SR 02-28-2017 8A
Ci ty Council
Redevelopment Successor Agency
Report
City Council Meeting : February 28, 2017
Agenda Item: 8.A
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To: Redevelopment Successor Agency, Mayor and City Council
From: Gigi Decavalles -Hughes, Director , Finance Department, Treasury
Subject: Annual Update on City Investment Policy and Resolution to Complete the
Divestment the City's and Successor Agency’s A ssets from Wells Fargo Bank
Recommended Action
Staff recommends that the City Council:
1. Review and approve the City’s revised Investment Policy;
2. Extend the delegation of investment authority to the Director of Finance, as City
Treasurer, from March 1, 2017 through February 28, 2018; and
3. Adopt a resolution setting forth steps to complete the divestment of City assets
from Wells Fargo Bank.
Staff also recommends that the Successor Agency Governing Board:
1. Review and approve the revised Investment Policy for Su ccessor Agency
Investments; and
2. Extend the delegation of investment authority to the Treasurer of the Successor
Agency, from March 1, 2017 through February 28, 2018; and
3. Adopt a resolution setting forth steps to complete the divestment of Successor
Agency assets from Wells Fargo Bank.
Executive Summary
To comply with State law, the City Council must adopt an investment policy and
consider it annually at a public hearing (Attachment A). Additionally, State law requires
that the Council delegate investment authority to the City Treasurer for a one -year
period, renewable annually, and the Santa Monica City Charter delegates the authority
for investing City funds to the Director of Finance as the City Treasurer. Staff is
requesting that the Council and Succes sor Agency consider and adopt a revised
investment policy and delegation of investment authority to the City and Successor
Agency Treasurer for a one year period through February 28, 2018. Additionally,
following a Council motion on February 14, 2017 to d ivest the City’s funds from Wells
Fargo Bank due to their business practices and their involvement in financing the
Dakota Access Pipeline, staff is requesting that the Council and Successor Agency
adopt resolutions setting forth steps to divest the City’s and Successor Agency’s assets
from Wells Fargo Bank.
Background
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Per State law, City Council annually considers and approves the City’s Investment
Policy (Attachment A) and delegates investment authority to the City Treasurer for a
one -year period. The current delegation of authority carries through February 28, 2017.
In addition, Santa Monica City Charter Section 711 delegates the authority to invest City
funds to the City Treasurer.
On February 14, 2017, reacting to Wells Fargo Bank’s past fraudulent practices and to
its involvement in financing the Dakota Access Pipeline, Council, under Item 13C,
approved a motion for the City to break its relationship with Wells Fargo Bank, issue a
new Request for Proposals for general banking services, immediately terminate its
broker/dealer relationship with Wells Fargo, review its investment policy to include
financial service institutions who finance 350.org companies as prohibited investments,
and sell its Wells Fargo bonds, and asked staff to return with a plan on how to
effectuate these changes in a practical and prudent manner.
Discussion
Investment Policy and Compliance with State law
City investments are made only in those instruments specifically authorized by
California State laws, primarily Sections 536 01, 16429.1, and 53684 et seq. of the
Government Code. Within these legal guidelines, t he City’s Investment Policy and
Investment practices have three primary objectives. In priority order, these are :
Safety – Safety of principal is the foremost objectiv e of the City’s investment
program. City investments shall be undertaken in a manner that seeks to ensure
the preservation of capital in the overall portfolio by diversifying its investments
among a variety of securities offering independent returns.
Liq uidity – City investments are kept sufficiently liquid to enable the City to meet
all operating requirements which might be reasonably anticipated by structuring
the portfolio so that securities mature concurrently with anticipated cash needs to
the extent possible. Investments are primarily made in securities with active
secondary or resale markets. Additionally, an adequate liquidity buffer is
maintained for extraordinary circumstances.
Rate of Return – The City’s investment portfolio is designed with the objective of
attaining a benchmark rate of return throughout budgetary and economic cycles,
taking into account safety and liquidity requirements. The benchmark may vary
from time to time depending on the economic and budgetary conditions present.
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Th e City continues to abide by the highest professional standards in the management of
public funds. While the investment strategy is flexible and can change based on market
and economic conditions, the legal and policy guidelines governing these investment
decisions remain relatively static. On an ongoing basis, staff reviews public fund
investment best practices and regulatory or legal changes to ensure City compliance.
Staff has reviewed the latest Local Agency Investment Guidelines Report issued by the
California Debt and Investment Advisory Commission. There are no significant
statutory changes requiring revisions to the City’s Investment Policy. Additionally, the
City’s Investment Policy was recertified by the Association of Public Treasurers United
States and Canada (APT & US&C) in October 2016.
Wells Fargo Bank
At its February 14, 2017 meeting, Council directed staff to completely divest from Wells
Fargo Bank due certain disreputable business practices and its financing of the Dakota
Access Pipeli ne. The City and Successor Agency have a number of relationships with
Wells Fargo, ranging from banking services to investments. The following table lists the
various relationships between the City and Successor Agency and Wells Fargo Bank.
Service Termi nation Date Contract Value
General Banking Services
(7 bank accounts)
3/31/2018
Not -to -exceed $750,000
over the five year term
3 rd Party Custodian for
City’s investment portfolio
30 days’ notice $11,000 per year
Broker Dealer Services Upon Notice $0 (c ompensation
included in price offered
for each specific
investment transaction
Investments Maturing July 2020 and
July 2021
The City’s investment
portfolio includes two
Wells Fargo bonds with a
total book value of $4.6
million.
Bank Loan (Successor
Ag ency)
Maturing January 1,
2018; To be paid off in
full July 2017 (pending
State DOF approval)
$12.7 million remaining
balance
Cemetery/Mausoleum Contract terminated N/A
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Perpetual Care
Investment Management
November 2016
The City expects to be fully div ested from Wells Fargo Bank within 12 to 13 months.
While some divestments are immediate, others require a transition that includes
competitive bidding for new services and complicated operational changes. The
following is a proposed plan for the changeo ver:
General Banking Services – The City’s current contract with Wells Fargo Bank
terminates on March 31, 2018. Changing banks providing general banking
services is a very complex undertaking, requiring not just the movement of funds,
but also changes to all the electronic payments to vendors, payroll direct deposits
to staff, and purchasing card activities. It also includes changes related to
deposits being made by checks, cash, credit cards, electronic payments from
State, County, and Federal agencies, other on -line deposits that require new
software integrations, and deposits from lockbox facilities. Converting to a new
bank, from issuance of an RFP to the complete closure of all accounts with the
old bank, can take twelve months. Staff has already begu n working on the RFP
for banking services and expects to issue it in March 2017.
