Resolution 95-21
RESOLUTION NO. tj~ - c!)./
A RESOLUTION OF mE CITY COUNCIL OF mE CITY OF WYLIE,
TEXAS, PROVIDING FOR SCOPE OF mIS POLICY, PROVIDING FOR
INVESTMENT OBJECI1VES, PROVIDING FOR DELEGATION OF
AUmORITY, PROVIDING FOR STANDARD OF CARE, PROVIDING FOR
AumORIZED INVESTMENTS, PROVIDING FOR ornER INVESTMENT
GUIDELINES, PROVIDING FOR PORTFOLIO MATURITIES, PROVIDING
FOR INVESTMENT LIMITS, PROVIDING FOR SELECTION OF
BROKER/DEALERS, PROVIDING FOR SELECTION OF DEPOSITORIES,
PROVIDING FOR SAFEKEEPING AND CUSTODY, PROVIDING FOR
RECORD KEEPING AND REPORTING, PROVIDING FOR EmICS AND
CONFLICTS OF INTEREST, PROVIDING FOR POLICY REVISIONS; AND
MAKING VARIOUS FINDINGS AND PROVISIONS RELATED TO mE
SUBJECT.
WHEREAS, the City of Wylie acknowledges the high priority of providing the necessary
guardianship of public funds in the municipal sector; and,
WHEREAS, the City Council expressly intends to set high fiscal standards, delegate
treasury and investment duties to appropriate officials, and to review the actual performance at
regular intervals; and,
WHEREAS, the City Council hereby intends to implement investment requirements set
forth in Texas government Code, Chapter 2256, Public Funds Investment, Subchapter A - Public
Funds Investment Act and Subchapter B - Investment of Public Funds.
NOW mEREFORE, BE IT RESOLVED BY mE CITY COUNCIL OF mE CITY OF
WYLIE, TEXAS:
SECTION 1.
See Exhibit A - Investment Policy
SECTION 2. This Resolution shall be in full force and effect immediately upon its
passage and approval.
PASSED AND APPROVED, this the 23rd day of MaYf995.
L
Jin Swartz, Mayor
A lTEST:
I~
Secretary
EXHIBIT A
City of Wylie, Texas
INVESTMENT
POLICY
May 1995
EXHIBIT A
CITY OF WYLIE, TEXAS
INVESTMENT POLICY
Table of Contents
SCOPE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . .. 2
Safety ...................................................... 2
LIqUIdIty .................................................... 2
Diversification ................................................ 2
Yield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
DELEGATION OF AUTHORITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
STANDARD OF CARE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
AUTHORIZED SECURITIES INVESTMENTS .............................. 4
Direct Obligations of the United States Government . . . . . . . . . . . . . . . . . . . . .. 5
Debentures or Discount Notes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
.#
Bonds or Other Interest Bearing Obligations ........................... 5
Time Certificates of Deposit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 5
Repurchase Agreements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
Money Market Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
State or Local Investment Pools .................................... 6
Common Trust Funds ........................................... 7
OTHER INVESTMENT GUIDELINES .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
PORTFOLIO MATURITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
INVESTMENT LIMITS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
SELECTION OF BROKER/DEALERS .................................... 9
SELECTION OF DEPOSITORIES
10
SAFEKEEPING AND CUSTODY
11
RECORD KEEPING AND REPORTING.................................. 12
Enncs AND CONFLICTS OF INTEREST. .. . . . . . . . . . . . .. . . . . . . . . . . . . . ., 14
POLICY REVISIONS
14
EXHIBIT A
CITY OF WYLIE, TEXAS
INVESTMENT POLICY
I.
SCOPE
Chapter 2256 of Title 10 of the Local Government Code (herein after
referred to as the "Public Funds Investment Act") prescribes that each city
is to adopt rules governing its investment practices and to define the
authority of the investment officer. The following Investment Policy
addresses the methods, procedures, and practices which must be exercised
to ensure effective and judicious fiscal management of the City's funds.
This Policy shall not ..apply to the selection, retention or other issues
concerning the depositories of the City's funds in demand and time deposits
as provided under Chapter 105 of the Local Government Code.
