EXHIBIT
A
CITY OF NAPA
STATEMENT OF INVESTMENT POLICY
June
2022
2023
Page
1 of
12 1. Policy
It is the policy of the City of Napa
(“City”)
to invest public funds in a manner which will provide
maximum security, meet the daily cash flow demands of the City, and provide highest investment return while conforming to all
California laws and local statutes governing the
investment of public funds.
2. Scope
This
investment policy
applies
to
all
the
funds
and
investment
activities
under the
direct authority
of the City
. This investment policy has been separately approved by the respective governing bodies of
the Housing Authority of the City of Napa
(“HACN”)
and the
Successor Agency to the
Napa Community Redevelopment
Agency
(“Successor Agency”); thus, references in thi
s policy
to the “City” shall apply equivalently to HACN and the Successor Agency .
There are
four
categories of funds that are separately invested in accordance with specialized requirements for admin
i
stration and reserve
requirements, which supersede confl
icting requirements of this
policy, including:
employees' retirement funds
(governed by CalPERS)
, pension stabilization
trust funds
(governed by separate investment guidelines adopted by City Council) ,
CERBT
trust
funds
(Governed by CalPERS)
, and
certain d
ebt issues which are invested by trustees
appointed under indenture agreements.
Funds are accounted for in the City's
Annual
Comprehensive
Financial Report
(
ACFR
)
and include the following:
General Fund
Special Revenue Funds
Capital Project Funds
Debt
Service Funds
Enterprise Funds
Internal Service Funds
Trust and Agency Funds
3. Prudence
All persons authorized to make investment decisions on behalf of the City are trustees and therefore fiduciaries subject to the prudent investor standard:
'When
investing, reinvesting,
purchasing, acquiring, exchanging, selling, or managing public funds, a trustee shall act with care, skill, prudence, and diligence under the circumstances then prevailing, including, but not limited to, the general economic conditi
ons and the anticipated needs of the agency, that a
prudent person acting in a like capacity and familiarity with those matters would use in the conduct of funds of a like character and with like aims, to safeguard the principal and maintain the liquidity
needs of the agency.
4. Objective
The primary objectives in priority order, of the City
’s
investment activities shall be:
4.1 Safety:
Safety of principal is the foremost objective of the investment program.
Investments of the City shall be undertaken in
a manner that seeks to ensure that capital losses
are avoided, whether from securities default, broker
-
dealer default, or erosion of market value.
To attain this objective, diversification is required in order that potential losses on individual ATTACHMENT 3
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CITY OF NAPA
STATEMENT OF INVESTMENT POLICY
June
2022
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12 securitie
s do not exceed the income generated from the remainder of the portfolio. The City may elect to sell a security prior to its maturity and record a capital gain or loss in order to improve the quality, liquidity or yield of the portfolio in response to mark et conditions or the City's
risk preferences.
4.2 Liquidity:
The City
’s
investment portfolio will remain sufficiently liquid to enable the City to meet all operating requirements which might be reasonably anticipated.
4.3 Return on Investment:
The
City
’s
investment portfolio shall be designed with the
objective of
attaining a market rate
of return throughout budgetary and economic cycles,
taking
into
account
the
City's
investment
risk
constraints
and
the
cash
flow characteristics of the
portfolio.
5. Delegation of Authority
Pursuant to
the
City
of
Napa
Municipal
Code
Section 2.32.030(g),
the
Finance
Director
/
Treasurer is delegated investment authority and is responsible for investment decisions and activities.
Section 53607 of the
California Government Code requires that delegation of
authority is only valid for a one
-
year period or until the delegation of the authority is revoked or expires.
Authority
must
be
renewed
each
year.
The
Finance Director/
Treasurer
shall
establish
written
procedures for the operation of the investment program consistent with this investment policy. Procedures should include
reference to:
Safekeeping, master repurchase
agreement,
wire transfer agreement, collateral/depository agreement and banking service c ontract.
Such
procedures shall include explicit delegation of authority to persons responsible for investment transactions.
No City personnel may engage in an investment transaction except as provided under the terms of this policy and the procedures estab lished by the
Finance Director/
Treasurer.
He or she shall be
responsible for
all transactions
undertaken and
shall establish
a
system of
controls to regulate the activities of subordinate officials. The City may engage the services of one or more external
professional money
managers to assist in the management of the City's
investment portfolio in a manner consistent with the City's objectives. Such external managers may be granted discretion to purchase and sell investment securities in accordance with thi s
Investment Policy. Such managers must be registered under the Investment Advisors Act of 1940.
