Reso 2002-664RESOLUTION NO. 2002-664
A RESOLUTION OF THE BOARD OF DIRECTORS OF THE COSTA MESA
SANITARY DISTRICT, AMENDING THE ADOPTED 2002-2003 STATEMENT OF
INVESTMENT POLICY, AND AUTHORIZING THE TREASURER TO INVEST
AND REINVEST IDLE MONIES OF THE COSTA MESA SANITARY DISTRICT
IN ACCORDANCE WITH THE REVISED 2002-2003 STATEMENT OF
INVESTMENT POLICY, AND AUTHORIZING THE SAID TREASURER TO
DELEGATE TO HIS DEPUTY THE CARRYING OUT OF ANY SUCH TASKS.
THE BOARD OF DIRECTORS OF THE COSTA MESA SANITARY DISTRICT
DOES HEREBY RESOLVE AS FOLLOWS:
WHEREAS, Government Code Section 53601 sets forth the investments that the
District may lawfully make; and
WHEREAS, Government Code Section 53646 sets forth that the District's
Treasurer shall annually render to the Board of Directors a Statement of Investment
Policy at a public meeting for the Board to consider; and
WHEREAS, The Board desires to amend the adopted fiscal year 2002.2003
Statement of Investment Policy; and
WHEREAS, Government Code Section 53607 authorizes the Board to delegate the
authority to make investments and to sell or exchange securities for a one year period to
the Treasurer provided that monthly reports are thereafter made of the status of said
transactions;
NOW THEREFORE, the Board of Directors of the Costa Mesa Sanitary District
does hereby resolve as follows:
1. That the Statement of Investment Policy is amended and approved.
2. That the Treasurer is authorized to make investments consistent with said
amended Policy and is required to report to the Investment Oversight Committee and
Board on a monthly basis on'the status of those transactions. The Treasurer is hereby given
all of the authority provided by Government Code Section 53607, including the power to
invest and reinvest and the power to sell or exchange securities, consistent with the
District's policy.
3. That the Treasurer may delegate some part of these duties to his deputy
provided that the Treasurer remains responsible for such decisions and
provides oversight.
The Clerk of the District shall certify to the passage and adoption of this resolution, and
it shall thereupon be in full force and effect.
PASSED AND ADOPTED this AL day of October 2002.
ATTEST = ,f "
Secretary, Costa Mesa S.ard-t ry D strict
v �soard of Directors
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss
COSTA MESA SANITARY DISTRICT)
President, Costa Mesa Sitary District
Board of Dire ors
I, JOAN REVAK, Clerk of the Costa Mesa Sanitary District, hereby certify
that the above and foregoing Resolution No. 2002-664 was duly and regularly
passed and adopted by said Board of Directors at a regular meeting thereof held on
the q O'day of October 2002.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal
of the Costa Mesa Sanitary District this day of October 2002.
is
Y T_
Cler f` he" Costa Mesa Sanitary District
'. Attachment 2
°•. COSTA MESA SANITARY DISTRICT
STATEMENT OF INVESTMENT POLICY
2002 -03
I. GENERAL INTRODUCTION
Under the laws of the State of California, it is the responsibility of the District Treasurer, at the direction
of the Board, to secure and protect the public funds of the District, and to establish proper safeguards,
controls, and procedures to maintain these funds in a lawful, rational and auspicious manner. Said
maintenance shall include the prudent and secure investment of those funds that are deemed temporarily
excess, in a manner anticipated to provide additional benefit to the people of the Costa Mesa Sanitary
District.
This Statement of Investment Policy will be provided annually for the review of the Oversight Committee
and the approval of the Board in an open public meeting. It will also be provided to securities dealers,
banks, and brokers currently approved for conducting investment transactions with the District Treasurer's
office in the ongoing effort to manage the excess cash portfolio; to other affected persons or entities; and
to any member of the electorate wishing to review this document upon request. The Treasurer reserves
the right to provide these documents on a cost basis.
II. SCOPE
This Statement of Investment Policy pertains to those temporarily surplus funds under the control of the
Treasurer, designated for the daily ongoing operations of the District; and concerns the deposit,
maintenance, safekeeping, land preservation of all such funds, and the investments made with these funds.
This Policy does not apply to pension trust funds, deferred compensation funds, and certain other trust or
non - operating funds.
III. PURPOSE
The purpose of this Statement of Investment Policy is to provide the District, the Investment Oversight
Committee, those involved in servicing the investment requirements of the District, and any other
interested party, a clear understanding of the regulations and internal guidelines that will be observed in
maintaining and investing those pooled funds deemed temporarily excess. This statement is intended to
provide guidelines for the prudent investment of the Costa Mesa Sanitary District's (District's) temporary
idle cash, and outline the procedures for maximizing the efficiency of the District's cash management
system. The ultimate goal is to enhance the economic status of the District while safeguarding its assets.
IV. OBJECTIVE
The District's cash management system is designed to accurately monitor and forecast revenues and
expenditures, thus enabling the District to invest funds to the fullest extent possible. The District attempts
to obtain the highest yield possible only after the criteria established for safety and liquidity have been
met.
:-- The Costa Mesa Sanitary District operates its pooled idle cash investments 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.
This affords the District a broad spectrum of investment opportunities as long as the investment is deemed
prudent and is allowable under current legislation of the State of California Government Code Section
53600 et seq. and the general laws of the Costa Mesa Sanitary District.
The Costa Mesa Sanitary District strives to maintain the level of investment of all idle funds as near 100%
as possible, through daily and projected cash flow determinations. Idle cash management and investment
transactions are the responsibility of the Treasurer.
