only firms meeting the following will be eligible requirements to that qualify serve as Qualified Financial Institutions: 1) Regional dealers Gapital FYle 2 updei:that Qualify under Securities and Exchange Commission Rule 15IC13-1 (uniform net capital rule). Capital of no less than 510,000,000; 2) Registered as a dealer under the Securities Exchange-Act-of-1 934; 3) Member of the Natiof�at-Assesiatiea-ef Qeaier&s NASD Financial Industry Regulatory Authority (FINRA)IfSM(41 4) Registered to sell securities in Florida; and 5) The firm and assigned broker have been engaged in the business of effecting transactions in U.S. government and agency obligations for at least five(5) consecutive years. All brokers, dealers and other financial institutions deemed to be Qualified Financial Institutions shall be provided with current copies of the City's Investment Policy and in turn shall provide written acknowledgment of receipt.- A current audited financial statement is required to be on file for each financial institution and broker/dealer with which the City transacts business. X. MATURITY AND LIQUIDITY REQUIREMENTS To the extent possible an attempt will be made to match investment maturities with known cash needs and anticipated cash flow requirements. Investments of current operating funds shall have maturities of no longer than twenty-four(24) months. Investments of bond reserves, construction funds, and other non-operating funds("core funds")shall have a term appropriate to the need for funds and in accordance with debt covenants, but in no ,..h event shall exceed five(5) years. City of Edgewater Page 5 of 13 XI. COMPETITIVE SELECTION OF INVESTMENT INSTRUMENTS After the Finance Director, management designee or the Investment Advisor has determined the approximate maturity date based on cash flow needs and market conditions and has analyzed and selected one or more optimal types of investments, a minimum of three (3) Qualified Financial Institutions and/or Primary Dealers must be contacted and asked to provide bidsloffers on securities in question fe;�P stmentsvv �90-1nyestrre.nts :arRdeivr,590,999 9Ri7' ORe (1) Quallf{cd oFoids will be held in confidence until the bid deemed to best meet the investment objectives is determined and selected. Comoetitive bids are not required for money market mutual funds, investment pools and balances held with the depository bank. However, if obtaining bids/offers are not feasible and appropriate, securities may be purchased utilizing the comparison to current market price method on an exception basis. Acceptable current market price providers include, but are not limited to: A. ;Telerate Inf FinatieR_ }t H-A. Bloomberg Information Systems B. Wall Street Journal online. Bloomberg online, or a comparable nationally recognized online service providing updated datiy-market pricingjsMt7] C. ',U.S. Department of the Treasury website: data section lisyirsi D. Hy mpGiRg-pr, The Finance Director or the Investment Advisor shall utilize the competitive bid process to select the securities to be purchased. Selection by comparison to a current market price, as indicated above, shall only be utilized when, in judgment of the Finance Director or the Investment Advisor, competitive bidding would inhibit the selection process. Examples of when this method may be used include: A. When time constraints due to unusual circumstances preclude the use of the competitive bidding process B. When no active market exists for the issue being traded due to the age or depth of the issue C. When a security is unique to a single dealer,, fGr example ,,,^«e plaGeMeRt D. When the transaction involves new issues or issues in the"when issued" market Overnight sweep investments or repurchase agreements will not be bid,-but may be placed with the City's depository bank relating to the demand account for which the sweep investments or repurchase agreement was purchased. XII. AUTHORIZED INVESTMENTS AND PORTFOLIO COMPOSITION Investments should be made subject to the City's cash flow needs aro-although such cash flows are subject to revisions as market conditions and the City's needs change. However, wheA7 In the event #he-invested funds are needed in whole or in part fer-the-prior to maturity for purposes not-originally intended or for more optimal investments, the Finance Director or management designee may sell the investment at the then-prevailing market price and place the proceeds with the City's custodian. City of Edgewater Page 6 of 13 The following are the investment requirements and allocation limits on security types, issuers, and maturities as established by the City. The Finance Director or management designee shall have the option to further restrict investment percentages from time to time based on market conditions, risks or diversification investment strategies. The percentage allocations requirements for investment types and issuers are calculated based on the original cost of each investment and the portfolio value at time of purchase. Investments not listed in this Policy are prohibited. Investments when purchased must have the required minimum debt rating as required by Moody's and by Standard Poor's. The allocation limits and security types do not apply to the investment of debt proceeds. These investments shall be governed by the debt covenant included in the debt instrument. A. Florida Prime Investment Pool (Formerly known as The State Board of Administration's Local Government Surplus Funds Trust Fund) ("SBA Pool") Portfolio Composition- 100%of available funds may be invested in the SBA. United States Government Securities, IsN•i(9]or obligations the principal and interest of which are unconditionally