Investment Portfolio Custodial Services – These services relate to investment
transactions. The third party custodian acts as the agent to ensure all investment
transactions are settled properly and holds all City investments in safekeeping.
This contract can be terminated with 30 days’ notice by either party. However,
converting to a custodian, from issuance of an RFP to the complete transition to
the new custodian, can ta ke three to five months. Staff will begin working on the
RFP and should be able to issue it by mid -March with the goal of divestiture
during the third quarter of 2017.
Broker/Dealer Services – As noted above, Wells Fargo Securities is one of six
broker d ealers currently in the City’s approved list to conduct investment
transactions. This broker dealer agreement can be terminated at any time. Staff
has stopped using the bank as a broker dealer immediately and will formally
notify them of the termination o f the agreement.
Investments – As noted above, the City’s investment portfolio includes two Wells
Fargo bonds with a total book value of $4.6 million with maturity dates of July
2020 and July 2021. Based on the Council 2/14/17 motion that directed staff to
sell the Wells Fargo bonds, staff has begun the process of selling the two Wells
Fargo bonds in the City’s portfolio. Losses on the divestment of these bonds will
be $120,000. No new Wells Fargo securities will be purchased for a minimum
period of fiv e years.
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Bank Loan (Successor Agency) – The original amount of the loan was $60
million with a final maturity date of January 1, 2018; the balance to date is $12.7
million. The City is planning to pay off the remaining loan balance in July 2017
pending S tate Department of Finance approval.
While many public agencies are considering actions regarding their relationship with
Wells Fargo, the following jurisdictions have taken significant action:
State of California – In September 2016, State Treasurer John Chiang
sanctioned Wells Fargo by suspending the purchase of Wells Fargo Securities,
use of Wells Fargo as a broker dealer for investment transactions, and use of
Wells Fargo as an underwriter for the negotiated sale of State bonds. The
sanctions, put in place for one year, were in response to the certain fraudulent
business practices that the bank was fined for.
County of Santa Cruz – In October 2016, Santa Cruz County Board of
Supervisors directed the suspension of any new business with Wells Fargo for
one year due to certain fraudulent business practices that the bank was fined.
University of California – In January 2017, the University of California announced
it will terminate $475 million in credit contracts with Wells Fargo over its ties to
private correctional facilities.
City of Seattle – On February 7, 2017, the Seattle City Council voted to not
renew a contract with Wells Fargo for Bank Depository Services beyond the
initial term of December 2018. In addition, the Council action directed that t he
City will not purchase any new investments in Wells Fargo securities for a period
of three years. The reasons for the divestment were Wells Fargo business
practices and its financial support of the Dakota Access Pipeline (DAPL).
City of Davis – On Feb ruary 8, 2017, the City of Davis City Council voted to
divest from Wells Fargo due to its financing of the DAPL as well as the scandal
regarding its business practices. The City used Wells Fargo for general banking
services and investment custodial servic es.
City of Alameda – Will consider divestment from Wells Fargo at its February 21,
2017 meeting for the same reasons as described above.
Recommendations for Santa Monica
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In light of the Council’s actions on February 14, 2017, staff recommends that the
C ouncil and Successor Agency approve revisions to the City’s Investment Policy
changing Section 17(b), Socially Responsible Investing, to state that t he direct
investment of City funds is restricted as follows: “No investments will be made in fossil
fuel c ompanies as defined by the organization 350.org or in banking institutions that
provide financing to said companies ” and also adopt the attached resolutions that set
forth the following course of action to divest the City and Successor Agency’s assets
from Wells Fargo Bank:
Issuance of a new Request for Proposals (RFP) for five years of new banking
services with a qualified banking institution with a demonstrated commitment to
and history of fair business practices, to take effect on or before March 31, 201 8,
the termination date of the City's current contract with Wells Fargo Bank;
Issuance of a new RFP for investment portfolio custodial services with a goal of
divestiture from Wells Fargo by the third quarter of 2017;
Immediate termination of Wells Farg o Securities as the City's broker dealer;
Payment of the Successor Agency's outstanding loan obligations to Wells Fargo,
pending approval by the State Department of Finance.
Disqualification of any banking institution that has been subject to a consent
order for improper sales practices, placed by the Consumer Financial Protection
Bureau or other federal or state regulatory agency with jurisdiction to protect
consumers from improper sales practices, from providing investment, debt,
and/or banking servic es to the City if the consent order was issued within five
years of the City's solicitation for such services.
Financial Impacts and Budget Actions
The selling of the two Wells Fargo bonds resulted in a loss of $114,000. All other
actions will not have a financial impact. Staff provides monthly reports to the City
Council and the City Manager describing the present status of City investments and
monies held by the City, as well as summarizing all investment transactions for the
month. Interest earnings from the City’s pooled investment portfolio are allocated to the
various City funds based upon each fund’s share of total City cash and investments.
Projected investment earnings for each fund are included in the FY 2016 -17 Revised
Budget. No budget act ion is required at this time.
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Prepared By: David Carr, Assistant City Treasurer
Approved
Forwarded to Council
Attachments:
A. Annual Update on City Investment Policy
B. Wells Fargo Divestment Reso CC
C. Wells Fargo Divestment Reso SA
D. Written Comments
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Revised 2/1 7
ATTACHMENT 1
INVESTMENT POLICY FOR THE CITY OF SANTA MONICA
1. POLICY
It is the policy of the City of Santa Monica (City) to invest public funds in a manner
which will safely preserve portfolio principal, provide adequate liquidity to meet the
City’s cash flow needs, and optimize returns while conforming to all federal, state,
and local statutes governing the investment of public funds.
2. SCOPE
This investment policy applies to all cash and financial investments of the various
funds of the City of Santa Monica as identified in the City's Comprehensive Annual
Financial Report, with the exception of those financial assets explicitly excluded from
coverage by the Investme nt Policy for legal or operational reasons. Cemetery and
Mausoleum Perpetual Care Funds are private funds held in trust and managed by
the City. These funds do not fall under the guidelines of the Government Code
sections noted in Section 8.0 of this Policy, but are invested by an outside investment
manager under guidelines established by the City Council.