Criteria for selecting investments and the order of priority are:
Safety: The safety and risk associated with an investment refers to the potential loss of principal,
interest, or a combination of these amounts. The District only operates in those investments that
are considered very safe.
2. Liquidity: This refers to the ability to "cash in" at any moment in time with a minimal chance of
losing some portion of principal or interest.
3. Yield: Yield is the potential dollar earnings an investment can provide, and sometimes is referred
to as the rate of return.
4. Safekeeping: Securities purchased shall be held in third party safekeeping in the Trust
Department of a financial institution, in the District's name and control. The account established
shall be protected from seizure by creditors should the financial institution holding the District's
securities file for bankruptcy protection.
The basic premise underlying the District's investment philosophy is and continues to be, to insure that
surplus funds are always safe and available when needed.
V. DELEGATION OF INVESTMENT AUTHORITY
Authority to manage the Costa Mesa Sanitary District's investment program is derived from Costa Mesa
Sanitary District Board Resolution No. 2002 -650. Management responsibility for the investment program
is hereby delegated for fiscal year 2002 -03 to the Treasurer who shall establish written procedures for the
operation of the investment program consistent with this Investment Policy. Procedures should include
references to: safekeeping, repurchase agreements, wire transfer agreements, banking service contracts,
and collateral /depository agreements. Such procedures shall include explicit delegation of authority to
persons responsible for investment transactions. No person may engage in an investment transaction
except as provided under the terms of this policy and the procedures established by the Treasurer. The
Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to
regulate the activities of subordinate officials.
..k — s
VI. STANDARD OF PRUDENCE
The Treasurer shall perform the investment function in conjunction with the "Prudent Man Rule ". This
rule states, in ,principle that whenever investing property for the benefit of others, a trustee shall exercise
the judgment and care, under circumstances then prevailing that persons of prudence, discretion, and
intelligence, would exercise in the management of their own affairs not in regards to speculation, but in
regard to the permanent disposition of their funds, considering the probability of safety of, as well as the
probable income from their capital. The Treasurer and his designees are considered to have a fiduciary,
trustee, relationship with the public for the public funds and all investment decisions will be made in a
manner sustaining this responsibility."
VII. AUTHORIZED INVESTMENTS
The California Government Code allows the District to invest in the following media:
• Securities of the U.S. Government, or its government sponsored agencies
• Small Business Administration loans
• Certificates of deposit, placed with commercial banks and savings and loan companies
• Negotiable certificates of deposit
• Bankers acceptances
• Commercial paper
• Corporate notes and bonds, including medium term notes
• Local Agency Investment Fund
• Repurchase agreements
• Reverse repurchase agreements
• Passbook savings account demand deposits
• County Treasurer demand deposits
• Asset- backed and mortgage- backed securities
• Money market mutual funds
As a matter of practice, however, the District generally limits its investments to the following vehicles:
U.S. Treasury Bills - Issued weekly with maturity dates up to one year. They are issued and traded on a
discount basis with interest figured on a 360 -day basis, actual number of days. They are issued in
amounts of $10,000 and up, in multiples of $5,000. They are a highly liquid security.
U.S. Treasury Notes - Initially issued with two- to ten -year maturities. They are actively traded in a large
secondary market and are very liquid. The Treasury may issue Note issues with a minimum of $ 1,000,
however, the average minimum is $5,000.
Federal Government Sponsored Agency Issues - Guaranteed directly or indirectly by the United States
Government. All agency obligations qualify as legal investments and are acceptable as security for public
deposits.
They usually provide higher yields than regular Treasury issues with all of the same advantages.
Examples include:
-. • FICBs (Federal Intermediate Credit Bank Debentures) - Loans to lending institutions used to finance
the short -term and intermediate needs of farmers, such as seasonal production. They are usually
issued monthly in minimum denominations of $3,000 with a nine -month maturity. Interest is
payable at maturity and is calculated on a 360 -day, 30 -day month basis.
• FFCBs (Federal Farm Credit Bank) - Debt instruments used to finance the short and intermediate
term needs of farmers and the national agricultural industry. They are issued monthly with three -
and six -month maturities. The FFCB issues larger issues (one to ten year) on a periodic basis.
These issues are highly liquid.
• FLBs (Federal Land Bank Bonds) - Long -term mortgage credit provided to farmers by Federal Land
Banks. These bonds are issued at irregular times for various maturities ranging from a few months
to ten years. The minimum denomination is $1,000. They carry semi - annual coupons. Interest is
calculated on a 360 -day, 30 -day month basis.
• FHLBs (Federal Home Loan Bank Notes and Bonds) - Issued by the Federal Home Loan Bank
System to help finance the housing industry. The notes and bonds provide liquidity and home
mortgage credit to savings and loan associations, mutual savings banks, cooperative banks,
insurance companies, and mortgage- lending institutions. They are issued irregularly for various
maturities. The minimum denomination is $5,000. The notes are issued with maturities of less than
one year and interest is paid at maturity. The bonds are issued with various maturities and carry
semi- annual coupons. Interest is calculated on a 360 -day, 30 -day month basis.
• FNMAs (Federal National Mortgage Association) - Used to assist the home mortgage market by
purchasing mortgages insured by the Federal Housing Administration and the Farmers Home
Administration, as well as those guaranteed by the Veterans Administration. They are issued about
four times a year for maturities ranging from a few months to 'eight years. They are issued in
minimum denominations of $10,000. They carry semi - annual coupons. Interest is computed on a
360 -day, 30 -day month basis.
• FHLMCs (Federal Home Loan Mortgage Corporation) - A government- sponsored corporation
established to develop the secondary market for conventional home mortgages. Mortgages are
purchased solely from the Federal Home Loan Bank System member lending institutions whose
deposits are insured by agencies of the United States Govermnent. They are issued for various
maturities and in minimum denominations of $10,000. Interest is paid semi - annually and is
calculated on a 360 -day, 30 -day month basis.
