HomeMy WebLinkAbout96-59 - Adopting the 1996-97 Statement of Investment Policy, Authorizing City Treasurer to Invest & Reinvest Idle MoniesRESOLUTION NO. ?6 _ 5F
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF COSTA MESA, CALIFORNIA, ADOPTING THE
1996-97 STATEMENT OF INVESTMENT POLICY, AND
AUTHORIZING THE CITY TREASURER TO INVEST
AND REINVEST IDLE MONIES OF THE CITY OF
COSTA MESA IN ACCORDANCE WITH THE 1996-97
STATEMENT OF INVESTMENT POLICY, AND
AUTHORIZING SAID TREASURER TO DELEGATE TO
THE ASSISTANT DIRECTOR OF FINANCE THE
CARRYING OUT OF ANY SUCH TASKS.
THE CITY COUNCIL OF THE CITY OF COSTA MESA DOES HEREBY
RESOLVE AS FOLLOWS:
WHEREAS, in accordance with Section 53607 of the Government Code of the State of
California, the City Treasurer is hereby authorized (a) to invest such portion of any sinking fund
of, or idle money in, the City Treasury, not required for the immediate necessities of the City
as is deemed wise or expedient, in securities in which this Council is authorized to invest such
sums by the provisions of State Government Code Section 53601 and Section 53635, limited by
the City's Investment Policy; and (b) to sell, or exchange for other eligible securities, and
reinvest the proceeds of the securities purchased. The City Treasurer shall make a monthly
report of such transactions to this Council.
NOW, THEREFORE BE IT RESOLVED that the City Council of the City of Costa
Mesa has adopted the 1996-97 Statement of Investment Policy as set forth in the attached
document. The City Clerk shall certify to the passage and adoption of this resolution, and it
shall thereupon be in full force and effect.
PASSED AND ADOPTED this 17th day of June, 1996.
ATTEST:
Deputy Ci t
Clerk of the City of Costa Mesa
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss
CITY OF COSTA MESA )
C�
Mayq of the City of Costa Mesa
A ROVED AS TO FORM
CITY ATTORNEY
I, MARY T. ELLIOTT, Deputy City Clerk and ex -officio Clerk of the City Council of
the City of Costa Mesa, hereby certify that the above and foregoing Resolution No. 96 -J79
was duly and regularly passed and adopted by the said City Council at a regular meeting thereof
held on the 17th day of June, 1996, by the following roll call vote:
AYES: LRicKSeAl� I�UFFA f-�oRn13u���t, �E,11;5 �A✓Ff IfA�/
NOES: (Jo nJ-i:-
ABSENT: t3on1E
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the Seal of the City
of Costa Mesa this 18th day of June, 1996.
Deputy City (Aerk and ex -officio Clerk of
the City CourUil of the City of Costa Mesa
CITY OF COSTA MESA
STATEMENT OF INVESTMENT POLICY
1996-97
I. PURPOSE
This statement is intended to provide guidelines for the prudent investment of the
City's temporary idle cash, and outline the procedures for maxinuzing the efficiency
of the City's cash management system. The ultimate goal is to enhance the economic
status of the City while safeguarding its assets.
H. OBJECTIVE
The City's cash management system is designed to accurately monitor and forecast
revenues and expenditures, thus enabling the City to "invest funds to the fullest
extent possible. The City attempts to obtain the highest yield possible only after the
criteria established for safety and liquidity have been met.
The City of Costa Mesa operates its pooled idle cash investments with judgment and
care, under circumstances then prevailing, which persons of prudence, discretion and
intelligence exercise in the management of their own affairs, not for speculation, but
for investment, considering the probable safety of their capital as well as the probable
income to be derived.
This affords the City a broad spectrum of investment opportunities as long as the
investment is deemed prudent and is allowable under current legislation of the State
of California Government Code Section 53600 et seq. and the general laws of the City
of Costa Mesa.
The City of Costa Mesa strives to maintain the level of investment of all idle funds
as near 100% as possible, through daily and projected cash flow determinations. Idle
cash management and investment transactions are the responsibility of the City
Treasurer or his/her designee.
Criteria for selecting investments and the order of priority are:
1. Safety: The safety and risk associated with an investment refers to the
potential loss of principal, interest, or a combination of these amounts. The
City only operates in those investments that are considered very safe.
2. Liquidity: This refers to the ability to "cash in" at any moment in time with
a minimal chance of losing some portion of principal or interest.
3. Yield: Yield is the potential dollar earnings an investment can provide, and
sometimes is referred to as the rate of return.
4. Safekeeping: Securities purchased shall be held in third party safekeeping in
the Trust Department of a financial institution, in the City's name and control.
The account established shall be protected from seizure by creditors should the
financial institution holding the City's securities file for bankruptcy protection.