This Policy shall apply to the investment and management of all
funds of the City under its control, other than those expressly excluded
herein or by applicable law or valid agreement. This Policy shall not
supersede the restrictions on investment and use applicable to any specific
fund and, in the event of any conflict between this Policy and the
requirements of any fund subject hereto, the specific requirement applicable
to such fund shall be followed as well as all other provisions of this Policy
other than those in conflict. The Employees Deferred Compensation
Agency Fund is excluded from coverage under this Policy.
In order to make effective use of the City's resources, all monies shall
be pooled into one investment bank account, except for those monies
required to be accounted for in other bank accounts as stipulated by
applicable laws, bond covenants or contracts. The income derived from this
pooled investment account shall be distributed in accordance with the City's
internal procedures.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 1
EXHIBIT A
II.
OBJECTIVES
The City's principal investment objectives in order of priority are
listed below.
Safety
The primary objective of the City's investment activity IS the
preservation of capital in the overall portfolio. Each investment transaction
shall seek first to ensure that capital losses are avoided, whether the loss
occurs from the default of a security or from erosion of market value.
Liquidity
The City's investment portfolio will remain sufficiently liquid to
enable the City to meet operating requirements that might be reasonably
anticipated. Liquidity shall be achieved by matching investment maturities
with forecasted cash flow requirements, by investing in securities with
active secondary markets, and by using state or local investment pools.
Diversification
The governing body recognizes that in a diversified portfolio,
occasional measured losses due to market volatility are inevitable, and must
be considered within the context of the overall portfolio's return, provided
that adequate diversification has been implemented. Therefore, assets held
in the common investment portfolio shall be diversified to eliminate the risk
of loss resulting from one concentration of assets in a specific maturity, a
specific issuer or a specific class of securities.
Yield
Attainment of a market rate of return equal to or higher than the
performance measure established from time to time by the Finance Director
of the City. Efforts to seek returns higher than the above goal must be
consistent with risk limitations identified in this policy and prudent
investment principles.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 2
EXHIBIT A
III.
DELEGATION OF AUTHORITY
Management responsibility for the investment program is delegated
by the City Council to the Finance Director (hereinafter referred to as the
"Director"). The Director's authority will at all times be limited by
conformance with all Federal regulations, State of Texas statutes and other
legal requirements including the City Charter and City Ordinances,
including this Policy.
The Director shall develop and maintain written administrative
procedures for the operation of the investment program consistent with this
Policy. The controls shall be designed to prevent, identify and control
losses of public funds arising from deviation from this Policy, fraud,
employee error, misrepresentation by third parties, or imprudent actions by
employees and officers of the City.
With written approval from the City Manager, the Director may
delegate any phase of the investment management program to members of
the City staff. Such approval shall state specifically the functions such
person is authorized to perform or that the person is authorized to perform
all activities of the Director under this Policy. The Director shall obtain and
maintain, at the City's expense, fidelity bonds for himself and each of his
designees in amounts determined adequate by the Director (which shall not
be less than five percent of the amounts subject to this Policy) for each
fiscal year as shown by the approved budget. No person may engage in an
investment transaction except as provided under the terms of this Policy and
the internal procedures established by the Director. A current list of persons
authorized to transact investment business and wire funds on behalf of the
City shall be maintained by the Director.
In the discretion of either the City Manager or the Director and in
any event upon the termination or reassignment of any member of the
Director's staff authorized to conduct transactions for the City pursuant to
this Policy, the authority of such person shall be revoked and such
revocation of authority shall be immediately communicated by the Director
orally and in writing to each and every depository, broker/dealer, investment
advisor, custodian and other agency or entity with whom the City has any
existing or continuing relationship in the management of its investments.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 3
EXHIBIT A
IV.
ST ANDARD OF CARE
The standard of prudence to be used for managing the City's assets
is the "prudent person" rule, which states, "Investments shall be made with
judgment and care, under prevailing circumstances, that a person of
prudence, discretion and intelligence would exercise in the management of
the person's own affairs, not for speculation, but for investment, considering
the probable safety of capital and the probable income to be derived."