All City f unds are listed in Attachment 1 -A . The Investment Policy will also apply to
all new funds created unless specifically exempted.
Except as otherwise noted, City funds are pooled for investment purposes.
Investment income will be allocated to the various funds based on their respective
participation and in accordance with generally accepted accounting principles.
Interest is alloca ted on a quarterly basis.
3. PRUDENCE
Investments shall be made with judgment and care, under circumstances then
prevailing, which persons of prudence, discretion, and intelligence exercise in
management of their own affairs, not for speculation, but for i nvestment considering
the probable safety of their capital as well as the probable income to be derived.
The standard of prudence to be used by investment officials shall be the “prudent
person” and/or “prudent investor” standard and shall be applied in the context of
managing an overall portfolio. Investment officers acting in accordance with written
procedures and the investment policy and exercising due diligence shall be relieved
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of personal responsibility for an ind ividual security’s credit risk or market price
changes, provided deviations from expectations are reported in a timely fashion and
appropriate action is taken to control adverse developments.
4. INVESTMENT OBJECTIVES
The primary objective of all City inv estments , in priority order , shall be:
4.1 SAFETY
Safety of principal is the foremost objective of the investment program. City
investments shall be undertaken in a manner that seeks to ensure the
preservation of capital in the overall portfolio. To attain this, the City will
diversify its investments by investing funds in securities of various types and
from various issuers offering independent returns .
4.2 LIQUIDITY
Liquidity is the ability to change an investment into its cash equivalent on short
notice at its prevailing market value. The City’s investment portfolio shall
remain sufficiently liquid to enable the City to meet all operating requirements
which might be reasonably anticipated. This is accomplished by structuring the
portfolio so that securi ties mature concurrent ly with anticipated cash needs.
Since all possible cash demands cannot be anticipated, the portfolio will
maintain a liquidity “buffer” and invest primarily in securities with active
secondary or resale markets.
4.3 R ATE OF R ETURN
The City’s investment portfolio shall be designed with the objective of attaining
a benchmark rate of return throughout budgetary and economic cycles, taking
into account safety and liquidity requirements. The benchmark may vary from
time to time dependin g on the economic and budgetary conditions present. At
no time shall funds be invested in any security that could result in zero interest
accrual if held to maturity.
5. INVESTMENT AUTHORITY DELEGATION
In accordance with the Santa Monica City Charter, Sec tion 711, the City Council
delegates to the City Treasurer the authority to invest City funds. The Director of
Finance , as City Treasurer, delegate s this authority to the Assistant City Treasurer .
In the absence of the Director of Finance and the Assistant City Treasurer , authority
to invest City funds may be delegated to the Principal Treasury Analyst . Section
53607 of the State of California Government Code limits the authorization of the
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legislative body to delegate investment authority to a on e -year period, renewable
annually.
5.1 INVESTMENT PROCEDURES
The Director of Finance is responsible for conducting and reporting on all City
investments. To facilitate this function, the Director of Finance or their designee
will prepare and maintain an Investment Procedures Manual detailing
procedures for the operation of the investment program consistent with this
policy. The manual should include reference to safekeeping, banking services
contracts, collateral/depository a greements, and repurchase agreements. The
manual shall also include explicit delegation of authority to persons responsible
for investment transactions. No person may engage in investment transactions
except as provided under the terms of this policy and the procedures
established by the Director of Finance . Additionally, the manual will explicitly
include a current listing of all City of Santa Monica financial institution deposit
and investment accounts, a current copy of State laws pertinent to City
in vestments, a description of specific controls to ensure the proper execution
of the City Investment Policy, and copies, with instructions, of all investment
reports required by law or by City Investment Policy.
5.2 INVESTMENT COMMITTEE
An Investment Committee (the Committee) shall be established consisting of
the City Manager, the Assistant City Manager, the Director of Finance , the
Assistant City Treasurer , one other department head serving one -year terms
on a rotating basis , and one qu alified citizen representative , appointed by the
City Manager for a one -year term, who possesses strong skills and knowledge
in the areas of finance and economics . The purpose of the Committee is to
provide general oversight and act in an advisory capacit y. The Committee will
meet once each calendar quarter to review and evaluate previous investment
activity, to review the current status of all funds held by the City, to discuss
anticipated cash requirements and investment activity for the next quarter, a nd
to discuss investment strategy .
6. ETHICS AND CONFLICTS OF INTEREST
The Director of Finance and other employees involved in the investment process
shall refrain from personal business activity that could conflict with proper execution
of the investment program, or which could impair their ability to make impartial
investment decisions. The Direc tor of Finance and other employees involved in the
investment process shall disclose any material interests in financial institutions with
which they conduct business within their jurisdiction, and they shall further disclose
any material personal financia l/investment positions that could be related to the
performance of the City’s investment portfolio and shall refrain from personal
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investment transactions with the same individual or firm with whom business is
conducted on behalf of the City.
The Direct or of Finance and other employees involved in the investment process are
required to file annual disclosure statements as required by the Fair Political
Practices Commission. During the course of the year, if there is an event subject to
disclosure that c ould impair the ability of the Director of Finance or investment
employees to make impartial decisions, the City Council will be notified in writing
within ten (10) days of the event.
7. AUTHORIZED FINANCIAL DEALERS AND INSTITUTIONS
The City shall transact business only with issuers, banks, savings and loans, and
registered securities dealers. The purchase of any investment, other than those
purchased directly from the issuer, shall be purchased from either an institution
licensed by the State as a broker/dealer as defined in Section 25004 of the
Corporation Code, who is a member FINRA (Financial Industry Regulatory Authority ,
or a member of a federally regulated securities exchange, a national or state
chartered bank, a federal or state association (as def ined by Section 5102 of the
Financial Code ), or a brokerage firm designated as a primary dealer by the Federal
Reserve Bank.
The Director of Finance ’s staff shall periodically conduct a “Request for
Qualifications” process to investigate broker/dealers that wish to do business with
the City in order to determine if they are adequately capitalized, make markets in
securities appropriate to the City’s needs, and agree to abide by the City’s
Investment Policy. All institutions that desire to become qualifi ed bidders for
investment transactions must complete City’s “Broker/Dealer Request for
Information” and “Broker/Dealer Certification”.
The Director of Finance shall conduct periodic review s of the financial condition and
other qualifications of all appro ved financial institutions and broker/dealers to
determine if they continue to meet the City’s guidelines for qualification as defined
in this section . Additionally, the City shall keep the current audited financial
statements on file for each approved f i nancial institution and broker/dealer with
which the City conducts investment transactions. A listing of websites where these
financial statements may be viewed may substitute for physical hard copies of the
statements.