guaranteed by the United States Government. Such securities will include, but not be limited to the following: ■ Treasury Bills ■ Treasury Notes I �Feasury GR4&jSM(1OI ■ Treasury Strips ■ Treasury Securities State and Local Government Series SLGS Portfolio Composition- 100%of available funds may be invested in the United States Government Securities. The length to maturity of any direct investment in the United States Government Securities are five(5) years from the date of purchase. Maturities longer than five (5)years require the City's approval. B. United States Government Agencies full faith and credit of the United States Government Purchase Authorization-Authorized Staff may invest in bonds, debentures or notes issued or guaranteed by the United States Government agencies, provided such obligations are backed by the full faith and credit of the United States Government. Such securities will include, but not be limited to the following: • Government National Mortgage Association (GNMA) • United States Export Import Bank • Farmer Home Administration • Federal Financing Bank • Federal Housing Administration Debentures • General Services Administration • New Communities Debentures • United States Public Housing Notes and Bonds • United States Department of Housing and Urban Development A maximum of 50%of available funds may be invested in United States Government agencies. City of Edgewater Page 7 of 13 A maximum of 25% of available funds may be invested in individual United States Government agencies. The length to maturity for an investment in any United States government agency security is five (5) years from the date of purchase. Maturities longer than five(5) years require the City's approval. C. Federal Instrumentalities(Government Sponsored Agencies or"GSEs") Bonds, debentures, or notes issued or guaranteed by U.S. Government Sponsored Agencies limited to the following issuers: o Federal Farm Credit Bank (FFCB) o Federal Home Loan Bank or its District banks(FHLB) o Federal National Mortgage Association (FNMA) o IFederal Agricultural Mortgage Corporation (Farmer Mac}Isyui 11 o Federal Home Loan Mortgage Corporation (Freddie Macs) including Federal Home Loan Mortgage Corporation participation certificates 9vauvern cvizn MwketiRgi-r -MQe)t$M(121 A maximum of 80% of available funds may be invested in Federal instrumentalities. The combined total of available funds invested in Federal Agencies, Instrumentalities and Mortgage Backed Securities cannot be more than 80%. A maximum of 40% of available funds may be invested in any one issuer. The length to maturity for an investment in any Federal Instrumentality is five (5) years from the date of purchase. Maturities longer than five (5) years require the City's approval. D. Non-Negotiable Interest Bearing Time Certificates of Deposit Non-negotiable interest bearing time certificates of deposit or savings accounts in banks organized under the laws of this state and/or in national banks organized under the laws of the United States and doing business and situated in this state, provided that banks aRy suGh dep '+ are listed as Florida Qualified Public Depositories (QPDs) under the Florida Public Deposits Act, Chapter 280. https:limvfloridacfc.com/docs-sf/treasury-libraries/treasury- documents/listofactivegpds.13df A maximum of 50%of available funds maybe invested in non-negotiable interest bearing time certificates of deposit or savings accounts. A maximum of 25%of available funds maybe deposited with any one issuer. The maximum maturity on any certificate shall be no greater than ^^eer„ (I)-Tea;-three 3 ears from the date of purchase. E. Repurchase Agreements �641;eFized Staff rpay invest PR FepUFGhase agreerneRtS GOFnpF;sed af only these .—� City of Edgewater Page 8 of 13 invcstments h-+�ed AR t e Fe ents set fe Fth by the Gi Y's Master RePWFG [SM(131 Agr-eement. All firms with whom the City enters into repurchase agreements will have in place an executed Master Repurchase Agreement with the City. A third party custodian shall hold collateral for all repurchase agreements with a term longer than one (1) business day. Securities authorized for collateral are negotiable direct obligations of the United States Government and Federal Instrumentalities with maturities under five (5) years and must have a mark-to-market value at a minimum of 102 percent during the term of the repurchase agreement. Immaterial short-term deviations from 102 percent requirement are permissible only upon the approval of the Authorized Staff. A maximum of 50% of available funds may be invested in repurchase agreements with the exception of one(1) business day agreements,overnight sweep agreements. A maximum of 25% of available funds may be invested with any one institution with the exception of one (1) business day agreements, overnight sweep Agreements. The maximum length to maturity of any repurchase agreement is 60 days from the settlement date. F. Commercial Paper Commercial paper issued by a United States company rated, at the time of purchase, "113-1" by Moody's, and "A-1" or better by Standard Poor's. If backed by a letter of credit(LOC), the long-term debt of the LOC provider must be rated at least "A" by at least two nationally recognized rating agencies at the time of purchase. The LOC provider must be ranked in the top fifty(50) United States banks in terms of total assets by the American Banker's yearly report. A maximum of 25% of available funds may be directly invested in prime commercial paper. A maximum of 4510%of available funds may be invested with any one issuer. The maximum maturity shall be 270 days from the settlement date. G. Corporate Notes Corporate