In determining whether an investment officer has exercised prudence
with respect to an investment decision, the determination shall be made
taking into consideration the investment of all funds, or funds under the
entity's control, over which the officer had responsibility rather than a
consideration as to the prudence of a single investment; and whether the
investment decision was consistent with the written investment policy of the
entity.
The Director and authorized investment personnel acting in
accordance with written procedures and exercising due diligence shall be
relieved of personal responsibility for an individual security's credit risk or
market price changes, provided that this Policy and the Director's procedures
were followed.
The Director and his staff shall recognize that the investment
activities of the City are a matter of public record. Therefore, all
participants in the investment process shall seek to act responsibly as
custodians of the public trust. Investment officials shall avoid any
transactions that might impair public confidence in the City's ability to
govern effectively.
V.
AUTHORIZED SECURITIES INVESTMENTS
Subject to any limitations otherwise imposed by applicable law,
regulations, bond indentures or other agreements, (including but not limited
to the Public Funds Investment Act) the following securities and deposits
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 4
EXHIBIT A
are the only ones permitted as investments for the City's funds:
a. Direct obligations of the United States government with a
maturity not to exceed two years from the date of purchase; U.S.
Treasury Bills, U.S. Treasury Notes, U.S. Treasury Bonds, and U.S.
Treasury Strips (book entry U.S. Treasury securities whose coupon
has been removed).
b. Debentures or discount notes with a maturity not to exceed
two years from the date of purchase issued by, guaranteed by, or for
which the credit of any of the following Federal Agencies and
Instrumentalities is pledged for payment: Federal National Mortgage
Association (FNMA), Federal Home Loan Bank (FHLB), Federal
Farm Credit Bank (FFCB), Student Loan Marketing Association
(SLMA), and Federal Home Loan Mortgage Corporation (FHLMC).
c. Bonds or other interest bearing obligations of which the
principal and interest are guaranteed by the full faith and credit of
the United States government with a stated maturity not to exceed
two years from the date of purchase. A security's "average life" does
not constitute a stated maturity.
d. Time Certificates of Deposit insured by the Federal Deposit
Insurance Corporation (FDIC) in state or national banks or state or
federally chartered savings and loan associations located within the
State of Texas which have been approved by the City in accordance
with Section X of this Investment Policy. Any deposits exceeding
FDIC insurance limits shall be fully collateralized by securities listed
in items a and b above, and the collateral shall be held by the City's
third party custodian bank.
e. Repurchase Agreements with a defined termination date of 90
days or less on U.S. Treasury and Federal Agency securities listed in
items a and c above, collateralized at a minimum market value of
102 percent of the dollar value of the transaction, with the accrued
interest accumulated on the collateral included in the calculation.
Repurchase Agreements shall be entered into only with dealers
who: 1) are recognized as primary reporting dealers with the Market
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 5
EXHIBIT A
Reports Division of the Federal Reserve Board of New York;'and 2)
have an executed, City approved Master Repurchase Agreement.
Collateral (purchased securities) shall be held by the City's custodian
bank as safekeeping agent, and the market value of the collateral
securities shall be marked-to-the-market daily based on the bid price
for the previous day as reported in the Wall Street Journal.
For the purpose of item e of this section the term "collateral"
shall mean "purchased securities" under the terms of the City
approved Master Repurchase Agreement. Collateral bearing no
coupon will have a maturity not to exceed five years. All other
eligible collateral shall have a maturity limit of ten years.
f. Money Market Funds meeting each of the following criteria:
(1) Registered with the Securities and Exchange Commission;
(2) no commission fee shall be charged on purchases or sales of
shares;
(3) have an-objective of maintaining a constant daily net asset
value of $1.00 per share;
(4) limit assets of the fund to those securities listed In
paragraphs a, b, c, and e above; and
(5) have a maximum stated maturity of 13 months and dollar
weighted average portfolio maturity of not more than 120 days.
