SECTION MAX POINTS SCORE 1 SCORE 2 SCORE 3 AVERAGE
1 SCOPE 5 5 5 5 5.00
2 PRUDENCE 5 4 2 4 3.33
3 OBJECTIVE 5 4 4 5 4.33
4 DELEGATION OF AUTHORITY 5 5 5 5 5.00
5 ETHICS AND CONFLICT OF INTEREST 5 3 5 5 4.33
6 AUTHORIZED DEALERS & INSTITUTIONS 5 4 3 3 3.33
7 AUTHORIZED & SUITABLE INVESTMENTS 10 8 7 7 7.33
8 REVIEW OF INVESTMENT PORTFOLIO 5 3 1 3 2.33
9 INVESTMENT POOLS/MUTUAL FUNDS 5 3 2 3 2.67
10 COLLATERALIZATION 5 5 5 4 4.67
11 SAFEKEEPING AND CUSTODY 5 5 5 5 5.00
12 DIVERSIFICATION 5 5 3 5 4.33
13 MAXIMUM MATURITIES 5 3 4 4 3.67
14 INTERNAL CONTROLS 5 4 3 3 3.33
15 PERFORMING STANDARDS 5 4 3 5 4.00
16 REPORTING 10 7 7 9 7.67
17 INVESTMENT POLICY ADOPTION 5 5 5 5 5.00
18 GLOSSARY 5 5 5 4 4.67
82 74 84
TOTAL AVERAGE SCORE (OUT OF 100) CERTIFIED
80.00 NO
CMTA Investment Policy Scorecard Summary
NAME OF ENTITY
REVIEW DATE
City of Richmond
2/19/25
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 1 SECTION MAX POINTS SCORE COMMENTS
1 SCOPE 5 5
2 PRUDENCE
5 4
Section should reflect one
term - policy refers to
prudent investor vs prudent
person. Is there a
difference?
3 OBJECTIVE
5 4
Section refers to investing
idle funds - is that defined?
Without clarity, their could
be scrutiny as to City's
intent
4 DELEGATION OF AUTHORITY 5 5
5 ETHICS AND CONFLICT OF INTEREST
5 3
Section refers to 1, 3 and 4 -
where is #2? Trying to
understand the relevance of
the second point.
6 AUTHORIZED DEALERS & INSTITUTIONS
5 4
There is no reference to
annual review of the
fnancial condition. Also, it
may be helpful to
understand what is the
evaluation criteria to
determine. The language
reflected in internal controls
may be more appropriate
here.
7 AUTHORIZED & SUITABLE INVESTMENTS
10 8
Reference to idle funds can
lead to misinterpretations.
No reference to Master
repurchase agreement
being signed by bank or
dealer
8 REVIEW OF INVESTMENT PORTFOLIO
5 3
There is no reference to
how to handle investment
that may fall below grade
listed in authorized
investment. It is preferable
to have a separate section
that highlights the key
individual's role.
CMTA Investment Policy Scorecard
City of Richmond
Margaret Moggia
2/6/2025
NAME OF ENTITY
EVALUATOR
EVALUATION DATE
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 2 9 INVESTMENT POOLS/MUTUAL FUNDS
5 3
Requirement should state a
thorough investigation of
the pool/fund is required
prior to investing, and on a
continual basis.
10 COLLATERALIZATION 5 5
11 SAFEKEEPING AND CUSTODY 5 5
12 DIVERSIFICATION 5 5
13 MAXIMUM MATURITIES
5 3
Requirement focuses on
the overall maturity duration
should not exceed 5 years,
match cash flow and that
forward settlements should
not exceed 45 days.
Reference at the list of
authorized investment.
14 INTERNAL CONTROLS
5 4
Language re financial
institutions and broker
dealers and bi-annual
review should be included
as part of authorized
dealers section
15 PERFORMING STANDARDS 5 4 Consider stating benchmark
16 REPORTING
10 7
May be helpful to share
government code section.
With the reporting, the
monthly reporting should
reference the transactions.
17 INVESTMENT POLICY ADOPTION 5 5
18 GLOSSARY 5 5
TOTAL SCORE (OUT OF 100) CERTIFIED
82 NO
Additional Comments:
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 3 SECTION MAX POINTS SCORE COMMENTS
1 SCOPE 5 5
2 PRUDENCE
5 4
Suggest eliminating the use
of "prudent Person" and
use "prudent Investor"
3 OBJECTIVE 5 5
4 DELEGATION OF AUTHORITY 5 5
5 ETHICS AND CONFLICT OF INTEREST 5 5
6 AUTHORIZED DEALERS & INSTITUTIONS
5 3
Suggest adding
"institutions" and moving
the 2nd and 3rd paragraphs
of section XIV under this
section.