6. Ethics and Conflicts of Interest
Officers and 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 make impartial investment decisions.
Employees and investment officials shall
disclose to the City Manager any material financial interests in financial instit utions that conduct
business within the jurisdiction, and they shall further disclose any large personal financial/investment positions that could be related to the performance of the City ’s
portfolio.
Employees and officers shall subordinate their persona
l investment transactions to those of the
City's, particularly with regard to the time of purchases and sales.
7. Authorized Money Managers. Financial Dealers and Institutions
The City may contract with professional money managers to assist in the manage ment of all or
part
of
its
investment portfolio
in
compliance
with
the
investment
guidelines
detailed
in
the
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12 Allowable Investment and Additional Investment Guidelines of this policy (Reference pages 5 -
11)
.
If the
Finance Director/
City Treasurer
directly invests in individual securities, then the City will maintain a list of financial institutions and primary dealers authorized to provide investment services. Professional money managers working with the City may maintain their own list. "Primary"
dealers include those that regularly report to the Federal Reserve Bank and should qualify under Securities and Exchange Commission Rule 15C3 -
1 (uniform net capital rule).
All financial institutions, dealers and cash managers who desire to become qualifie d bidders for
investment transactions must supply the City with the following:
audited financial statements,
proof
of
National
Association
of
Security
Dealers
certification
when
applicable,
trading
resolution, proof of State of California
registration when applicable, completed questionnaire
and certification of having read the City of Napa's investment policy and depository contracts.
A current audited financial statement is required to be on file for each financial institution and dealer
.
8. Authorized Investments
The City is governed by the California Government Code Sections 53600 et seq. Authorized investments of the City are detailed in
the Allowable Investment and Additional Investment
Guidelines of this policy (Reference pages 5
-
11 ).
9. Collateralization
Collateralization will be required as indicated in
the Allowable Investment and Additional
Investment Guidelines of this policy (Reference pages 5 -
11).
Collateral will always be held by
an independent third party with whom the City has a current custodial agreement.
A clearly
marked evidence of ownership
(safekeeping receipt) must be supplied to the city and retained.
The right of collateral substitution may be granted.
10. Safekeeping and Custody
All securities owned by the City, shall be held in safekeeping by the City's custodian bank or a third
party bank trust department, acting as agent for the City under the terms of a custody or trustee agreement executed by the bank and by the City.
All securities will be received and
delivered using standard delivery
-
versus
-
payment (DVP) procedures.
11. D
iversification
The City will diversify its investments by security type and institution as detailed in the Allowable
Investment and Additional Investment Guidelines of this policy (Reference pages 5 -
11).
12. Maximum Maturities
Unless matched to a speci
fic cash flow, the City will not directly invest in securities maturing more than 5 years from the date of purchase (See exception indicated in the Allowable
Investment and Additional Investment Guidelines of this policy (Reference pages 5 -
11).
For
purpos
es of compliance with this
Policy
, an investment’s term or remaining maturity shall be
measured from the settlement date to final maturity.
13. Internal Control
The
Finance Director/
Treasurer shall establish a system of written internal controls which shall ATTACHMENT 3
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CITY OF NAPA
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June
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12 be reviewed by an independent auditor.
This review
will provide internal control by assuring
compliance with policies and procedures.
The controls shall be designed to prevent loss
es of
public funds arising from fraud, employee error, misrepresentation of third parties, unanticipated changes in financial markets, or imprudent actions by employees and officers of the City
.
Controls deemed most important include:
control of
collusion, separation of duties, separation
of transaction authority from accounting and recordkeeping, clear delegation of authority, specific limitations regarding securities losses and remedial action, written confirmation of telephone transactions, min
imizing the number of authorized investment officials,
documentation of transactions and strategies, and code of ethics standards.
14. Performance Standards
The investment portfolio shall be designed to attain a market average rate of return through budge
tary and economic cycles, taking into account the investment risk constraints and cash flow needs.
The specific investment performance objective for the portfolio shall be to earn a total rate of return over a market cycle which is approximately equal to a
market benchmark
index.
The current benchmark index for the portfolio is the Merrill Lynch U.S. Treasuries/ Agencies 1
-
5 Year Index.
15. Reporting
Per California
Government
Code section 53607, the Finance Director
/
Treasurer shall provide
monthly transact
ions to the City Council.