• Other federal agency issues are Small Business Administration notes (SBAs), Government National
Mortgage Association notes (GNMAs), Tennessee Valley Authority notes (TVAs), and Student
Loan Marketing Association notes (SALLIE- MAEs). As a matter of practice, the District does not
invest in these is :sue- sissues, as they do not suit our purposes as well as other investment
opportunities available.
The District limits its investments to no more than 25% of its surplus funds in any one Federal Agency.
4W
Bankers Acceptances - Short -term credit arrangements to enable businesses to obtain funds to finance
commercial transactions. They are time drafts drawn on a bank by an exporter or importer to obtain funds
to pay for specific merchandise. By its acceptance, the bank becomes primarily Iiable for the payment of
the draft at its maturity. An acceptance is a high -grade negotiable instrument. Bankers Acceptances can
be purchased in various denominations for 30, 60, or 90 days, but no longer than -180 days. The interest
is calculated on a 360 -day discount basis similar to Treasury Bills. Local agencies may not invest more
than 40% of their surplus funds in bankers acceptances or more than 10% of the agency's surplus funds in
bankers acceptances of any one commercial bank.
Certificates of Deposit - Time deposits of a bank or savings and loan. They are purchased in various
denominations with maturities ranging from 30 to 360 days. The interest is calculated on a 360 -day,
actual -day month basis and is payable monthly.
Negotiable Certificates of Deposit - Unsecured obligations of the financial institution, bank or savings and
loan, bought at par value with the promise to pay face value plus accrued interest at maturity. They are
high -grade negotiable instruments, paying a higher interest rate than regular certificates of deposit. The
primary market issuance is in multiples of $1,000,000, the secondary market usually trades in
denominations of $500,000, although smaller lots are occasionally available. As a matter of practice, only
the ten largest U.S. banks where there is a secondary market established for continued liquidity are
considered for investment. The District's total investment in negotiable certificates of deposit may not
exceed 30% of surplus funds.
" Commercial Paper - Short-term unsecured promissory notes issued by a corporation to raise working
capital. These negotiable instruments are purchased at a discount to par value or at par value with interest
bearing.
Local agencies are permitted by State law to invest in commercial paper of "prime" quality of the highest
ranking or of the highest letter and numerical rating as provided by Moody's Investor's Service, Inc.,
and/or Standard and Poor's Corporation. Eligible paper is further limited to issuing corporations that are
organized and operating within the United States and having total assets in excess of five hundred million
dollars ($500,000,000) and having an "A" or higher rating for the issuer's debt other than commercial
paper. Commercial Paper issued by an Issuer that has a rating of "A" on their debt other than commercial
paper but are on credit watch for a possible downgrade by a nationally recognized rating agency shall not
be considered for investment purposes. Purchases of eligible commercial paper may not exceed -270
days maturity nor exceed represent more than 10% of the outstanding paper of an issuing corporation.
Purchases of commercial paper may not exceed 15 percent of the portfolio. An additional 15 %, for a total
of 30 percent of the portfolio, may be invested only if the dollar - weighted average of the entire investment
in commercial paper does not exceed 31 days. "Dollar- weighted average maturity" is defined as the sum
of the amount of each outstanding commercial paper investment multiplied by the number of days to
maturity, divided by the total amount of outstanding commercial paper.
Medium Term Corporate Notes - Unsecured promissory notes issued by a corporation organized and
operating in the United States. These are negotiable instruments and are traded in the secondary market.
Medium term corporate notes can be defined as extended maturity commercial paper.
A, %
Local agencies are restricted by the Government Code to investments in corporations rated in the top three
note categories by Moody's Investors Service, Inc., and/or Standard and Poor's Corporation. For medium -
term notes, eligible purchases consist of instruments that have a rating of "A" or better by both Moody's
Investors Service, Inc., and Standard and Poor's Corporation. Corporate Notes issued by an Issuer that has
a rating of "A" but are on credit watch for a possible downgrade by a nationally recognized rating agency
shall not be considered for investment purposes. If the security's credit rating falls below "A" by one of
these agencies, then awareness is heightened and the security monitored closely to determine if credit risk
has been significantly increased. If a security falls below "A" by both rating agencies, then the Treasurer
will evaluate the need to sell the security prior to maturity. Further restrictions are a maximum term of
five years to maturity and total investments in medium term corporate notes may not exceed 30% of the
local agency's surplus funds.
Repurchase Agreements - A repurchase agreement is a short -term investment transaction. Banks buy
temporarily idle funds from a customer by selling U.S. Government or other securities with a contractual
agreement to repurchase the same securities on a future date. Repurchase agreements are typically for one
to ten days in maturity. The customer receives interest from the bank. The interest rate reflects both the
prevailing demand for Federal funds and the maturity of the repurchase agreement. Some banks will
execute repurchase agreements for a minimum of $100,000 to $500,000, but most banks have a minimum
of $1,000,000. The term of a repurchase agreement may not exceed one year. The market value of
securities that underlay a repurchase agreement shall be valued at 102 percent or greater of the funds
borrowed against those securities and the value shall be adjusted no less than quarterly. Repurchase
Agreements can only be executed with financial institutions or broker /dealers that have signed a Master
Repurchase Agreement with the District.
Reverse Repurchase Agreements - A reverse repurchase agreement is the opposite of a repurchase
agreement. The District loans a security to a bank in exchange for cash. The District agrees to pay off the
loan with interest on a future date. As this type of investment actually involves a loan arrangement, the
District may not invest more than 10% of its surplus funds in reverse repurchase agreements, and must
always match its maturities to the reinvestment. Reverse repurchase agreements may be utilized only
when either of the following conditions are met:
1. The security was owned or specifically committed to purchase, by the local agency, prior to
December 31, 1994, and was sold using a reverse repurchase agreement on December 31, 1994.
