February 14, 2025
Andrea Miller
Director of Finance/City Treasurer
City of Richmond
450 Civic Center Plaza
Richmond, CA 94804
Via email: [email protected]
Subject: RE: Revised City of Richmond Investment Policy
Dear Andrea,
Thank you for being a long-time CalTRUST shareholder. As you are aware, City of Richmond has been a shareholder with CalTRUST since 2006. In response to your letter dated February 6, 2025, it is important to clarify that CalTRUST does not actively manage the City’s assets as a separately managed account. As a joint powers authority, CalTRUST is a local government itself. The CalTRUST funds are local government investment pool funds, a structure similar to that of a money market fund, that are available for California public agencies to utilize as one tool in their investment strategy. Since CalTRUST is not actively managing individual investments for the City, we are unable to certify compliance with your City’s specific investment policy; we can only certify compliance with the CalTRUST Investment Policy, which is in compliance with California Government Code. Since we are pooled investment funds, we are unable to place additional screens or restrictions on our investment funds for individual shareholders.
The CalTRUST holdings are always available and updated daily in your online shareholder portal so you are able to review the current holdings at any time. While we are unable to place additional restrictions on CalTRUST, it would be unusual for CalTRUST to hold the investments that Richmond has chosen to restrict as they do not o[er value in the liquidity space. Additionally, the credit on several of your specifically restricted investments would likely fail to qualify for consideration per our credit parameters. By its nature, the CalTRUST Liquidity Fund invests primarily in banks so that fund could be an option that would likely be compliant with your restrictions, but again, we are unable to o[er a guarantee beyond the parameters of the CalTRUST Investment Policy. It is also worth noting that as a local government investment fund, when you invest in CalTRUST your exposure is to the CalTRUST funds and not directly to the underlying securities.
I would be more than happy to facilitate a conversation with our asset management team at State Street Global Advisors for further discussion and clarity for you on how CalTRUST invests its assets.
Please do not hesitate to reach out for further clarification or discussion.
Kindest Regards,
Laura Labanieh
Chief Executive O[icer
(916) 745-6701
[email protected]