Per California Government Code sect
ion 53646, the Finance Director/
Treasurer
may
render a
periodic
report to the City Council. T
his report shall include:
Type of investment,
issuer,
Date of maturity,
Par and dollar amount
invested on all securities,
The quarterly report shall state compliance of the portfolio to the statement
of investment
policy, or manner in which the portfolio is not in compliance. The quarterly
report shall also
include a statement denoting the ability
of the local agency to meet its pool's expenditure
requirements for the next six months, or provide an explanation
as to why sufficient money
shall, or may, not be available.
The quarterly report shall be submitted within 45 days following the end of the
quarter covered by the report.
Monthly
statements
generated
by the City's contracted
investment managers
shall provide
the
following information:
Type of investment
Issuer
Maturity date
Par and dollar amount invested on all securities
Market value as of
the date of the report and source of valuation
16. Investment Policy Adoption
The
City
’s
investment
policy
shall
be
adopted
by
City
Council
resolution.
Any modifications
made thereto must be approved by the City Council.
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STATEMENT OF INVESTMENT POLICY
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ALLOWABLE INVESTMENTS AND ADDITIONAL INVESTMENT
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12 A.
CASH AND
INVESTMENT
INSTRUMENTS
City
funds
that are
necessary to meet current
operating
demands
may be kept in checking
accounts and savings accounts at financial institutions as identified in California State Government Code Section 53648 provided that they are adequately secured with proper collateral as prescribed by Government Code Sections 53656 and/or 53658 .
The
Finan
ce
Director/
City Treasurer is authorized to establish systems by which funds may be transferred between
these checking and savings accounts
, and to and
from
allowable
investment
instruments in accordance
with
this
policy
.
Allowable investments for the
portfolio of the City are limited by California State Government Code Sections 53601 et seq.; 53635. They are further restricted by the
Finance Director/
City
Treasurer’s investment strategy.
Allowable investments for the Housing Authority of the City of Na
pa are further
restricted
b
y
the Federal Department of Housing and Urban Development’s (HUD) Required HA Cash Management and Investment Policies and Procedures as provided in Notice PIH 96
-
33(HA).
Percentages of Investment Participation and percentages o f Maximum Investment Participation
apply at the time of purchase. Purchase transactions may not exceed $10,000,000, nor exceed five
-
year maturities. Exceptions can only be approved by City Council.
A security purchased in
accordance with this
Policy
shall not have a forward settlement date exceeding 45 days from the time of investment.
The investment instruments and percentages of participation permitted by this policy are:
1. U.S. Treasury Securiti
es (
bills, notes and bonds)
are sold to finance gap
s between the
federal government's receipts and expenditures.
A
T
reasury
bill (or T
-
bill) is an obligation of the U.S. government to pay the bearer a fixed sum on a specific date. Bills are sold by the Treasury at a discount from their par (face) value th rough
a competitive auction.
Treasury notes are coupon securities paying interest every six months and have a fixed maturity of not less than one year and not more than 10 years.
Treasury bonds are coupon securities paying interest every six months with maturities of more
than 10 years.
California Government Code Section 53601 Requirement
:
No limit specified:
Cit
y
of Napa Limitation:
1)
Maximum maturity
-
5 years
2)
Maximum par value total size
-
None
3)
Maximum par value per issue
-
None
4)
Credit
-
Full faith and
credit of the Federal Government
2. U.S. Agency & Governm
ent Sponsored Enterprise Securities
are not direct obligations
of the United States but rather are direct obligations of agencies of the federal government or government
-
sponsored enterprises.
Securities issued by U.S. government agencies are backed by the full faith and credit of the
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12 U.S.
government.
The federal government has sponsored the creation of, or the financial support of several corporations, also known as government
-
sponsored enterprises.
None of these organizations
carry the federal government guarantee.
FDIC
-
guaranteed secur
ities were a new fixed
-
income asset class in 2008 that resulted from the
Federal Depository Insurance Corporation's creation of the Temporary Liquidity Guarantee Program (
TLGP). Eligible banking institutions participating in the TLGP Program were able to i
ssue debt guaranteed by the FDIC through 10/31/09. The Program covers commercial paper
and corporate debt issued by participating banks and bank holding companies for issues that are greater than 30 days maturity, but maturing on or before 12/31/2012.
California Government Code Section 53601 Requirement:
No limit specified.
City
of Napa Limitation:
1)
Maximum maturity
-
5 years
2)
Maximum
allocation
-
no limitation
3)
Maximum
allocation
per issue
r
-
no limitation
4)
Credit
-
Despite
having
no
statutory
limitation
concerning
this
category,
prudent
investment practice necessitates constant analysis
of the
issuing
agency.