2. The security:
a) to be sold has been owned and fully paid for a minimum of 30 days prior to sale; and
b) total of all reverse repurchase agreements owned does not exceed 10 percent of the base
value of the portfolio; and
c) agreement does not exceed a term of 92 days, unless the agreement includes a written
codicil guaranteeing a minimum earning or spread for the entire period between the sale of
a security using a reverse repurchase agreement and the final maturity date of the same
security.
LAIF (Local Agency Investment Fund) - A special ,fund in the State Treasury which local agencies may
use to deposit funds for investment. There is no minimum investment period and the minimum
transaction is $5,000, in multiples of $1,000 above that, with a maximum balance of $40,000,000 for any
agency. The District is restricted to a maximum of fifteen transactions per month. It offers high liquidity
- because deposits can be converted to cash in 24 hours and no interest is lost. All interest is distributed to
those agencies participating on a proportionate share basis detennined by the amounts deposited and the
length of time they are deposited. Interest is paid quarterly. The State retains an amount for reasonable
costs of making the investments, not to exceed one - quarter of one percent of the earnings. California
Government Code § 16429.3 states, in part:
"money placed with the State Treasurer for deposit in the Local Agency Investment Fund
by cities, counties, or special districts shall not be subject to impoundment or seizure by
any state official or state agency."
Orange County Treasurer's Pool - A special fund in the County Treasury which local agencies may use to
deposit funds for investment. The District may not invest more than 35% of its surplus money with the
Orange County Treasurer's Pool. However, any investment held by the Orange County Treasurer's Pool
will be apportioned and overlaid with the District's portfolio to determine compliance with other self -
imposed restrictions as specified in this Investment Policy. The County Treasurer charges 12.5 basis
points (.125 %) to all pool participants for its direct costs. Direct Costs include proper staffing, bank and
custodial fees, software maintenance fees, and other indirect costs relating to the investment. Investment
earnings are distributed to the pool participants on a monthly basis, net of the above charges. The
earnings are credited to the participants accounts on either the last day of each month or the first day of the
subsequent month.
Money Market Mutual Funds - Shares of beneficial interest issued by diversified management companies.
To be eligible for investment, shares must:
attain the highest rating provided by Moody's Investors Service, Inc., which is currently "Aaa,"
and/or Standard and Poor's Corporation, which is currently "AAA;" and
2. the investment adviser managing the shares must be registered with the Securities and Exchange
Commission with not less than five year's experience investing in instruments authorized under
California Government Code §53601 subdivisions (a) to (m) inclusive, and with assets under
management in excess of five hundred million dollars ($500,000,000); and
3. the purchase price of shares shall not include any commission that these companies may charge;
and
4. investment in shares shall not exceed 20 percent of surplus funds.
However, no more than 10 percent of the District's surplus funds may be invested in shares of beneficial
interest of any one mutual fund. Furthermore, any investment in a money market mutual fund must
comply with other self - imposed restrictions as specified in this Investment Policy.
Asset - Backed and Mortgage- Backed Securi ty - Bonds backed by payments from receivables /mortgages
having a maximum of five years maturity. These securities must have an "AA" or better rating by
Moody's Investors Service, Inc., and/or Standard and Poor's Corporation. No more than 20% of the
District's surplus money may be invested in these securities.
'J ,
VIII. INVESTMENT OF BOND PROCEEDS
When investing proceeds from the issuance of bonds, the Costa Mesa Sanitary District will follow this
Investment Policy when determining allowable investments. Should the trust agreement of a particular
bond issue be more restrictive than the District's policy on permitted investments, then the trust agreement
will take precedence.
IX. DISTRICT CONSTRAINTS
The Treasurer will evaluate local banks and savings institutions and may invest idle cash funds with such
institutions when the criteria for prudent investment previously stated are met. The District operates its
investment pool according to State and self - imposed constraints. It does not. buy stocks; it does not
speculate; it does not deal in futures or options. Any investment extending beyond a five -year period
requires prior District Board approval. 'Additionally, a minimum of 25% of the outstanding investments
must mature within a one -year time period.
X. SAFEKEEPING AND COLLATERALIZATION
All security transactions, including collateral for repurchase agreements, entered into by the District shall
- be conducted on a delivery- versus - payment (DVP) basis. Securities will be held by a third party
custodian designated by the Treasurer.
Collateral ization will be required on two types of investments: certificates of deposit and repurchase (and
reverse repurchase) agreements. In order to anticipate market changes and provide a level of security for
all funds, a minimum collateral ization level is required.
Surplus funds must be deposited in State or national banks, State or Federal savings associations, or State
or Federal credit unions within the State of California. The deposits cannot exceed the amount of the
bank's or savings and loan's paid -up capital and surplus.
The bank or savings and loan must secure public funds deposits with eligible securities having a market
value of 110% of the total amount of the deposits. State law also allows as an eligible security, first trust
deeds having a value of 150% of the total amount of the deposits. A third class of collateral is 105% in
the form of a letter of credit drawn on the Federal Home Loan Bank.
The Treasurer may waive security for that portion of a deposit, which is insured pursuant to Federal law.
Currently, the first $100,000 of a deposit is federally insured. Deposits in excess of $100,000 are
collateralized as previously indicated.
XI. DERIVATIVE INVESTMENTS
A derivative is a generic term often used to categorize a wide variety of financial instruments whose value
"depends on" or is "derived from" the value of an underlying asset, reference rate, or index.