8. AUTHORIZED AND SUITABLE INVESTMEN TS
Investments shall be made only in those instruments specifically authorized by
California State laws, primarily Sections 53601, 53601.6, 53601.8 , 16429.1, and
53684 et sq. of the Government Code and to no greater an extent than authorized
by those laws. These laws are summarized in Attachment 1 -B . Additional City
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guidelines are as follows:
Instruments Additional City Guidelines
U.S. Federal Agencies No more than 50% of p ortfolio, per agency
Banker's Acceptances (BA) Maximum of 10% of portfolio per issuer
Neg otiable Certificates of Deposit Maximum of 10% of portfolio per issuer
(NCD)
Commercial Paper (CP) Maximum of 15% of portfolio
It is recognized that legal or other events may occur that could require revision of
certain guidelines.
In addition to following all legal guidelines, the portfolio will preserve principal,
maintain adequate liquidity to meet all City obligations, cont ain an appropriate level
of interest rate risk, and be diversified across types of investments, maturities, and
institutions to minimize credit risk and maintain an appropriate return.
8.1 REPURCHASE AGREEMENTS
Investments in repurchase agreements are allowa ble and shall be made only
with financial institutions with which the City has an executed master
repurchase agreement. The financial institution must be a primary dealer of
the Federal Reserve Bank of New York.
8.2 PROHIBITED INVESTMENTS AND TRANSACTIONS
Prohibited investments include as inverse floaters, range notes, interest only
strips derived from a pool of mortgages (collateralized mortgage obligations),
and any security that could result in zero interest accrual if held to maturity, as
specified in S ection 53601.6.
8.3 INVESTMENTS HELD AND/OR MANAGED BY FISCAL AGENTS AND
TRUSTEES
In addition the main pooled portfolio, the City may hold and invest certain other
funds that are restricted as to use. One example is bond proceeds held by
fiscal agents . Investments of bond or loan proceeds will be made in
accordance with Government Code Section 53601 (m ), which states that
money from bond proceeds should be invested as specified by bond
documents , and in accordance with specific bond covenants . In most cases
these investments will be made under the same guidelines as other City
investments. Another example is funds received from legal settlements that
are restricted for a certain purpose , which will be invested in accordance with
legal or escrow agreeme nts that may be more restrictive than the City’s Policy.
As noted previously in this Policy, Cemetery and Mausoleum Perpetual Care
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Funds are private funds held in trust by the City. These funds are invested by
an outside investment manager under guidel ines adopted by the City Council
and do not fall under the guidelines of the Government Code sections noted in
Section 8.0 of this Policy . The Director of Finance’s staff monitors all
investment activity of these funds to ensure guidelines are followed.
9. INVESTMENT POOLS/MUTUAL FUNDS
A thorough investigation of any pooled investment funds, including mutual funds, is
required prior to investing, and on a continual basis. To accomplish this, a
questionnaire will be used to evaluate the suitability of the pooled fund. The
questionnaire will answer the following general questions:
A description of eligible investment securities, and a written statement of
investment policies and objectives.
A description of interest calculations and how it is distributed, and how gains and
losses are treated.
A description of how the securities are safeguarded (including the settlement
processes), and how often the securities are priced and the program audited.
A description of who may invest in the program, how often, and what size deposit
and withdrawal are allowed.
A schedule for receiving statements and portfolio listings.
Are reserves, retained earnings, etc., utilized by the pool/fund?
A fee schedule, and when and how fees are assessed.
Is the pool/fund eligible for bo nd proceeds and/or will it accept such proceeds?
For mutual funds, a fund prospectus can substitute for the questionnaire.
10. COLLATERALIZATION
California Government Code Sections 53652, et seq. requires depositories to post
certain types of collateral fo r public funds above the Federal Deposit Insurance
Corporation (FDIC) insurance amounts. The collateral requirements apply to bank
deposits, both active (checking and savings accounts) and inactive (non -negotiable
certificates of deposit).
Collateralizat ion is also required for repurchase agreements. In order to anticipate
market changes and provide a level of security for all funds, the collateralization level
will be 102% of the market value of principal and accrued interest, and the value
shall be adj usted no less than quarterly. Collateral will be in the form of U.S.
Treasury Obligations or U.S. Agency Securities.
Collateral will always be held by an independent third party with whom the entity has
a current custodial arrangement. A clearly marked evidence of ownership
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(safekeeping receipt) must be available to be supplied to the City , if requested, and
retained. The right of collateral substitution is granted.
11. SAFEKEEPING AND CUSTODY
In accordance with California Government Code Section 53601, all securities owned
by the City shall be held in safekeeping by the City’s custodial bank or a third party
bank trust department, acting as an agent for the City under terms of the custody
agree ment. Collateral for repurchase agreements will be held by a third party
custodian under terms of the Master Repurchase Agreement.
All securities will be received and delivered using a delivery vs. payment (DVP)
basis, which ensures that securities are deposited with the third party custodian prior
to the release of funds. Securities held by the third party custodian will be evidenced
by safekeeping receipts and/or bank statements . Investments in the State Local
Agency Investment Fund (LAIF) or money market mutual funds are undeliverable
and are not subject to delivery or third party safekeeping.
Investment trades shall be verified against bank transactions and broker
confirmation tickets. On a monthly basis, t he custodial asset statement shall be
reconciled with the month -end portfolio holdings.
12. DIVERSIFICATION
The City will diversify its investments by security type, institution, and maturity date.
Concentration limits are set by the State Government Code (see Attachment B) and
Section 8.0 (Authorized and Suitable Investments) of this policy .
13. MAXIMUM MATURITIES
To the extent possible, the City will attempt to match its investments with anticipated
cash flow requirements. Unless matched to a specific cas h flow, the City will not
directly invest in securities with a final stated maturity date of more than five (5) years
from the date of purchase settlement . Any investment of more than five years
requires the advance approval of the City Council, in accord ance with State law, and
the City Manager. Further maturity limitations are shown in Attachment B . The
weighted average maturity of the investment portfolio should be three years or less.