The basic premise underlying the City's investment philosophy is and continues to
be, to insure that surplus funds are always safe and available when needed.
III. DELEGATION OF INVESTMENT AUTHORITY
Authority to manage the City of Costa Mesa's investment program is derived from
City of Costa Mesa Council Resolution No. 96-59. Management responsibility for the
investment program is hereby delegated to the City Treasurer or his/her designee,
who shall establish written procedures for the operation of the investment program
consistent with this Investment Policy. Procedures should include references to:
safekeeping, repurchase agreements, wire transfer agreements, banking service
contracts, and collateral/ depository agreements. Such procedures shall include
explicit delegation of authority to persons responsible for investment transactions.
No person may engage in an investment transaction except as provided under the
terms of this policy and the procedures established by the City Treasurer or his/her
designee. The City Treasurer or his/her designee shall be responsible for all
transactions undertaken and shall establish a system of controls to regulate the
activities of subordinate officials.
IV. AUTHORIZED HWESTMENTS
The California Government Code allows the City to invest in the following media:
• Securities of the U.S. Government, or its agencies
• Small Business Administration loans
• Certificates of deposit, placed with commercial banks and savings and loan
companies
• Negotiable certificates of deposit
• Bankers acceptances
• Commercial paper
• Corporate notes and bonds, including medium term notes
• Local Agency Investment Fund
• Repurchase agreements
• Reverse repurchase agreements
• Passbook savings account demand deposits
• County Treasurer demand deposits
• Asset-backed and mortgage-backed securities
• Money market mutual funds
As a matter of practice, however, the City of Costa Mesa generally limits its
investments to the following vehicles:
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U.S. Treasury Bills - Issued weekly with maturity dates up to one year. They are
issued and traded on a discount basis with interest figured on a 360 -day basis, actual
number of days. They are issued in amounts of $10,000 and up, in multiples of
$5,000. They are a highly liquid security.
U.S. Treasury Notes - Initially issued with two- to ten-year maturities. They are
actively traded in a large secondary market and are very liquid. The Treasury may
issue Note issues with a minimum of $1,000, however, the average minimum is
$5,000.
Federal Agency Issues - Guaranteed directly or indirectly by the United States
Government. All agency obligations qualify as legal investments and are acceptable
as security for public deposits.
They usually provide higher yields than regular Treasury issues with all of the same
advantages. Examples include:
FICBs (Federal Intermediate Credit Bank Debentures) - Loans to lending
institutions used to finance the short-term and intermediate needs of farmers,
such as seasonal production. They are usually issued monthly in minimum
denominations of $3,000 with a nine-month maturity. Interest is payable at
maturity and is calculated on a 360 -day, 30 -day month basis.
FFCBs (Federal Farm Credit Bank) - Debt instruments used to finance the
short and intermediate term needs of farmers and the national agricultural
industry. They are issued monthly with three- and six-month maturities. The
FFCB issues larger issues (one to ten year) on a periodic basis. These issues
are highly liquid.
FLBs (Federal Land Bank Bonds) - Long-term mortgage credit provided to
farmers by Federal Land Banks. These bonds are issued at irregular times for
various maturities ranging from a few months to ten years. The minimum
denomination is $1,000. They carry semi-annual coupons. Interest is
calculated on a 360 -day, 30 -day month basis.
FHLBs (Federal Home Loan Bank Notes and Bonds) - Issued by the Federal
Home Loan Bank System to help finance the housing industry. The notes and
bonds provide liquidity and home mortgage credit to savings and loan
associations, mutual savings banks, cooperative banks, insurance companies,
and mortgage -lending institutions. They are issued irregularly for various
maturities. The minimum denomination is $5,000. The notes are issued with
maturities of less than one year and interest is paid at maturity. The bonds
are issued with various maturities and carry semi-annual coupons. Interest
is calculated on a 360 -day, 30 -day month basis.
FNMAs (Federal National Mortgage Association) - Used to assist the home
mortgage market by purchasing mortgages insured by the Federal Housing
Administration and the Farmers Home Administration, as well as those
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guaranteed by the Veterans Administration. They are issued about four times
a year for maturities ranging from a few months to eight years. They are
issued inminimum denominations of $10,000. They carry semi-annual
coupons. Interest is computed on a 360 -day, 30 -day month basis.
FHLMCs (Federal Home Loan Mortgage Corporation) - A government-
sponsored corporation established to develop the secondary market for
conventional home mortgages. Mortgages are purchased solely from the
Federal Home Loan Bank System member lending institutions whose deposits
are insured by agencies of the United States Government. They are issued for
various maturities and in minimum denominations of $10,000. Interest is paid
semi-annually and is calculated on a 360 -day, 30 -day month basis.