K '
--� Investments in derivative instruments are limited to debt securities that have periodic increases, or step -up
interest rate adjustments that provide upward mobility in yield return. Investments in debt securities,
which contain a callable feature are also allowable, but must comply with other restrictions as specified in
this Investment Policy.
Investments in derivative instruments known as "inverse floaters," "dual index," or "stepped inverse"
securities that produce higher than market yields at purchase date (when interest rates are low), but have
the possibility of producing low or no coupon rates as market interest rates rise through the life of the
instrument are not allowable. Furthermore, investments in range notes or interest -only strips that are
derived from a pool of mortgages are not allowable. However, debt securities that have a floor or a built -
in feature that prevents the instrument from potentially returning no yield are allowable.
XII. POLICY COMPLIANCE REGULATIONS
Should the portfolio, for any reason, fall out of compliance with this Investment Policy, immediate
liquidation of securities in order to bring the portfolio back into compliance is not required. However,
the Treasurer must take action to bring the portfolio into compliance within 12 months from the date the
portfolio was determined to be in non - compliance with the provisions of this Investment Policy.
Additionally, adequate disclosure as to all instances of noncompliance, and the efforts undertaken to
bring the portfolio into compliance, must be made on the monthly Treasurer's Report.
XIII. REPORTING
Under provisions of Section 53646 of the California Government Code, the Treasurer shall render a
quarterly investment report to the District Board and Manager of the District within 30 days following
the end of the quarter covered by the report. However, as a matter of practice a monthly report shall be
submitted listing the type of investments, institution, date of maturity, amount of deposit, rate of
interest, current market value for all securities, and such other data as may be required by the District
Board on a monthly basis. Furthermore, an Investment Oversight Committee comprised of the
following individuals will meet quarterly to review the District's portfolio and investment strategy.
• Director of Finance /District Treasurer
• Assistant Director of Finance
• Revenue Supervisor
• District Manager
• Assistant Manager
• Two Board Members
Additionally, an annual audit of the District's investment portfolio will be conducted by an independent
Certified Public Accounting firm and a report of the results will be made available.
XIV. QUALIFIED DEALERS
The Costa Mesa Sanitary District shall transact business only with banks, savings and loans, and
registered investment securities dealers. The District will utilize broker /dealers authorized to do business
`✓ with the City of Costa Mesa. Each authorized broker /dealer shall be required to annually file a signed
certification with the District Treasurer certifying that they have read and understand the District's most
recently adopted investment policy.
The Treasurer will maintain a list of financial institutions authorized to provide investment services. In
addition, a list will also be maintained of approved broker /dealers who are authorized to provide
investment services in the State of California. These may include "primary" and "regional" broker /dealers
with offices located in the State of California. All financial institutions and broker /dealers who desire to
become qualified bidders for investment transactions must be approved by and supply the Treasurer with a
completed broker /dealer questionnaire.
XV. POLICY REVIEW
This Statement of Investment Policy shall be reviewed at least annually to ensure its consistency with the
overall objectives of preservation of principal, liquidity and return, and its relevance to current law,
financial and economic trends.
Should conditions change or legislation become effective that behooves subsequent changes or a
liberalization of terms within the policy during the next fiscal year, the revised policy will be submitted to
both the Investment Oversight Committee and Board for adoption of the recommended action."
I
Attachment 3
COSTA MESA SANITARY DISTRICT
INVESTMENT GUIDELINES AND STRATEGY
GUIDELINES - Guidelines are established to direct and control activities in such a manner that
previously established goals are achieved.
1. Investment Transaction. Every investment transaction must be authorized and reviewed
by the Treasurer.
2. Pooled Cash. Whenever practical, local agency cash is consolidated into one bank
account and invested on a pooled concept basis. Interest earnings are allocated quarterly
according to month -end cash and investment balances for each fund.
3. Competitive Bids. Purchase and sales of securities are made on the basis of competitive
offers and bids when practical.
4. Cash Forecast. The cash flow for the District is analyzed with the receipt of revenues and
maturity of investments scheduled so that adequate cash will be available to meet
disbursement requirements.
5. Investment Limitations. Security purchases and holdings are maintained within statutory
limits imposed by the California Government Code. Current limits are:
Bankers Acceptances
Commercial Paper
Negotiable Certificates of Deposit
Reverse Repurchase Agreements
Medium Term Notes
Money Market Mutual Funds
Asset- Backed/Mortgage- Backed Securities
Local Agency Investment Fund
Orange County Treasurer's Pool
40% Section 53601(f)
30% Section 53601(g)
30% Section 53601(h)
20% Section 53601(1)
30% Section 536010)
15% Section 53601(k)
20% Section 53601(n)
$40,000,000 Section VII of Policy
35% Section VII of Policy
6. Liquidity. The marketability of a security is considered at the time of purchase, as the
security may have to be sold at a later date to meet unanticipated cash demands.
7. Diversification. The portfolio should consist of a mix of various types of securities,
issuers, and maturities.
8. Evaluate Certificates of Deposit
(a) Certificates of Deposit shall be evaluated in terms of FDIC coverage. For deposits
in excess of the insured maximum of $100,000, approved collateral at full market
value shall be required. (California Government Code Section 53652 and/or
53651(m) and 53651.2(a)(1).
--� COSTA MESA SANITARY DISTRICT
INVESTMENT GUIDELINES AND STRATEGY
(continued)
(b) Negotiable Certificates of Deposit shall be evaluated in terms of the credit
worthiness of the issuer, as these deposits are uninsured and uncol lateral ized
promissory notes.
II. STRATEGY - Strategy refers to the ability to manage financial resources in the most advantageous
manner.