Although
these issues have either the implicit or explicit guarantee of the federal government, market perception often limits
the liquidity of these issues.
3. Obligations of the State of California or any local agency within the state,
including
bonds payable solely out of revenues from a revenue producing property owned, controlled or operated by the state or any local agency,
or by a department, board, agency or authority of the
state or any local agency.
California Government Code Section 53601 Requirement:
No limit specified.
City of Napa Limitation:
1)
Maximum maturity
-
5 years
2)
Maximum
allocation
-
no
limitation
3)
Maximum
allocation
per issue
r
-
5%
4)
Credit
-
Despite
having
no
statutory
limitation
concerning
this
category,
prudent
investment practice necessitates constant analysis
of the
issuing
State or
agency.
4. Registered treasury notes or bonds of any of the other 49 states in addition to California,
including bonds payable solely out of the revenues from a revenue -
producing
property owned, controlled, or operated by a state, or by a department, board, agency, o r
authority of any of these states.
California Government Code Section 53601 Requirement:
No limit specified.
City of Napa Limitation:
1)
Maximum maturity
-
5 years
2)
Maximum
allocation
-
no limitation
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12 3)
Maximum
allocation
per issu
e
-
5%
4)
Credit
-
Despite
having
no
statutory
limitation
concerning
this
category,
prudent
investment practice necessitates constant analysis
of the
issuing
State
.
5 . Bankers acceptances
are typically created from a letter of credit issued in a foreign trade
transaction.
It is a time draft drawn on and accepted by a bank to pay a specified amount of money on a specified date.
California Government Code Section 53601 Requirement:
1)
Purchases may not exceed 180 days.
2)
Purchases are restricted to 40% of
the agency's surplus money.
3)
No more than 30% of the City's surplus money may be invested in the bankers ’
acceptances of any one commercial bank.
4)
Include only those that are eligible for discounting with the Federal Reserve System.
City of Napa
Limitation:
1)
Maximum maturity
–
180 days
2 )
Maximum
allocation is
30% of portfolio
3 )
Maximum par value per institution
-
regardless of sector, $2,000,000 or 5%
whichever
is lower.
4 )
Credit
-
financial institutions that shall only include banks that hav e short
-
term
credit
ratings of A
-
1, P
-
1 or equivalent ratings from other recognized rating
services.
6 . Certificate of Deposit
6 A
. Certificate of Deposit
(
Time Deposit
)
is
a
time
deposit
in
a
financial
institution
documented by a certificate that
bears a specified dollar amount of the deposit, a specified maturity date and a specified interest rate.
California Government Code Section 53635.8 Requirement:
No limit specified.
City of Napa Limitation:
1)
Maximum maturity
-
2 years
2)
Maximum par
value total size
-
No restriction
3)
Maximum par value per institution
-
$
250,000
4)
Credit
-
from City authorized financial institutions.
Collateralization must comply
with statutory regulations.
6B
. Negotiable Certificate of Deposits
are issued
by
nationally or state
-
chartered bank
s
,
savings association
s
or federal association
s
(as defined by Section 5102 of the Financial
Code), state or federal credit union
s
, or by federally
-
or state
-
licensed branch
es
of foreign
bank
s
and are traditionally
trade i
n lots of at least $1,000,000.
California Government Code Section 53601 Requirement:
Shall not exceed the net worth of
the institution.
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12 City of Napa Limitation:
1)
Maximum Maturity
-
5 years
2)
Maximum
allocation
30 %
3)
Maximum
allocation
per institution
-
5% regardless of sector
4)
Credit
-
Must
be
rated
in a rating category of “
A
” (long
-
term) or its equivalent or
better
or A
-
1 (short
-
term) or its equivalent or better,
by
a
nationally
recognized
statistical
-
rating
organization.
7 . Commercial Paper
are short
-
term
unsecured
promissory
notes issued
by various
economic entities in the open market to finance certain short -
term credit needs.
California Government Code Section 53601 Requirement:
1)
Prime
quality
of
the
highest
ranking
or of
the
highest
letter
and
numerical
rating
as
provided for by nationally recognized
statistical
-
rating
organization.
2)
Issuing corporation must be organized and operating within the United States.
3)
Issuing
corporation
must
have
total
assets
in
excess
of
fi
ve hundred
million
dollars
($500,000,000).