A list of City approved Money Market Funds shall be kept by the
Director.
g. State or local investment pools organized under the Interlocal
Cooperation Act that have been specifically approved by the Director
and meet each of the following criteria:
(1) no commission fee shall be charged on purchases or sales of
shares;
(2) have an objective of maintaining a constant daily net asset
value of $1.00 per share;
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 6
EXHIBIT A
(3) The weighted average maturity of the portfolio will not
exceed 180 days and no investment will have a stated remaining
maturity of greater than three years;
(4) limit assets of the fund to those seCUrItIes listed in
paragraphs a, b, c, d, and e above plus U. S. Government
Agencies or Instrumentalities. A list of City approved investment
pools shall be kept by the Director.
In addition to all of the investments listed above, all proceeds from
the sale of bonds and reserves and funds maintained for debt service
purposes may be invested in common trust funds owned or administered by
banks domiciled in Texas if the common trust fund meets all of the
following requirements:
1. all of the assets of such fund consist of an appropriate
combination of the securities listed above;
2. comply with the provisions of the Internal Revenue Code of 1986
and applicable federal regulations governing the investment of
bond proceeds;
3. meet the cash flow requirements and investment needs of the
City~ and
4. is owned or administered by a bank approved by the City
pursuant to Section X of this Policy.
VI.
OTHER INVESTMENT GUIDELINES
The City seeks active management of its portfolio assets. In the
effort of meeting the objectives of this Policy, the City may from time to
time sell securities that it owns in order to better position its portfolio assets.
Sales of securities prior to maturity shall be documented and approved by
the Director before such a transaction is consummated. Sales of securities
yielding net proceeds less than 98 percent of the book value of the securities
must be approved in advance and in writing by the City Manager.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 7
EXHIBIT A
Each investment transaction must be based upon competitive
quotations received from at least three broker/dealers who have been
approved by the City in accordance with Texas law.
The purchase and sale of all securities shall be on a delivery versus
payment or payment versus delivery basis (i.e., for securities purchases,
monies will not be released by the City's safekeeping bank until securities
are received at the Federal Reserve Bank for further credit to the City's
safekeeping bank. In the case of securities sales, monies will be received
by the City's safekeeping bank via tne Federal Reserve Bank as the
securities are simultaneously released to the purchaser). In this manner the
City will always have possession of either its securities or its monies.
VII.
PORTFOLIO MATURITIES
Maturities shall be selected which provide for both stability of
income and reasonable liquidity.
At all times the City shall maintain 10 percent of its total investment
portfolio in instruments maturing in 90 days or less. The weighted average
maturity of all securities and certificates of deposit in the City's total
investment portfolio at any given time (not including cash or demand
deposits) shall not exceed one and one-half years.
VIII.
INVESTMENT LIMITS
It is the policy of the City to avoid concentration of assets in a
specific maturity, a specific issue, or a specific class of securities, with the
exception of U.S. Treasury issues listed in Section V(a). The asset
allocation in the portfolio should, however, be flexible depending upon the
outlook for the economy and the securities markets.
The City will not exceed the following maximum limits as a
percentage of the total portfolio for each of the categories listed below:
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 8
EXHIBIT A
20 percent in Money Market Funds
30 percent in Certificates of Deposit
60 percent in State and Local Government
Investment Pools
30 percent in Instrumentality securities
described in Section V(b)
In addition to the limitations set forth above, the City's investment in
any single money market fund shall never exceed 10 percent of the total
assets of the money market fund.
The Director shall evaluate how each security purchased fits into the
City's overall investment strategy.
The amount of investments in U.S. Treasury and Agency Securities
and Repurchase Agreements backed by those securities, as defined in
Sections V(a), V(c) and V(e), shall at no time be less than 30 percent of the
total portfolio. There shall be no maximum limits on these investments.
IX.
SELECTION OF BROKER/DEALERS
The City shall maintain a list of broker/dealers and financial
institutions which have been approved for investment purposes. Securities
may only be purchased from those authorized institutions and firms. To be
eligible, a broker/dealer must meet at least one of the following criteria: 1)
be recognized as a Primary Dealer as defined by the New York Federal
Reserve Market Reports Division; or 2) report voluntarily to the Market
Reports Division of the Federal Reserve Bank of New York.