7 AUTHORIZED & SUITABLE INVESTMENTS
10 7
Suggest adding language
within the Repurchase
Agreements section to
require having a signed
Master Repurchase
Agreement with the bank or
dealer. Also, suggest
changing last sentence
under Medium Term Notes
to "Purchase may not
exceed 30% of portfolio",
8 REVIEW OF INVESTMENT PORTFOLIO
5 3
Suggest adding language
stating securities must be in
compliance with section XIII
at time of purchase, as well
as requiring portfolio be
reviewed monthly for
compliance with Policy. If
portfolio is found to be non-
compliant, a report to City
Council detailing the issue
and recommendation to
bring portfolio back into
compliance with Policy
should be made.
9 INVESTMENT POOLS/MUTUAL FUNDS
5 3
Suggest adding specifics as
to the investigation of the
Investment Pool (see
CMTA's sample investment
policy).
CMTA Investment Policy Scorecard
City of Richmond
Mary-Ann Davidson
1/30/2025
NAME OF ENTITY
EVALUATOR
EVALUATION DATE
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 4 10 COLLATERALIZATION
5 4
Suggest adding language to
require collateralization of
102% of principal and
interest for repurchase
agreements.
11 SAFEKEEPING AND CUSTODY 5 5
12 DIVERSIFICATION 5 5
13 MAXIMUM MATURITIES
5 4
Although stated in section
VIII of your Policy, I suggest
adding a new section to
emphasize the maximum
maturiy of 5 years (from
time of purchase) and
include language to match
investment maturies to
cash flow requirements.
14 INTERNAL CONTROLS
5 3
Suggest moving 2nd and
3rd paragraphs to section
VII and expanding language
to include an independent
review by an external
auditor".
15 PERFORMING STANDARDS 5 5
16 REPORTING
10 9
Suggest adding language
requiring monthly report to
include a listing of that
month's transactions
(buys/sells).
17 INVESTMENT POLICY ADOPTION 5 5
18 GLOSSARY
5 4
Suggest removing certain
words and /or phrases
within the glossary not
utilized in the Policy (Bid,
Annual Comprehensive
Financial Report, Federal
Reserve System,
Secondary market and
Offer).
TOTAL SCORE (OUT OF 100) CERTIFIED
84 NO
Additional Comments:
Making the suggested changes will improve your Investment Policy and help to receive the CMTA Investment Policy Certification.
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 5 SECTION MAX POINTS SCORE COMMENTS
1 SCOPE 5 5
2 PRUDENCE
5 2
states both prudent person
and prudent investor
standards; should hold to
prudent investor
3 OBJECTIVE
5 4
suggest removing
statement "The City will
invest up to 100% of all idle
funds." Could open up for
criticism if the city does not
invest up to 100%
4 DELEGATION OF AUTHORITY 5 5
5 ETHICS AND CONFLICT OF INTEREST 5 5
6 AUTHORIZED DEALERS & INSTITUTIONS
5 3
expand to includeother
institutions in addition to
broker dealers; suggest
adding more than just credit
worthiness. While a key
consideration there is more
in the standard due
diligence process.
7 AUTHORIZED & SUITABLE INVESTMENTS
10 7
clarify "at the time of
purchase as of settlement
date (per code); in the GSE
section, is it the intention of
the City to exclude the GSE
names not listed?; in MTN
secion, the reference to
30% of invested idle funds
may be confusing, code
allows for 30% of the
portfolio at time of
purchase; add language to
limit exposure to a single
counterparty, 10% (code
max) or less, often see no
more than 5% and often 3%
per single issuer.
8 REVIEW OF INVESTMENT PORTFOLIO
5 1
create a separate section
for review of the portoflio
with specifics related to
responsibilities and
frequency
CMTA Investment Policy Scorecard
City of Richmond
Susan Munson
1/30/2025
NAME OF ENTITY
EVALUATOR
EVALUATION DATE
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 6 9 INVESTMENT POOLS/MUTUAL FUNDS
5 2
suggest added language on
how the due diligence is
completed, as outlined in
the sample investment
policy
10 COLLATERALIZATION 5 5
11 SAFEKEEPING AND CUSTODY 5 5 good to emphasize DVP
only
12 DIVERSIFICATION
5 3
add specifics, see
comments related to issuer
concentration in the
investment section
13 MAXIMUM MATURITIES
5 4
does address in the
investment section, update
to clarify based on
settlement date (to align
with code)
14 INTERNAL CONTROLS
5 3
Add specifics outlining
responsibilities of all
parties; move the
paragraph related to
financial and broker dealers
to section VII
15 PERFORMING STANDARDS
5 3
is it the City's intention to
manage the portfolio on a
total rate of return? If the
portfolio is not managed on
a total rate of return it is
best practice to use other
indicators as performance
benchmarks.
16 REPORTING
10 7
Only the monthly
transaction reports are
required. The code allows
for the City to report the
required elements for
quarterly reports more
frequently but checking to
make sure going beyond
what is requred by code
mandatory
17 INVESTMENT POLICY ADOPTION 5 5
18 GLOSSARY 5 5
TOTAL SCORE (OUT OF 100) CERTIFIED
74 NO
Additional Comments:
Attachment 7 CMTA Investment Policy Certification - Scores and Feedback 7