4)
Issuing
corporation
must
be rated in a rating category of
"A"
or its equivalent
or
higher
by
a
nationally
recognized statistical
-
rating
organization for the issuer's
debt,
other than commercial paper.
5)
Purchases may not exceed 270 days maturity.
6 )
Purchases may not exceed
40%
of the agency's surplus
m
oney.
7)
No more than 10% of the agency’s total investment assets may be in the commercial paper and the
medium
-
term notes of any single issuer.
City of Napa Limitation:
1)
Maximum maturity
-
270 days
2)
Maximum allocation
-
40%
, effective until January 1, 2026. After January 1, 2026, maximum allocation
-
25%.
3 )
Maximum
allocation
per
issuer
-
5% per issuer
regardless of sector.
4 )
Credit
-
CA GC Section 53601 requirements.
8 . Medium Term Notes (
MTNs
)
issued
by
corporations
organized
and
operating
within the
United States.
California Government Code Section 53601 Requirement:
1)
Maximum of five years
maturity
2)
Shall be rated
in a rating category of “
A
” or its equivalent
or better by a nationally
recognized
statistical ratings organization.
3)
May not exceed 30% of surplus money
4)
No more than 10% of the agency’s total investment assets may be in the
commercial paper and the medium
-
term notes of any single issuer.
City of Napa Limitation:
1)
Maximum maturity
–
5 years
2)
Maximum allocation
-
30%
3)
Maximum
allocation
per issuer
-
5%
regardless of sector
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12 4
)
Credit
-
from City
or
money manager
authorized institutions
that shall
only
include
institutions
rated
in a rating category of
“
A
” or its equivalent
or higher
by a nationally
recognized statistical
-
rating
organization.
Any
downgrading
of these issues
below
t
he minimum required
after
purchase shall be reported to the Council in the
quarterly reports.
9 . Local Agency Investment
Fund (LAIF)
was established by the State to enable treasurers
to place funds in a pool for investments.
City of Napa Limitation:
None
LAIF
Limitations:
1)
M
aximum amount permitted by LAIF’s Local Investment Advisory Board.
2)
No more than 15 transactions in a month
10 . A Repurchase Agreement
is not a security but a contractual agreement.
It consists of two
simultaneous transactions.
First, a
n investor purchases securities (collateral) from a bank or dealer.
At the same time, the selling bank or dealer contractually agrees to repurchase the collateral security at the same price (plus interest) at some mutually agreed future date.
California G
overnment Code Section 53601 Requirement:
1)
Term of repurchase agreements shall be for 1 year or less.
2)
All securities under a repurchase agreement shall be held by the agency's safekeeping agent.
3)
The seller of repurchase securities shall not be
entitled to substitute securities,
except as
authorized by the City.
New or substitute securities should be reasonably
identical to the original securities in terms of maturity, yield, quality and liquidity.
City of Napa Limitation:
This investment vehicl
e, when utilized,
shall comply with
the following
guidelines:
1)
Maximum maturity
-
30 days
2)
Maximum par value total size
-
20%
3)
Maximum par val
ue per institution
-
20%
4)
Credit
-
a)
Securities shall be marked to market daily and shall be maintained at a
value no lower than $102.
b)
Securities acceptable as collateral shall be U.S. Treasury obligations only.
c)
It should be covered by a master repurchase agreement.
5)
Repurchase agreements shall only be made with primary dealers of the Federal
Reserve
Bank of New York.
11 . Money
M
arket
F
unds
The City is authorized to invest in shares of beneficial interest issued by
diversified
management
companies
that
are
money
market
funds
registered
with
the
Securities and Exchange
Commission under the Investment Company Act of 1940 and are subject to either one of the following requirements:
1)
The institutions shall have the highest rating provided by not less than two nationally recognized rating services.
2)
The institutions' inv
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12 with the Securities and Exchange Commission with not less than five years' experience managing money market mutual funds with assets under management in excess of five hundred million dollars
($500,000,000).
The purchase price of
shares of beneficial interest purchased shall not include any commission that these companies may charge.
City of Napa Limitation:
1)
Maximum
allocation
-
20% of agency's funds
.
2)
Maximum of 10% per any one
money market mutual fund.
1 2
. California Asset Management Program
.
The City is authorized to invest in shares of the
California
Asset
Management
Program,
a
joint
powers
authority
established
to
provide
investment services for California public
agencies under section 53601(p).
1)
City of Napa Limitation:
None
2)
CAMP Limitations
: City's investment may not comprise more than 10% of the CAMP Pool.