Broker/dealers and other financial institutions will be selected by the
Director on the basis of their financial stability, expertise in cash
management and their ability to service the City's account. Each
broker/dealer, bank, or savings and loan that has been authorized by the
City shall be required to submit and annually update a Broker/Dealer
Information Request form which includes the firm's most recent financial
statements. The Director shall maintain a file which includes the most
recent Broker/Dealer information Request forms submitted by each firm
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 9
EXHIBIT A
approved for investment purposes. A copy of the submitted Broker/Dealer
Information Request forms as well as a list of those broker/dealers approved
by the City shall be maintained by the Director.
The Director shall review the quality of service and financial stability
of each broker/dealer and financial institution approved under this Section
at least annually. Any approved broker/dealer or financial institution may
be removed from the list of approved broker/dealers with the approval of
the Director, if in the opinion of the Director, the firm has not performed
adequately or its financial position is considered inadequate.
x.
SELECTION OF DEPOSITORIES
The City shall maintain a list of authorized banks and savings and
loans which are approved to provide Certificates of Deposit. To be eligible
for authorization, a bank or savings and loan must be members of the FDIC
and meet the minimum credit criteria (described below) of a credit analysis
provided by a commercially available bank rating service such as Prudent
Man Analysis, Inc., or Sheshunoff Public Finance Bank Rating Service.
Banks or savings and loans failing to meet the minimum criteria or, in the
judgement of the Director, no longer offer adequate safety for the City will
be removed from the list.
Bank rating guidelines will be calculated using publicly available
information obtained from the Federal Reserve, the Comptroller of the
Currency, or the banking institution itself. Data obtained from bank rating
services will include factors covering the following: overall rating,
liquidity policy, credit risk policy, interest rate policy, profitability ~d
capital policy. Financial institutions selected to issue certificates of deposit
to the City in excess of $100,000 or that are selected as Safekeeping or
Custodial agents for the City shall meet the following criteria: 1) have a
Sheshunoff Public Finance Peer Group Rating of thirty or better on a scale
of zero to one hundred with one hundred being the highest rating at the time
of selection or 2) have a Prudent Man Express Analysis overall rating of
three or better on a scale of one to five with one being the highest quality
for the most recent reporting quarter before the time of selection, and 3)
qualify as a depository of public funds in the State of Texas.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 10
EXHIBIT A
The Director shall maintain a file of the credit rating analysis reports
performed for each approved firm.
In addition to the foregoing requirements, with respect to bond
proceeds and reserves or other funds maintained for debt service purposes,
a depository of such funds must be selected by competitive bidding by two
banks located within the boundaries of the City or if there are not two banks
available within the City's boundaries that are willing and able to accept
such deposits, then at least three bids must be obtained from banks situated
in Collin County that are willing and able to accept such deposits.
XI.
SAFEKEEPING AND CUSTODY
Investment securities purchased for the City will be delivered by
either book entry or physical delivery and shall be held in third-party
safekeeping by a Federal Reserve Member financial institutio~ designated
as the City's safekeeping and custodian bank. The City may designate more
than one custodian bank, but the safekeeping banks shall not be a depository
bank. The City shall execute a Safekeeping Agreement with each bank
prior to utilizing the custodian's safekeeping services. Only a state or
national bank located within the State of Texas may be utilized as a
custodian. of securities pledged to secure certificates of deposit. The
safekeeping agreement must provide that the safekeeping bank will
immediately record and promptly issue and deliver a signed safekeeping
receipt showing the receipt and the identification of the security, as well as
the City's interest.
The Director shall maintain a list of designated custodian banks and
a copy of the Safekeeping Agreement executed with each custodian bank.
The City must approve release of securities in writing prior to their
removal from the custodial account. A telephone facsimile of a written
authorization shall be sufficient if the custodian orally confirms receipt of
the transmission and an exact copy of the document is retained in the City's
files. In no event shall the custodial bank be an authorized depository bank,
issuer of repurchase agreements in which the City invests or broker/dealer
of securities on behalf of the City.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 11
EXHIBIT A
All secunties shall be confirmed in the name of the City and
delivered to an approved custodial bank or carried at a Federal Reserve
Bank in the name of the City. The Custodian shall not otherwise deposit
purchased or pledged securities. All book entry securities owned by the
City shall be evidenced by a safekeeping receipt issued to the City and
signed by the appropriate officer at the custodian bank stating that the
securities are held in the Federal Reserve system in a CUSTOMER
ACCOUNT naming the City as the "customer." In addition, the custodian
bank will, when requested, furnish a copy of the delivery advice received
by the custodian bank from the Federal Reserve Bank.