notes issued by corporations organized and operating within the United States or by depository institutions licensed by the United States that have a long term debt rating at the time of purchase with a minimum "Aa" by Moody's and a minimum of"AA"by Standard & Poor's. A maximum of 25% of available funds may be directly invested in corporate notes. A maximum of 2-110% of available funds may be invested with any one issuer. The maximum length to maturity for corporate notes shall be 3 years from the date of purchase. City of Edgewater Page 9 of 13 H. Bankers Acceptances Banker's acceptances, which are issued by a domestic bank, which has at the time of purchase, an unsecured, un-insured and un-guaranteed obligation rating of at least "Prime-1" by Moody's or "A-1" by Standard Poor's. The bank must be ranked in the top fifty (50) United States banks in terms of total assets by the American Banker's yearly report. A maximum of ldsrol «%of available funds may be directly invested in bankers' acceptances. A maximum of 2-010%of available funds may be invested with any one issuer. The maximum length to maturity for bankers'acceptances shall be 180 days from the date of purchase. I. State and/or Local Government Taxable and/or Tax-Exempt Debt General obligation and/or revenue bonds rated at least"Aa" by Moody's or"AA" by Standard &Poor's for long-term debt, or"MIG-2"by Moody's or"SP-2" by Standard Poor's for short-term debt. A maximum of 20%of available funds may be invested in taxable and tax-exempt debt. A maximum of 2810%of available funds may be invested with any one issuer. A maximum length to maturity for an investment in any state or local government debt security is three (3) years from the date of purchase. J. Registered Investment Companies (Money Market Mutual Funds) Open-end and no-load money market funds provided such funds are registered under the Federal Investment Company Act of 1940 and operate in accordance with 17 C.F.R. §2a-7,which stipulates that money market funds must have an average weighted maturity of 59L60 ksm(i5ldays or less. In addition, the share value of the money market fund must be equal to$1.00. A maximum of 50% of available funds may be invested in money market funds. A maximum of 25% of available funds may be invested with a single money market fund. The money market funds shall berated Ino less than AAArn SM(lbl" G"-by Standard&Poor's or the equivalent by another rating agency. A thereugh review Gf a r rngRey market fund is Fequired prier to investing and an a r hnsis There shall he a estieggaire developed by the Finanne Direntnr that 1.4,411 r.ontain a last Gf ques-tim-Ra- that r_,avers the rAajGF a6peGtS Of aAY K. Other Intergovernmental Investment Pools Intergovernmental investment pools, rated AAAm or equivalent, that are authorized pursuant to the Florida Interlocal Cooperation Act, as provided in s.163.01, F. S. City of Edgewater Page 10 of 13 s� A maximum of 25% of available funds may be invested in intergovernmental investment pools. � thaFeu gh r view ef and Gn ' a nnntin, al basis. TheFe shall be a-questionnaire d by the C:nnn^n nirnntr.r that i rill nnta'n o loot Of n BSt'n c that n eFs the mains aceeGtS Of aRY innc�r nl�r�nS`M/1gl JJ XIII. PERFORMANCE MEASUREMENTS In order to assist in the evaluation of the portfolios' performance, the City will use performance benchmarks for short-term and long-term portfolios. The use of benchmarks will allow the City to measure its returns against other investors in the same markets. A. Investment performance of funds designated as short-term funds and other funds that must maintain a high degree of liquidity will be compared to the rolling average return on the six-month U.S. Treasury Bill. Investments of♦� ,rant ^ rat'n shell have matuFities ef no IGn9er than tWeRtV_fGUF(24) mnntH�c B. Investment performance of funds designated as core funds and other non-operating funds that have a longer-term investment horizon will be compared to an index comprised of U.S. Treasury or Government securities. The appropriate index will have a duration and asset mix that approximates the portfolios and will be utilized as a benchmark to be compared to the portfolios'total rate of return. Investments of bond reserves, construction funds, and other non-operating funds ("core funds") shall have a term appropriate to the need for funds and in accordance with debt covenants, but in no event shall exceed five(5) years. XIV. REPORTING The Finance Director, management designee and/or Investment Advisor shall provide the City Manager with a"Quarterly Investment Report"that summarizes but not limited to the following: A. Recent market conditions, economic developments and anticipated investment conditions. B. The investment strategies employed in the most recent quarter. C. A description of all securities held in investment portfolios at month-end. D. The ,average portfolio yield'is mo9ltntal rata of r�for the quarter and year-to-date versus appropriate benchmarks. E. Any areas of the Policy concern warranting possible revisions to current or planned investment strategies. The market values presented in these reports will be consistent with accounting guidelines in GASB Statement 31. On an annual basis, the City Manager designee shall submit to the City Council a written report on all invested funds. The annual report shall provide all, but not limited to the following_a complete list of all funds, security descriptions including issuer name, coupon rate, par amount, book and market value, trade date, settlement date, and maturity date. The annual report will shGw pertnrma compare portfolio performance to the results to tho above-stated performance benchmarks. All