In order to minimize the impact of market risk, most investments will be purchased
with the intent to hold to maturity. Investments may be sold prior to maturity for cash
flow needs, portfolio rebalancing and/or appreciation purposes, or in order to
mitigate portfolio risk by limit ing potential losses. However, no investment shall be
made based solely on earning s anticipated from capital gains. Due to the uncertain
nature of cash flow requirements, a portion of the portfolio should be continually
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invested in readily available funds.
14. INTERNAL CONTROLS
The Director of Finance shall be responsible for ensuring that all investment
transactions comply with the City’s Investment Policy and for establishing internal
controls that are designed to prevent losses due to fraud, negligence, and third -pa rty
misrepresentation .
The Director of Finance will also establish internal control procedures addressing
wire transfer controls, separation of duties and administrative controls, avoidance of
collusion, separation of transaction authority from accounting procedures,
documentation of investment transactions, and monitoring of results.
As part of its annual audit of the City, the City’s external auditor will review
compliance with statutes, policies, and procedures.
15. PERFORMANCE STANDARDS
The portfolio shall be designed with the objective of obtaining a rate of return
throughout budgetary and economic cycles, commensurate with investment risk
constraints and cash flow needs.
15.1 MARKET YIELD (Benchmark)
The City’s overall investment strategy is passive. G iven this strategy, the basis
used by the Director of Finance to determine whether appropriate and suitable
market yields are being achieved shall be to identify a comparable benchmark
to the portfolio’s investment duration, e.g. the Constant Maturing Two Year
Treasury bill index. Benchmarks may change over time depending on the
portfolio’s duration.
16. REPORTING
In accordance with State law and the City Charter, monthly reports will be made to
the City Council and the City Manager describing the present s tatus of City
investments and monies held by the City, as well as summarizing all investment
transactions for the month. Schedules in the monthly report should include the
following:
A complete list of investments including the type of the investment, name of the
issuer, maturity date, par value, book value, and market value
The source of market value data
The weighted average maturity and yield to maturity of the portfolio
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Coupon, discount, or earnings rate for each security
P ercentage of portfolio represented by each investment category
A certification of compliance with the Investment Policy
A statement denoting the City’s ability to meet its anticipated expenditures
requirements for the next six months
Benchmark comparison
Records of all investment transactions will be kept and filed in the Finance
Department in accordance with legal guidelines and records retention policies .
17. SOCIALLY RESPONSIBLE INVESTING
RESTRICTIONS – The direct investment of City funds are restricted as follows:
a. Investments are to be made in entities that support clean and healthy
environment, including following safe and environmentally sound practices.
b. No investments will be made in fossil fuel companies as defined by the
organization 350.org or in banking institutions that provide financing to said
companies .
c. No investments are to be made in tobacco or tobacco -related products.
d. No investments are to be made to support the production of weapons, military
systems, or nuclear power.
e. Investments are to be made in entities that support equality of rights regardless
of sex, race, age, disability or sexual orientation.
f. Investments are to be made in entities that promote community economic
development.
Funds invested with trustee and/or outside investment managers such as the
Cemetery and Mausoleum Perpetual Care Funds will comply with this section of the
policy.
18. COMMUNITY REINVESTMENT ACT (CRA)
The City will deposit funds only in those financial institutions, which have a CRA
rating (as determined by the appropriate regulatory body) of "Outstanding" or
"Satisfactory".
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19. INVESTMENT POLICY ADOPTION
The City’s investment policy shall be reviewed and adopted by the City Council
annually. The Investment Committee will review the policy periodically to ensure its
consistency with the overall objectives of preservation of principal, liquidity, and
return, and its conformance with current law, financial and economic trends, and
cash flow needs of the City.
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ATTACHMENT 1 -A
City of Santa Monica Funds for Cash Pooling
The following listed City of Santa Monica funds shall have their cash balances pooled
for investment purposes :
FUND NUMBER
FUND NAME
01 GENERAL FUND
04 SPECIAL REVENUE SOURCE FUND
06 CLEAN BEACHES AND OCEAN PARK PARCEL TAX FUND
11 BEACH RECREATION FUND
12 HOUSING AUTHORITY FUND
14 TENANT OWNERSHIP RIGHTS CHARTER AMENDMENT
FUND 15 LOW/MODERATE INCOME HOUSING ASSET FUND
19 COMMUNITY DEVELOPMENT BLOCK GRANT (CBDG) FUND
20 MISCELLANEOUS GRANTS FUND
21 ASSET SEIZURE FUND
22 CITIZENS OPTION FOR PUBLIC SAFETY FUND
25 WATER FUND
27 SOLID WASTE MANAGEMENT FUND
28 COMMUNITY BROADBAND FUND
29 RENT CONTROL FUND
30 PIER FUND
31 WASTEWATER FUND
33 AIRPORT FUND
34 STORMWATER MANAGEMENT FUND
37 CEMETERY FUND
41 BIG BLUE BUS FUND
42 TRAFFIC SAFETY FUND
43 GAS TAX FUND
44 SC AQMD AB2766 FUND
45 LOCAL RETURN FUND
53 PARKS AND RECREATION FACILITIES FUND
54 VEHICLE MANAGEMENT FUND
55 INFORMATION TECHNOLOGY REPLACEMENT AND
SERVICES FUND
56 SELF INSURANCE -GENERAL LIAB/AUTO FUND
57 SELF INSURANCE -BUS FUND
58 SELF INSURANCE -ADMIN FUND
59 SELF INSURANCE WORKERS -COMPENSATION FUND
77 PARKING AUTHORITY FUND
A -2
FUND NUMBER
FUND NAME
80 GENERAL TRUST FUND
82 CEMETERY PERPETUAL CARE FUND
89 MAUSOLEUM PERPETUAL CARE FUND
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ATTACHMENT 1 -B
Summary of State of California Statutes Applicable to Municipal Investments
The following investments are authorized by California State Code, Title 5, Division 2,
and Sections 53600, 53601, 53631.5 and 53635. See code sections for complete
descriptions.
Authorized Investment
Legal
Limit (%) Other Constraints
Local Agency Bonds No limit Maximum maturity 5 years.
U.S. Treasury Obligations No limit Maximum maturity 5 years.
State Obligations -
California and Others
No limit Maximum maturity 5 years.
California Local Agency
Obligations
No limit Maximum maturity 5 years.
U.S. Agenc y Obligations No limit Maximum maturity 5 years.
Bankers Acceptance 40% Eligible for purchase by the Federal Reserve
System and not to exceed 180 days to
maturi ty. No more than 30% may be in
bankers ' acceptances of any one commercial
bank.