All certificated securities (those transferred by physical delivery)
shall: 1) be held by an approved custodian bank or any correspondent bank
in New York City approved by the Director; and 2) the correspondent bank
or the City's safekeeping bank shall issue a safekeeping receipt to the City
evidencing that the securities are held by the correspondent bank for the
City.
The original safekeeping receipt for each transaction including
purchased securities under a repurchase agreement and collateral securing
deposits will be forwarded to the Director or his designee and held in a
secured file by the City.
XII.
RECORD KEEPING AND REPORTING
A record shall be maintained of all bids and offerings for securities
transactions in order to ensure that the City receives competitive pricing.
All transactions shall be documented by the person authorizing the
transaction in a form that shows that person's name, the party instructed to
execute the transaction, the date, a description of the transaction and a brief
statement of the reason(s) for the transaction.
Each depository of the City's funds shall maintain separate, accurate
and complete records relating to all deposits of the City's funds, the
securities pledged to secure such deposits and all transactions relating to the
pledged securities. Each approved custodian shall maintain separate,
accurate and complete records relating to all securities received on behalf
City of Wylie Investment Policy
(As Revised May 17. 1995)
Page 12
EXHIBIT A
of the City, whether pledged, purchased or subject to repurchase agreement,
as well as all transactions related to such securities. In addition, each
depository shall file all reports required by the Texas State Depository
Board. Each depository and custodian shall agree to make all the records
described in this paragraph available to the Director's designee and the
City's auditors at any reasonable time.
At least once each quarter, the Director shall verify that all securities
purchased by or pledged to the City are on hand in appropriate form. At
least annually the City's investment program, including the records of
custodians and depositories, shall be audited by independent certified public
accountants selected by the City Council.
All broker/dealers, custodians, depositories and investment advisors
shall maintain complete records of all transactions that they conducted on
behalf of the City and shall make those records available for inspection by
the Director or other representatives designated by the City Councilor City
Manager.
All sales of securities for less than the book value of the security
shall be approved by the Director and reported to the City Council at the
next regular meeting. Sales of securities for less than 98 percent of the
book value of the securities must be approved by both the City Manager
and the Director.
An investment report shall be prepared by the Director on a quarterly
basis listing all of the investments held by the City, the current market
valuation of the investments and transaction summaries, including a detailed
list of the gains and losses recognized. The report shall explain the total
investment return during the previous quarter and compare the portfolio's
performance to other benchmarks of performance.
Within 60 days after the end of the City's fiscal year, the Director
shall prepare, sign and deliver to the City Manager and the City Council an
annual report on the City's investment program and investment activity
which has also been signed by each officer and employee of the City
authorized to conduct any of the City's investment activity. The annual
report shall include full year and separate monthly comparisons of
investment return. Such annual report shall include an analysis of the
compliance with this Policy as well as changes in the applicable laws and
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 13
EXHIBIT A
regulations during the previous year and may include any other items of
significance related to the investment program.
XIII.
ETHICS AND CONFLICTS OF INTEREST
Officers and employees of the City involved in the investment
process shall refrain from personal business activity that involves any of the
City's approved custodians, depositories, broker/dealers or investment
advisors and shall refrain from investing in any security issue held by the
City. Employees and officers shall not utilize investment advice concerning
specific securities or classes of securities obtained in the transaction of the
City's business for personal investment decisions, shall in all respects
subordinate their personal investment transactions to those of the City,
particularly with regard to the timing of purchases and sales and shall keep
all investment advice obtained on behalf of the City and all transactions
contemplated and completed by the City confidential, except when
disclosure is required by law.
XIV.
POLICY REVISIONS
This Investment Policy will be reviewed at least annually by the
Director and may be amended as conditions warrant by the City Council.
City of Wylie Investment Policy
(As Revised May 17, 1995)
Page 14