investments shall be reported at fair value per GASB Statement 31. If an investment held by the City of Edgewater Page 1 1 of 13 City &4a-Il-falls below the required Moody's or Standard Poor's rating,this shall be included in the Investment report. The Council shall have the option to discuss and affirm or atter sell the saw downgraded investment-4eldh� the City. Investment reports shall be available to the public. XV. THIRD PARTY CUSTODIAL AGREEMENTS Securities, with the exception of certificates of deposits, shall be held with a third-party custodian; and all securities purchase by, and all collateral obtained by the City should be properly designated as an asset of the City. The securities must be held in an account separate and apart from the assets of the financial institution. A third-party custodian is defined as any bank depository chartered by the Federal Government, the State of Florida, or any other state or territory of the United States which has a branch or principal place of business in the State of Florida, or by a national association organized and existing under the laws of the United States which is authorized to accept and execute trusts and which is doing business in the State of Florida. Certificates of deposits will be placed in the provider's safekeeping department for the term of the deposit. The custodian shall accept transaction instructions only From those persons who have been duly authorized by the City Manager and which authorization has been provided, in writing, to the custodian. No withdrawal of securities, in whole or in part, shall be made from safekeeping, shall be permitted unless by such a duly authorized person. The custodian shall provide the Finance Director or management designee with safekeeping statements that provide detailed information on the securities held by the custodian. On a monthly basis, the custodian will also provide reports that list all securities held for the City, the book value of holdings and the market value as of month-end. If an iRve truant falls below the requiFed enGad r Stnpcinrd PGGr'r rte.}inn thP AWMAdiAR Shall .,r.lif y Oho CinAnn.m- Dirr.ntAr wathi., 2 All Ssecurity transactions of the CitV aCnP hrnkLgr1dPAlor unci the im lvino +ho purGrhrase nr ale of sen-uritieG by transfer r.f FAGney oGu4 in 'rust be made on a "delivery vs. payment" basis, if-a plisable, to ensure that the custodian will have the security or money, as appropriate, in hand at the conclusion of the transaction. Securities held as collateral shall be held free and clear of any liens. XVI. INVESTMENT COMMITTEE The Finance Director with the approval of the City Manager may establish an Investment Committee for the purpose of formulating alternative investment strategies 9F6 WithiR the quidelinn herein et fGFth ^nd for monitoring the performance and structure of the City's portfolio. The Committee may include the Finance Director as Chairman, the City's Investment Advisor and other staff members as designated by the City Manager. In lieu of formal establishment of an investment committee the Finance Director may evaluate and manage the investment portfolio solely with the City's Investment Advisor. A designee of the Finance Director may provide the Committee members with current market information, an updated portfolio listing and analysis, and various pertinent financial data. The Committee or quorum of the committee shall meet as often as deemed necessary, under the gi„on GGRditiORS, to review, discuss and affirm or alter the current investment strategy and perform other functions as herein provided. The Investment Committee activities Gan-include but are not ,'limited to review and setting of investment strategies; review and establishing of written investment procedures; review and approval of bank and other rating agency services; review and approval of source documentation regarding issuers, and dealers, and any other functions as defined herein. XVII. INTERNAL LOAN PROGRAM City of Edgewater Page 12 of 13 This section governs the extension of internal loans from the City's internal liquidity resources of the Pooled Cash Fund for the purpose of financing capital construction projects or capital outlay expenditures for which external financial is not available, or for providing interim financing for municipal strategic initiatives for which a gap exists between the acquisition or construction of a project and the timing of the cash receipts from planned sources of funding including permanent debt financing,federal and state grants, fees and charges and cash from general operating sources. Internal loans will be utilized to provide a short to medium term financing alternative for departments seeking to finance such capital projects/capital outlay expenditures, in a manner that does not detract from the overall City portfolio investment objectives and liquidity requirements. All internal loans under the Program must be approved by the City Council. The Finance Director will promulgate general objectives, guidelines and financial reporting of administration of Program. XVIII. INVESTMENT POLICYADOPTION The Investment Policy shall be adopted by City resolution. The Finance Director apd-Qity's FiRaasla4&m(2ij Advisor�'�rshall review the Policy annually and submit recommendations to the City Manager for review and approval. If a change in the Policy is recommended for approval by the City Manager, the Finance Director will prepare the necessary report to Council. Approved by the City Council of the City of Edgewater at a meeting held on the 3r4 day- le day of WaF-Gh 2014November under Agenda Item 8e Resolution No. 'nom;-r'4 2022-R-34. City of Edgewater Page 13 of 13