Economic Forecasts. Economic Forecasts are obtained periodically from economists and
financial experts through bankers and brokers to assist the Treasurer with the formulation
of an investment strategy for the local agency.
2. Implementing Investment Strategy. Investment transactions are executed which conform
with anticipated interest rate trends and the current investment strategy plan.
3. Rapport. A close working relationship is maintained with large vendors of the District.
The objective is to pinpoint when large disbursements will clear the District's bank
account. It is essential for good cash control that such large expenditures be anticipated,
estimated as to dollar amount, and communicated to the Treasurer for liquidity planning
purposes.
4. Preserve Portfolio Value. Field standards are developed in order to maintain earnings
near the market and to preserve the value of the portfolio.
III. AUDIT - At least annually, the District's external auditors will analyze the District's portfolio and
report to the Board regarding the legal, credit, and market risks associated with each investment.
Additionally, the auditors will review the District's investment policy and make recommendations
for modifications, if appropriate.
Attachment 4
-� COSTA MESA SANITARY DISTRICT
INVESTMENT PROCEDURES
INTERNAL CONTROL - GUIDELINES
OBJECTIVES OF INTERNAL CONTROL
Internal control is the plan of organization and all the related systems established by management's
objective of ensuring, as far as practicable:
• The orderly and efficient conduct of its business, including adherence to management policies.
• The safeguarding of assets.
• The prevention or detection of errors and fraud.
• The accuracy and completeness of the accounting records.
• The timely preparation of reliable financial information.
LIMITATIONS OF INTERNAL CONTROL
No internal control system, however elaborate, can by itself guarantee the achievement of management's
objectives. Internal control can provide only reasonable assurance that the objectives are met, because of
its inherent limitations, including:
• Management's usual requirement that a control be cost - effective.
• The direction of most controls at recurring, rather than unusual, types of transactions.
• Human error due to misunderstanding, carelessness, fatigue, or distraction.
• Potential for collusion that circumvents controls dependent on the segregation of functions.
• Potential for a person responsible for exercising control abusing that responsibility; a responsible staff
member could be in a position to override controls which management has set up.
—� COSTA MESA SANITARY DISTRICT
INVESTMENT PROCEDURES
INTERNAL CONTROL - GUIDELINES
(continued)
ELEMENTS OF INTERNAL CONTROL
Elements of a system of internal control are the means by which an organization can satisfy the objectives
of internal control. These elements are:
ORGANIZATION
Specific responsibility for the performance of duties should be assigned and lines of authority and
reporting clearly identified and understood.
2. PERSONNEL
Personnel should have capabilities commensurate with their responsibilities. Personnel selection
and training policies together with the quality and quantity of supervision are thus important.
3. SEGREGATION OF FUNCTIONS
Segregation of incompatible functions reduces the risk that a person is in a position both to
perpetrate and conceal errors or fraud in the normal course of duty. If two parts of a transaction
are handled by different people, collusion is necessary to conceal errors or fraud. In particular, the
functions that should be considered when evaluating segregation of functions are authorization,
execution, recording, custody of assets, and performing reconciliations.
4. AUTHORIZATION
All transactions should be authorized by an appropriate responsible individual. The
responsibilities and limits of authorization should be clearly delineated. The individual or group
authorizing a specific transaction or granting general authority for transactions should be in a
position commensurate with the nature and significance of the transactions. Delegation of
authority to authorize transactions should be handled very carefully.
5. CONTROLS OVER AN ACCOUNTING SYSTEM
Controls over an accounting system include the procedures, both manual and computerized,
carved out independently to ascertain that transactions are complete, valid, authorized, and
properly recorded.
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Attachment 5
u—, COSTA MESA SANITARY DISTRICT
CASH CONTROLS
PROCEDURES PERFORMED BY EXTERNAL AUDITORS WITH RESPECT TO CASH RECEIPTS
A. District procedures and controls are reviewed. Some of the system strengths are:
1. Receipts are controlled upon receipt by proper registration devices.
2. Receipts are reconciled on a daily basis.
3. Amounts are deposited intact.
4. All bank accounts are authorized by the District Board.
5. Cash counts are done by two or more individuals. '
6. Bank reconciliations are reviewed.
7. Prompt posting of cash receipt entries in books.
8. Receipt forms are prenumbered, accounted for, and physically secured.
9. Proper approval required for write -offs of customer accounts.
10. Checks are restrictively endorsed upon receipt.
11. Adequate physical security over cash.
12. Individuals that handle cash do not post to customer account records or process billing
statements.
13. Adequate supervision of Finance Department operations.
B. Significant revenues are confirmed directly with payor and compared with District books to make
sure amounts are recorded properly.
C. Cash balances are substantiated by confirming all account balances recorded in books. Bank
reconciliations are reviewed for propriety and recalculated by the auditor. All significant
reconciling items on bank reconciliations are verified as valid reconciling items by proving to
subsequent bank statements.
)
COSTA MESA SANITARY DISTRICT
SEGREGATION OF RESPONSIBILITIES OF
THE TREASURY FUNCTIONS
Attachment 6
Function
Responsibility
1.
Authorization of Investment
Transactions:
Formal Investment Policy should be:
Prepared By:
Treasurer
Submitted To:
District Board
Investment Transactions
Treasurer
should be approved by
2.
Execution of investment
Assistant Director of Finance
transactions
3.
Timely recording of investment
transactions:
Recording of investment
Revenue Supervisor
transactions in the
Treasurer's records
Recording of investment
Accountant
transactions in the
accounting records
4.
Verification of investment,
Assistant Director of Finance
i.e., match broker confirma-
tion to Treasurer's records
5.