Commercial Paper –
Select Agencies
25% "A -1 /P - 1/F - 1 " rating; if the issuer has
long -term debt, it must rated “A”; U.S.
corporate assets over $500,000,000;
purchases may not represent more than 10%
of outstanding paper and may not exceed 270
days to maturity. The maximum limit on
commercial paper is 25% of all investments .
Commercial Paper –
Other Agencies
40% "A -1 /P - 1/F - 1 " rating; if the issuer has
long -term debt, it must rated “A”; U.S.
corporate assets over $500,000,000;
purchases may not represent more than 10%
of outstanding paper and may not ex ceed 270
days to maturity. The maximum limit on
commercial paper is 25% of all investments .
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Authorized Investment
Legal
Limit (%) Other Constraints
Negotiable Certificates of
Deposit
30% Maximum maturity 5 years . State and
Federally chartered banks and savings
institutions, including U.S. branches of foreign
banks regulated by State regulatory
authorities ("Yankee CD").
Deposit/CD Placement
Services
30% Maximum maturity 5 years with a sunset date
of January 1, 2021 for deposits; no sunset
date for CD’s . Deposits with any one private
sector placement service are limited to 3 0% of
the portfolio. This limit does not apply to
placement service -assisted CD’s.
Repurchase Agreement No limit Maximum maturity 1 year . Securities used as
collateral for repo's must be investments
allowable under Govt. Code (i.e., T -bills,
Agencies, BAs, CDs, etc.); must be
collateralized at 102% of market value or
greater; securities must be safe kept by third
party.
Reverse Repurchase
Agreements /Securities
Lending Agreements
20% Must be made with primary dealers of the
Federal Reserve Bank of New York and the
securities used for the agreement must have
been held by the local agency for at least 30
days. The maximum maturity is 92 days.
Medium -Term Corporate
Notes
30% Maximum maturity 5 years; bonds must be
rated minimum of “A” by a nationally
recognized rating service.
Mutual Funds and Money
M arket Mutual F unds
20% No more than 10% may be invested in any
one mutual fund. Funds are invested in
securities and obligations authorized by sub -
divisions (a) through (m) of Section 53601 and
53635, (any of the authorized investments for
local agencies) the investment company must
be in highest ranking provided by not less than
two of the three largest nationally recognized
rating services OR must have the investment
advisor registered with the SEC with no less
than 5 yrs. experience and have assets under
mgmt. in excess of $5 00 million.
B -3
Authorized Investment
Legal
Limit (%) Other Constraints
Supra N ationals
(International Bank for
Reconstruction and
Development.
International Finance
Corporation, Inter -
American Development
Bank
30% Maximum maturity 5 years. Must be rated AA
or better by a nationally recognized rating
service. Must be senior unsubordinate
obligations denominated in U.S. Dollars.
Money Market Funds 20% The money market funds must have an
average weighted maturity of 90 days or less
and abide by SEC regulations; funds must
receive the highest ranking by 2 of th e 3
largest nationally recognized rating agencies
OR retain an investment advisor who is
registered, or exempt from registration, with
the SEC and has at least 5 years experience
managing money market funds in excess of
$500 million.
Collateralized Certificate
of Deposit
No limit Maximum maturity 5 years . Banks: deposit
not to exceed the total of paid -in capital
surplus . S&Ls: deposit not to exceed the
greater of total net worth or $500,000. State
and Federal credit unions: deposit shall not
ex ceed the greater of the total of unpaired
capital and surplus or $500,000. Must be
collateralized to 110% of the CD value by
other eligible securities. Investments in
certificates of deposits of state or federal
credit unions if any member of the city’s
governing or managing officers (council, city
manager, fiscal officers) serves on the credit
union board or key committee positions is
prohibited.
Mortgage Pass -Through 20% Maximum maturity 5 years; bonds must be
rated in top two rating categories by a
na tionally recognized rating service. Shall not
exceed 95% of the mortgage security's fair
market value. Issuer must have rating of “A”
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Authorized Investment
Legal
Limit (%) Other Constraints
or higher on issuer’s debt.
Bank/Time Deposits No Limit Maximum maturity of 5 years
Local Agency Investment
Fund (LAIF)
$ 65
million **
Monies are invested in pooled state fund
manag ed by State Treasurer. Maximum 15
transactions per month.
Joint Powers Authority
Pool
No limit
County Pooled
Investment Funds
No limit
** Per LAIF account. Separate accounts can be established for different legal entities.
Bond Proceeds
Bond proceeds may be invested in accordance with the State Code and bond indenture
provisions.
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ATTACHMENT 1 -C
GLOSSARY
AGENCIES: Federal agency securities and /or Government Sponsored Enterprises
(GSE’s).
ASKED: The price at which securities are offered for sale .
BANKERS’ ACCEPTANCE (BA): A draft or bill of exchange accepted by a bank or trust
company. The accepting institution guarante es payment of the bill, as well as the issuer.
BASIS POINT: A basis point equals one one -hundredth of 1% (.01%).
BENCHMARK: A comparative base for measuring the performance or risk tolerance of
an investment portfolio. The benchmark should represent a close correlation to the level
of risk and the average duration of the portfolio.
BID: The price offered for securities.
BROKER: A broker brings buyers and sellers together for a commission.
CALLABLE SECURITY: A security that can be redeemed by the issuer before the
scheduled maturity date.
CERTIFICATE OF DEPOSIT (CD): A time deposit with a specific maturity evidenced by
a certificate. Large denomination CD’s are typically negotiable.
COLLATERAL: Securities, evidence of deposit or other property which a borrower
pledges to secure repayment of a loan. Also refers to securities pledged by a bank to
secure deposits of public monies.
COMPREHENSIVE ANNUAL FINANCIAL REPORT (CAFR): The official annual report
for the City of Santa Monica. It includes basic financial statements for each individual
fund and account group prepared in conformity with GAAP. It also includes supporting
schedules necessary to demonstrate compliance with finance -related legal and
contractual provisions, extensive introductor y material, and a detailed Statistical Section.
COMMERCIAL PAPER (CP): An unsecured promissory note with a fixed maturity no
longer than 270 days. Usually sold in discount form .
COUPON: (a) The annual rate of interest that a bond's issuer promises to pay the
bondholder on the bond's face value. (b) A certificate attached to a bond evidencing
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interest due on a payment date.
DEALER: A dealer, as opposed to a broker, acts as a principal in all transactions, buying
and selling for his own account.