1 3
.
Asset
-
Backed Securities.
The City is authorized to invest in
a
mortgage
pass
-
through
security, collateralized mortgage obligation, mortgage
-
backed or other pay
-
through bond,
equipment lease
-
backed certificate, consumer receivable
pass
-
through
certificate, or
consumer receivable
-
backed bond
.
California Government Code Section
53601 Requirement:
1)
Maximum
remaining maturity
of five years
or less
2)
Shall be
rated in a rating category of
“AA” or its equivalent or better
.
3)
May not exceed 2
0% of surplus money
City of Napa Limitation:
1)
Maximum maturity
-
5 years
2)
Maximum allocation
-
20%
3 )
Maximum
allocation
per issuer
-
5%
regardless of sector
4 )
Credit
-
CA GC Section 53601 requirements.
1 4
.
Supranationals.
The City is authorized to invest in
United States dollar denominated senior
unsecured
unsubordinated obligations issued or unconditionally guaranteed by the International Bank for Reconstruction and Development, International Finance Corporation, or Inter
-
American Development Bank
.
California Government Code Section 53601 Requirement:
1)
Maximum of five years maturity
2)
Shall be rated
in a rating category of “
A
A
” or its equivalent
or better by a
nationally recognized
statistical ratings organization.
3)
May not exceed
3 0% of surplus money
City of Napa Limitation:
ATTACHMENT 3
EXHIBIT
A
CITY OF NAPA
STATEMENT OF INVESTMENT POLICY
June
2022
2023
ALLOWABLE INVESTMENTS AND ADDITIONAL INVESTMENT
GUIDELINES
Page
11 of
12 1)
Maximum maturity
-
5 yea
rs
2)
Maximum allocation 30%
3 )
Maximum
allocation
per issuer
-
5%
regardless of sector
4 )
Credit
-
CA GC Section 53601 requirements.
Other investments not authorized by the City of Napa (with the exception of LAIF and
CAMP)
:
1)
Reverse repurchase
agreement
2)
Mutual funds
3)
Derivatives such as financial futures and options, step -
ups, floaters, inverse
floaters, Interest
-
only
(lOs),
Principal
-
only (POs), forwards, currency and interest
rate swaps, caps, floors, collars, STRIPS except those
already owned as of
12/31/83), etc.
4)
Local government investment pools other than LAIF unless specifically approved by the
City Council.
5)
Eurodollar C
D
s
6)
Federal (Fed) funds.
B. ADDITIONAL GUIDELINES
1 )
Where California Government Code
Section 53601 specifies a percentage
limitation for a particular category of investment, that percentage is applicable only at the date of purchase.
2 ) The rating criteria will apply at the time of purchase. If an eligible investment is downgraded after
purchase to a rating category which is below the minimum required, the
Finance Manager
Deputy Finance Director
will document his/her
analysis and recommendation for disposition of the security for review and
approval
by the Finance Director / Treasurer
.
3 )
Securities shall not be purchased with trading or speculation (such as anticipating an appreciation of capital value through changes in market interest rates) as the dominant criterion for the section of the security,
4 )
Transfer of funds to any one insti
tution of more than $5,000,000
shall
be approved
by the
Finance Director/
Treasurer.
5 )
All new financial institutions or primary dealers not already approved by professional money managers working with the City shall be approved by the Finance Director/
Tre
asurer.
6 )
Trading is prohibited when cash or securities are not available to pay for the securities being purchased.
Taking of short position, i.e. selling securities which the City does not own, is also prohibited.
7 )
Written policies and
procedures for the delegation of authority for all investment activities shall be strictly followed.
8 )
Written investment procedures shall be strictly followed.
9 )
In case a financial institution or depository is downgraded, the Finance
Director/
Treasurer shall promptly make and implement an informed decision on whether to sell, withdraw, or retain any security or deposit in the City portfolio issued or held by such
affected financial institution or depository.
10 )
Written policies and procedures for the selection and maintenance of qualified ATTACHMENT 3
EXHIBIT
A
CITY OF NAPA
STATEMENT OF INVESTMENT POLICY
June
2022
2023
ALLOWABLE INVESTMENTS AND ADDITIONAL INVESTMENT
GUIDELINES
Page
12 of
12 financial institutions should be strictly followed.
The
Finance Director/
Treasurer
shall continue to monitor financial institut
ions' credit characteristics and financial
history throughout the period in which City funds are deposited or invested.
ATTACHMENT 3