Safeguarding of Assets and Records:
Reconciliation of Treasurer's
Revenue Supervisor
records to the accounting records
Reconciliation of Treasurer's
Accountant
records to bank statements and
safekeeping records
Attachment 6
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-- COSTA MESA SANITARY DISTRICT
SEGREGATION OF RESPONSIBILITIES OF
THE TREASURY FUNCTIONS
(Continued)
Function Responsibility
5. Safeguarding of Assets and Records
(continued):
Annual review of (a) financial Assistant Director of Finance with
institution's financial condition, Treasurer's approval
(b) safety, liquidity, and potential
yields of investment instruments.
6. Periodic review of investment Independent Auditors
portfolio as prepared by
Treasurer including:
• Investment types
• Purchase Price
• Market values
• Maturity dates
• Par values
• Investment yields
• Conformance to stated investment policy
0 Safekeeping reports
7. Periodic review of investment Investment Oversight Committee
portfolio and strategies.
GLOSSARY
(Note: Entities are encouraged to include a glossary as part of
the investment policy. All words of a technical nature should
be included. Following is an example of common treasury
terminology.)
AGENCIES: Federal agency securities and/or Government -
sponsored enterprises.
ASKED: The price at which securities are offered.
BANKERS' ACCEPTANCE (BA): a draft or bill or exchange
accepted by a bank or trust company.
BID: The price offered by a buyer of securities. (When you are
selling securities, you ask for a bid.) See Offer.
BROKER: A broker brings buyers and sellers together for a
commission..
CERTIFICATE OF DEPOSIT (CD): A time deposit with a
specific maturity evidenced by a certificate. Large -
denomination CD's are typically negotiable.
'.OLLATERAL: Securities, evidence of deposit or other
,coperty which a borrower pledges to secure repayment of a
loan. Also refers to securities pledged by a bank to secured
deposits of public monies.
COMPREHENSIVE ANNUAL FINANCIAL REPORT
(CAFR): The official annual report for the City of Costa Mesa.
It includes five combined statements for each individual fund
and group prepared in conformity with GAAP. It also includes
supporting schedules necessary to demonstrate compliance with
finance- related legal and contractual provisions, extensive
introductory material, and a detailed Statistical Section.
COUPON: (a) The annual rate of interest that a bond's issuer
promises to pay the bondholder on the bond's face value. A
certificate attached to a bond evidencing interest due on a
payment date. DEALER: A dealer, as opposed to a broker, acts
as a principal in all transactions, buying and selling
DEBENTURE: A bond secured only by the general credit of
the issuer.
DELIVERY VERSUS PAYMENT: There are two methods of
delivery of securities: delivery versus payment and delivery
versus receipt. Delivery versus payment is delivery of securities
--ith an exchange of money for the securities. Delivery versus
,_ ceipt is delivery of securities with an exchange of a signed
receipt for the securities.
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DERIVATIVES: (1) Financial instrument whose return profile
is linked to, or derived from, the movement of one or more
underlying index or security, and may include a leveraging
factor, or (2) financial contracts based upon notional amounts
whose value is derived from an underlying index or security
(interest rates, foreign exchanges, equities or connnodities).
DISCOUNT: The difference between the cost price of a
security and its maturity when quoted at lower than face value.
A security selling below original offering price shortly after sale
also is considered to be at a discount.
DISCOUNT SECURITIES: Non - interest bearing money
market instruments that are issued a discount and redeemed at
maturity for full face value, e.g., U.S. Treasury Bills.
DIVERSIFICATION: Dividing investment funds among a
variety of securities offering independent returns.
FEDERAL CREDIT AGENCIES: Agencies of the Federal
government set up to supply credit to various classes of
institutions and individuals, e.g., S &L's, small business firms,
students, farmers, farm cooperatives, and exporters.
FEDERAL DEPOSIT INSURANCE CORPORATION
(FIDC): A federal agency that insures bank deposits, currently
up to $100,000 per deposit.
FEDERAL FUNDS RATE: The rate of interest at which Fed
funds are traded. This rate is currently pegged by the Federal
Reserve through open - market operations.
FEDERAL HOME LOAN BANKS (FHLB): Government
sponsored wholesale banks (currently 12 regional banks) which
lend funds and provide correspondent banking services to
member commercial banks, thrift institutions, credit unions and
insurance companies. The mission of the FHLBs is to liquefy
the housing related assets of its members who must purchase
stock in their district Bank.
FEDERAL NATIONAL MORTGAGE ASSOCIATION
(FNMA): FNMA, like GNMA was chartered under the Federal
National Mortgage Association Act in 1938. FNMA is a federal
corporation working under the auspices of the Department of
Housing and Urban Development (HUD). It is the largest single
provider of residential mortgage funds in the United States.
Fannie Mae, as the corporation is called, is a private
stockholder -owned corporation. The corporation's purchases
include a variety of adjustable mortgages and second loans, in
addition to fixed -rate mortgages. FNMA's securities are also
highly liquid and are widely accepted. FNMA assumes and
guarantees that all security holders will receive timely payment
of principal and interest.
a ltM iF �
"FEDERAL OPEN MARKET COMMITTEE (FOMC):
_consists of seven members of the Federal Reserve Board and
five of the twelve Federal Reserve Bank Presidents. The
President of the New York Federal Reserve Bank is a permanent
member, while the other Presidents serve on a rotating basis.
The Committee periodically meets to set Federal Reserve
guidelines regarding purchases and sales of Government
Securities in the open market as a means of influencing the
volume of bank credit and money.
FEDERAL RESERVE SYSTEM: The central bank of the
United States created by Congress and consisting of a seven
member Board of Governors in Washington, D.C., 12 regional
banks and about 5,700 commercial banks that are members of
the system. '
GOVERNMENT NATIONAL MORTGAGE
ASSOCIATION (GNMA or Ginnie Mae): Securities
influencing the volume of bank credit guaranteed by GNMA
and issued by mortgage bankers, commercial banks, savings and
loan associations, and other institutions. Security holder is
protected by full faith and credit of the. U.S. Government.