DE LIVERY VERSUS PAYMENT (DVP): There are two methods of delivery of securities:
delivery versus payment and delivery versus receipt (also called free). Delivery versus
payment is delivery of securities with an exchange of money for the securities. Delive ry
versus receipt is delivery of securities with an exchange of a signed receipt for the
securities.
DEBENTURE: A bond secured only by the general credit of the issuer.
DERIVATIVES: (1) Financial instruments whose return profile is linked to, or derive d
from, the movement of one or more underlying indices or securities, and may include a
leveraging factor, or (2) financial contracts based on notional amounts whose value is
derived from an underlying index or security (interest rates, foreign exchange ra tes,
equities, or commodities).
DISCOUNT: The difference between the cost price of a security and its value at maturity
when quoted at lower than face value. A security selling below original offering price
shortly after sale also is considered to be at a discount.
DISCOUNT SECURITIES: Non -interest bearing money market instruments that are
issued at a discount and redeemed at maturity for full face value (e.g., U.S. Treasury bills ,
commercial paper, Agency discount notes ).
DIVERSIFICATION: Dividing investment funds among a variety of securities , issuers ,
and maturity dates offering independent returns.
DURATION: A measure of the timing of the cash flows, such as the interest payments
and the principal repayment, to be received from a given fixed -in come security. This
calculation is based on three variables: term to maturity, coupon rate, and yield to
maturity. The duration of a security is a useful indicator of its price volatility for given
changes in interest rates.
FEDERAL CREDIT AGENCIES: Ag encies of the Federal government set up to supply
credit to various classes of institutions and individuals, e.g., S&L's, small business firms,
students, farmers, farm cooperatives, and exporters.
FEDERAL DEPOSIT INSURANCE CORPORATION (FDIC): A federal a gency that
insures bank deposits, currently up to $250,000 per deposit.
FEDERAL FUNDS: Non -interest bearing deposits held by member banks at the Federal
Reserve. Also used to denote "immediately available" funds in the clearing sense. "Fed
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Funds" also used to refer to these funds.
FEDERAL FUNDS RATE: The rate of interest at which private banks lend funds to other
private banks. The Federal Open Market Committee (FOMC) sets a target rate . This
actual rate is currently pegged by the Federal Reserve t hrough open -market operations.
FEDERAL HOME LOAN BANKS (FHLB): Government sponsored wholesale banks
(currently 12 regional banks) which lend funds and provide correspondent banking
services to member commercial banks, thrift institutions, credit unions, and insurance
companies. The mission of the FHLB’s is to liquefy the housing related assets of
members who must purchase stock in their district Bank.
FEDERAL HOME LOAN MORTGAGE CORPORATION (FHLMC): A Government
Sponsored Enterprise that provides liqui dity to the mortgage markets, much like FNMA
and FHLB. Also referred to as “Freddie M ac”.
FEDERAL NATIONAL MORTGAGE ASSOCIATION (FNMA): FNMA, like GNMA was
chartered under the Federal National Mortgage Association Act in 1938. FNMA is a
federal corpora tion working under the auspices of the Department of Housing & Urban
Development, H.U.D. It is the largest single provider of residential mortgage funds in the
United States. Fannie Mae, as the corporation is called, is a private stockholder -owned
corpor ation. The corporation’s purchases include a variety of adjustable mortgages and
second loans in addition to fixed -rate mortgages. FNMA's securities are also highly liquid
and are widely accepted. FNMA assumes and guarantees that all security holders wi ll
receive timely payment of principal and interest.
FEDERAL OPEN MARKET COMMITTEE (FOMC): Consists of seven members of the
Federal Reserve Board and five of the twelve Federal Reserve Bank Presidents. The
President of the New York Federal Reserve Bank is a permanent member while the other
Presidents serve on a rotating basis. The Committee periodically meets to set Federal
Reserve guidelines regarding purchases and sales of Government Securities in the open
market as a means of influencing the volume o f bank credit and money.
FEDERAL RESERVE SYSTEM: The central bank of the United States created by
Congress and consisting of a seven -member Board of Governors in Washington, D.C.,
12 Regional Banks , and about 5,700 commercial banks that are members of t he system.
GOVERNMENTAL NATIONAL MORTGAGE ASSOCIATION (GNMA or Ginnie Mae):
Securities influencing the volume of bank credit guaranteed by GNMA and issued by
mortgage bankers, commercial banks, savings and loan associations and other
institutions. Securi ty holder is protected by full faith and credit of the U.S. Government.
Ginnie Mae securities are backed by FHA, VA or FmHM mortgages. The term pass -
throughs is often used to describe Ginnie Maes.
INVERSE FLOATERS: A structured note in which the coupon increase as interest rates
decline and decrease as rates rise.
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LIQUIDITY: Liquidity is the ability to change an investment into its cash equivalent on
short notice at its prevailing market value. In the money market, a security is said to be
liquid if the spread between bid and asked prices is narrow and reasonable size can be
done at those quotes.
LOCAL AGENCY INVESTMENT FUND (LAIF): The aggregate of all funds from political
subdivisions that are placed in the custody of the State Treasurer for inves tment and
reinvestment.
MARKET VALUE: The price at which a security is trading and could presumably be
purchased or sold.
MASTER REPURCHASE AGREEMENT: A written contract covering all future
transactions between the parties to repurchase -reverse repurch ase agreements that
establishes each party's rights in the transactions. A master agreement will often specify,
among other things, the right of the buyer -lender to liquidate the underlying securities in
the event of default by the seller -borrower.
MATUR ITY: The date upon which the principal or stated value of an investment becomes
due and payable.
MONEY MARKET: The market in which short -term debt instruments (bills, commercial
paper, bankers' acceptances, etc.) are issued and traded.
OFFER: The pric e asked by a seller of securities (When you are buying securities, you
ask for an offer). See ASKED AND BID.
OPEN MARKET OPERATIONS: Purchases and sales of government and certain other
securities in the open market by the New York Federal Reserve Bank, as directed by the
FOMC, in order to influence the volume of money and credit in the economy. Purchases
inject reserves into the bank system and stimulate growth of money and credit; sales have
the opposite effect. Open market operations are the Federal Reserve's most important
and most flexible monetary policy tool.
PORTFOLIO: Collection of securities held by an investor.
