1 June 5, 2024
Memorandum
To: Xenia Bradford, Interim Finance Director
Rick Kirkwood, Interim Assistant Finance Director
Angie Hernandez, Revenue Manager
City of Santa Maria
From: Monique Spyke, Managing Director
Justin Resuello, Client Relations Manager
PFM Asset Management LLC
Re: Investment Policy Review
PFM Asset Management LLC has completed its review of the City of Santa Maria’s (“the City”) 2024 Investment Policy (the “Policy”). The Policy is well written and in compliance with the sections of the California Government Code (the “Code”).
As requested, we are redacting the language in the section titled, Statement of Investment Policy, that requires the policy be reviewed annually, and are updating it to “…the Policy shall be reviewed when there are any changes made to the policy…” In January 2024, Senate Bill 882 made several changes to Code, including one change to Code Section 53601(o). The bill clarified that mortgage-backed securities issued by federal agencies are exempt from the Code’s requirements described in Section 53601(o) for privately i ssued asset- and mortgage- backed securities. The Code update codifies the common understanding of how agency mortgage-backed securities are treated under Code. We are recommending including the following language:
“For securities eligible for investment not issued or guaranteed by federal agencies and GSEs, the following limitations apply”.
Please let us know if you have any questions and if you would like to schedule a call to discuss our review further. Thank you.
ATTACHMENT A