Ginnie Mae securities are backed by the FHA, VA or FmHA
mortgages. The term "pass - throughs" is often used to describe
Ginnie Maes.
iQUIDITY: A liquid asset is one that can be converted easily
and rapidly into cash without a substantial loss of value. In the
money market, a security is said to be liquid if the spread
between bid and asked prices is narrow and reasonable size can
be done at those quotes.
LOCAL GOVERNMENT INVESTMENT POOL (LGIP):
The aggregate of all funds from political subdivisions that are
placed in the custody of the State Treasurer for investment and
reinvestment.
MARKET VALUE: The price at which a security is trading
and could presumably be purchased or sold.
MASTER REPURCHASE AGREEMENT: A written
contract covering all future transactions between the parties to
repurchase — reverse repurchase agreements that established
each party's rights in the transactions. A master agreement will
often specify, among other things, the right of the buyer- lender
to liquidate the underlying securities in the event of default by
the seller - borrower.
MATURITY: The date upon which the principal or stated
value of an investment becomes due and payable.
,,,.ONEY MARKET: The market in which short-term debt
instruments (bills, commercial paper, bankers' acceptances,
etc.) are issued and traded.
A l 1 AL.111V1L1 V 1 /
OFFER: The price asked by a seller of securities. (When you
are buying securities, you ask for an offer.) See Asked and Bid.
OPEN MARKET OPERATIONS: Purchases and sales of
government and certain other securities in the open market by
the New York Federal Reserve Bank as directed by the FOMC
in order to influence the volume of money and credit in the
economy. Purchases inject reserves into the bank system and
stimulate growth of money and credit; sales have the opposite
effect. Open market operations are the Federal Reserve's most
important and most flexible monetary policy tool.
PORTFOLIO: Collection of securities held by an investor.
PRIMARY DEALER: A group of government securities
dealers who submit daily reports of market activity and
positions and monthly financial statements to the Federal
Reserve Bank of New York and are subject to its informal
oversight. Primary dealers include Securities and Exchange
Commission (SEC) - registered securities broker - dealers, banks,
and a few unregulated firms.
PRUDENT PERSON RULE: An investment standard. In
some states the 1aw requires that a fiduciary, such as a trustee,
may invest money only in a list of securities selected by the
custody state — the so- called legal list. In other states the trustee
may invest in a security if it is one which would be bought by a
prudent person of discretion and intelligence who is seeking a
reasonable income and preservation of capital.
QUALIFIED PUBLIC DEPOSITORIES: A financial
institution which does not claim exemption from the payment of
any sales or compensating use or ad valorem taxes under the
laws of this state, which has segregated for the benefit of the
commission eligible collateral having a value of not less than its
maximum liability and which has been approved by the Public
Deposit Protection Commission to hold public deposits.
RATE OF RETURN: The yield obtainable on a security based
on its purchase price or its current market price. This may be
the amortized yield to maturity on a bond the current income
return.
REPURCHASE AGREEMENT (RP OR REPO): A holder
of securities sells these securities to an investor with an
agreement to repurchase them at a fixed price on a fixed date.
The security "buyer" in effect lends the "seller" money for the
period of agreement, and the terms of the agreement are
structured to compensate him for this. Dealers use RP
extensively to finance their positions. Exception: When the
Fed is said to be doing RP, it is lending money, that is,
increasing bank reserves.
SAFEKEEPING: A service to customers rendered by banks
for a fee whereby securities and valuables of all types and
.— ECONDARY MARKET: A market made for the purchase
and sale of outstanding issues following the initial distribution.
SECURITIES & EXCHANGE COMMISSION: Agency
created by Congress to protect investors in securities
transactions by administering securities legislation.
SEC RULE 150 -1: See Uniform Net Capital Rule.
STRUCTURED NOTES: Notes issued by Government
Sponsored Enterprises (FHLB, FNMA, SLMA, etc.) and
Corporations which have imbedded options (e.g., call features,
step -up coupons, floating rate coupons, derivative -based
returns) into their debt structure. Their market performance is
impacted by the fluctuation of interest rates, the volatility of the
imbedded options and shifts in the shape of the yield curve.
TREASURY BILLS: A non - interest bearing discount security
issued by the U.S. Treasury to finance the national debt. Most
bills are issued to mature in three months, six months, or one
year.
TREASURY BONDS: Long -term coupon- bearing U.S.
Treasury securities issued as direct obligations of the U.S.
overnment and having initial maturities of more than 10 years.
TREASURY NOTES: Medium -term coupon- bearing U.S.
Treasury securities issued as direct obligations of the U.S.
Government and having initial maturities from two to 10 years.
UNIFORM NET CAPITAL RULE: Securities and Exchange
Commission requirement that member firms as well as
nonmember broker - dealers in securities maintain a maximum
ratio of indebtedness to liquid capital of 15 to l; also called net
capital rule and net capital ratio. Indebtedness covers all money
owed to a firm, including margin loans and commitments to
purchase securities, one reason new public 'issues are spread
among members of underwriting syndicates. Liquid capital
includes cash and assets easily converted into cash.
YIELD: The rate of annual income return on an investment,
expressed as a percentage. (a) INCOME YIELD is obtained by
dividing the current dollar income by the current market price
for the security. (b) NET YIELD or YIELD TO MATURITY
is the current income yield minus any premium above par or
plus any discount from par in purchase price, with the
adjustment spread over the period from the date of purchase to
the date of maturity of the bond.
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descriptions are held in the bank's vaults for protection.