PRIMARY DEALER S : A group of government securities dealers that submit daily reports
of market activity and positions and monthly f inancial statements to the Federal Reserve
Bank of New York and are subject to its informal oversight. Primary dealers include
Securities and Exchange Commission (SEC) registered securities broker -dealers, banks,
and a few unregulated firms.
PRIME RATE: The rate at which banks lend to their best or "prime" customers.
PRINCIPAL: 1) the dollar cost of an issue excluding accrued interest. 2) The one who
takes ownership in a transaction, as opposed to brokering or acting as agent.
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PRUDENT PERSON RULE: An investment standard. In some states the law requires
that a fiduciary, such as a trustee, may invest money only in a list of securities selected
by the state (the so -called legal list). In other states, the trustee may invest in a security
if it is o ne, which would be brought by a prudent person of discretion and intelligence who
is seeking a reasonable income and preservation of capital.
QUALIFIED PUBLIC DEPOSITORIES: A financial institution which does not claim
exemption from the payment of any sales or compensating use or ad valorem taxes under
the laws of this state, which has segregated for the benefit of the commission eligible
collateral having a value of not less than its maximum liability and which has been
approved by the Public Deposit P rotection Commission to hold public deposits.
RATE OF RETURN: The yield obtainable on a security based on its purchase price or
its current market price . This may be the amortized yield to maturity on a bond or the
current income return.
REPURCHASE AGR EEMENT (RP OR REPO): A holder of securities sells these
securities to an investor with an agreement to repurchase them at a fixed price on a fixed
date. The security "buyer" in effect lends the "seller" money for the period of the
agreement, and the term s of the agreement are structured to compensate him for this.
Dealers use RP extensively to finance their positions. Exception: When the Fed is said
to be doing RP, it is lending money, that is, increasing bank reserves.
REVERSE REPO: An agreement wher eby the dealer agrees to buy securities and the
investor agrees to repurchase them at a later date.
SAFEKEEPING: A service to customers rendered by banks for a fee whereby securities
and valuables of all types and descriptions are held in the bank's vaul ts for protection.
SECONDARY MARKET: A market made for the purchase and sale of outstanding issues
following the initial distribution.
SEC RULE 15C3 -1: See uniform net capital rule.
SECURITIES AND EXCHANGE COMMISSION: Agency created by Congress to pr otect
investors in securities transaction by administering securities legislation.
STRUCTURED NOTES: Notes issued by Government Sponsored Enterprises (FHLB,
FNMA, SLMA, etc.) and Corporations which have embedded options (e.g. call features,
step -up coupo ns, floating rate coupons, derivative based returns) into their debt structure.
Their market performance is impacted by the fluctuation of interest rates, the volatility of
the imbedded options, and shifts in the shape of the yield curve.
STUDENT LOAN M ARKETING ASSOCIATION (SLMA): A U.S. Corporation and
instrumentality of the U.S. government. Through its borrowings, funds are targeted for
C -6
loans to students in higher education institutions. SLMA's securities are highly liquid and
are widely accepted.
SETTLEMENT DATE: The date on which a trade is cleared by delivery of securities
against funds. This date may be the same as the trade date or later.
SUPRA NATIONAL S – For purposes of this investment policy - obligations issued by the
International Bank for Reconstruction and Development, International Finance
Corporation, or Inter -American Development Bank.
TENNESSEE VALLEY AUTHORITY (TVA): A U.S. Corporation created in the 1930's, to
electrify the Tennessee Valley area; currently a major utility headq uartered in Knoxville
Tennessee. TVA's securities are highly liquid and are widely accepted.
TLGP: Temporary Liquidity Guarantee Program is a temporary program established by
the Federal Deposit Insurance Corporation that guarantees debt issued by banks.
TRADE DATE: The date on which the buyer and seller agree to a transaction. The trade
date may or may not be the date on which the securities and money changes hands
(settlement date).
TREASURY BILLS: A non -interest bearing discount security issued by the U.S. Treasury
to finance the national debt. Most bills are issued to mature in three months, six months,
or one year.
TREASURY BOND: Long -term coupon -bearing securities U.S. Treasury securities
issued as direct obligations of the U.S. Gove rnment and having initial maturities of more
than ten years.
TREASURY NOTES: Intermediate term coupon -bearing U.S. Treasury securities issued
as direct obligations of the U.S. Government and having initial maturities of from one to
ten years.
UNIFORM CA PITAL RULE: Securities and Exchange Commission requirement that
member firms as well as non -member broker -dealers in securities maintain a maximum
ratio of indebtedness to liquid capital of 15 to 1; also called net capital rule and net capital
ratio. Ind ebtedness covers all money owed to a firm including margin loans and
commitments to purchase securities, one reason new public issues are spread among
members of underwriting syndicates. Liquid capital includes cash and assets easily
converted into cash.
YIELD: The rate of annual income return on an investment, expressed as a percentage.
(a) INCOME YIELD is obtained by dividing the current dollar income by the current market
price for the security. (b) NET YIELD or YIELD TO MATURITY is the current inco me yield
minus any premium above par or plus any discount from par in purchase price with the
adjustment spread over the period from the date of purchase to the date of maturity of the
C -7
bond.
YIELD TO MATURITY: The rate of return yielded by a debt secur ity held to maturity when
both interest payments and the investor's capital gain or loss on the security are taken
into account.
1
Vernice Hankins
From:lindap_a@verizon.net
Sent:Monday, February 27, 2017 8:48 PM
To:councilmtgitems
Subject:Item 8A on your 2/28/17 agenda - Divestment from Wells Fargo
Dear Council Members,
I read an article in today's Daily Press that quotes Wells Fa rgo as saying your divestment will have no effect on the
Dakota Access Pipeline.
I urge you to stick with your position tak en at the 2/14/17 Council meeting and follow through on your intentions to divest.
One city's divestment may or may not have an impact on the Pi peline construction, but we set an example in our city and I
believe other cities will follow your lead.
When multiple cities divest, the effect *will* be felt and the message clearly sent.
Additionally, I believe that our city's $1billion soon-to-be-gone business with Wells Fargo will be felt by them and will send
a strong message that we do not appreciate their actions and policies as a banking institution.
I applaud you for seeking out a bank that will better reflect our community's progressive humanitarian and ecological
values.
Thank you.
Linda Piera-Avila
1424 12th St. Apt. E
Santa Monica 90401
Item 8-A
02/28/2017
1 Item 8-A
02/28/2017
Reference:
Resolution No. 11025 (CCS)
&
Resolution No. 34 (SA)