Res 2014-031/adopting revised Investment Policies for Operating Funds and Reserve Funds

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VII. INVESTMENT PROCEDURES The Investment Officer(s) shall establish reasonable commercial written procedures for the operation of the investment program consistent with this Policy. The procedures should include to safekeeping, repurchase agreements, wire transfer agreements, banking service contracts and collateral /depository agreements. No person may engage in an investment transaction except as provided under the terms of this Policy and the procedures established by the Investment Officer(s). All investment purchases will be executed using the competitive bidding process and settled on a delivery versus payment (DVP) basis. A minimum of three competitive offers on the purchase /sale of every security will be obtained. All investment purchases will be executed in compliance with the Internal Revenue Service's Fair Market Rules. VIII. ETHICS AND CONFLICTS OF INTEREST Investment officers and employees involved in the investment process shall refrain from any personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. Investment Officers shall disclose in writing to the City Manager any material financial interests in financial institutions that conduct business with the City, and they shall further disclose any large personal financial /investment positions that could be related to the performance of the City's portfolio. Investment officers involved in the investment process with personal business relationships or relatives within the second degree of affinity or consanguinity seeking to sell investment/securities to the City shall disclose the relationship and file a statement with the Texas Ethics Commission and the City Council. Personal business relationships are defined in the Act. IX. AUTHORIZED BROKER/DEALERS AND FINANCIAL INSTITUTIONS The objective of safety requires that the City transact business with financially strong broker /dealers and financial institutions. Therefore, financial broker /dealers and institutions shall be subject to a screening process by the Investment Officers or Investment Advisor to eliminate those dealers and institutions that lack economic viability or whose past practices put the safety of public capital at risk. The Investment Advisor under contract will observe the instructions of the City with respect to broker /dealers who are approved to execute transactions involving the City's Managed Funds and in the absence of such instructions will engage broker /dealers which the Advisor reasonably believes to be reputable, qualified and financially sound. These broker /dealers may include "primary" dealers or regional dealers that qualify under Securities and Exchange Commission Rule 15C3 -1 (uniform net capital rule). Authorized dealers and institutions shall provide proof of Financial Institutions Regulatory Authority (FINRA) certification, an annual audited financial statement, and a completed broker /dealer questionnaire. Additional financial institutions may be used for time or demand deposits designed for investment purposes (i.e. not as the primary depository of the City). These institutions may be approved by the Investment Officer(s) on an ongoing basis to accommodate the need for timely action. Action by the Investment Committee is not required before use of such institutions. Each financial institution will provide policy certification and execute a depository agreement. The City may utilize third -party rating agencies in order to assess the overall financial strength of potential depositories. The depository, or its brokerage subsidiary, from which the City obtains banking services including safe- keeping, will not be used for brokerage services in order to perfect ownership on delivery versus payment settlement. The bank may be used for time deposits but all time deposits will be bid competitively. City of San Marcos Investment Policy Page 3