Other federal agency issues are Small Business Administration notes (SBAs),
Government National Mortgage Association notes (GNMAs), Tennessee Valley
Authority notes (TVAs), and Student Loan Marketing Association notes
(SALLIE-MAEs). As a matter of practice, the City does not invest in these
issues as they do not suit our purposes as well as other investment
opportunities available.
The City limits its investments to no more than 20% of its surplus funds in any one
Federal Agency.
Bankers Acceptances - Short-term credit arrangements to enable businesses to obtain
funds to finance commercial transactions. They are time drafts drawn on a bank by
an exporter or importer to obtain funds to pay for specific merchandise. By its
acceptance, the bank becomes primarily liable for the payment of the draft at its
maturity. An acceptance is a high-grade negotiable instrument. Acceptances are
purchased in various denominations for 30, 60, or 90 days, but no longer than 270
days. The interest is calculated on a 360 -day discount basis similar to Treasury Bills.
Local agencies may not invest more than 40% of their surplus money in bankers
acceptances.
Certificates of Deposit - Time deposits of a bank or savings and loan. They are
purchased in various denominations with maturities ranging from 30 to 360 days.
The interest is calculated on a 360 -day, actual -day month basis and is payable
monthly.
Negotiable Certificates of Deposit - Unsecured obligations of the financial institution,
bank or savings and loan, bought at par value with the promise to pay face value plus
accrued interest at maturity. They are high-grade negotiable instruments, paying a
higher interest rate than regular certificates of deposit. The primary market issuance
is in multiples of $1,000,000, the secondary market usually trades in denominations
of $500,000, although smaller lots are occasionally available. As a matter of practice,
only the ten largest U.S. banks where there is a secondary market established for
continued liquidity are considered for investment.
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Commercial Paper - Short-term unsecured promissory notes issued by a corporation
to raise working capital. These negotiable instruments are purchased at a discount
to par value or at par value with interest bearing. Commercial paper is issued by
corporations such as General Motors Acceptance Corporation, IBM, BankAmerica, etc.
Local agencies are permitted by State law to invest in commercial paper of "prime"
quality of the highest ranking or of the highest letter and numerical rating as
provided by Moody's Investor's Service, Inc., and/or Standard and Poor's Corporation.
Purchases of eligible commercial paper may not exceed 180 days maturity nor exceed
30% of the local agency's surplus funds.
Medium Term Corporate Notes - Unsecured promissory notes issued by a corporation
organized and operating in the United States. These are negotiable instruments and
are traded in the secondary market. Medium term corporate notes can be defined as
extended maturity commercial paper.
Local agencies are restricted by the Government Code to investments in corporations
rated in the top three note categories by Moody's Investors Service, Inc., and/or
Standard and Poor's Corporation. For medium-term notes, eligible purchases consist
of instruments that have a rating of "A" or better by both Moody's Investors Service,
Inc., and Standard and Poor's Corporation. If the security's credit rating falls below
"A" by one of these agencies, then awareness is heightened and the security
monitored closely to determine if credit risk has been significantly increased. If a
security falls below "A" by both rating agencies, then the City Treasurer or his/her
designee will evaluate the need to sell the security prior to maturity. Further
restrictions are a maximum term of five years to maturity and total investments in
medium term corporate notes may not exceed 30% of the local agency's surplus funds.
Repurchase Agreements - A repurchase agreement is a short-term investment
transaction. Banks buy temporarily idle funds from a customer by selling U.S.
Government or other securities with a contractual agreement to repurchase the same
securities on a future date. Repurchase agreements are typically for one to ten days
in maturity. The customer receives interest from the bank. The interest rate reflects
both the prevailing demand for Federal funds and the maturity of the repurchase
agreement. Some banks will execute repurchase agreements for a minimum of
$100,000 to $500,000, but most banks have a minimum of $1,000,000. The term of
a repurchase agreement may not exceed one year. The market value of securities
that underlay a repurchase agreement shall be valued at 102 percent or greater of
the funds borrowed against those securities and the value shall be adjusted no less
than quarterly. Repurchase Agreements can only be executed with financial
institutions or broker/dealers that have signed a Master Repurchase Agreement with
the City.
Reverse Repurchase Agreements - A reverse repurchase agreement is the opposite of
a repurchase agreement. The City loans a security to a bank in exchange for cash.
The City agrees to pay off the loan with interest on a future date. As this type of
investment actually involves a loan arrangement, the City may not invest more than
10% of its surplus funds in reverse repurchase agreements, and must always match
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its maturities to the reinvestment. Reverse repurchase agreements may be utilized
only when either of the following conditions are met:
1. The security was owned or specifically committed to purchase, by the local
agency, prior to December 31, 1994, and was sold using a reverse repurchase
agreement on December 31, 1994.
2. The security:
a) to be sold has been owned and fully paid for for a minimum of 30 days
prior to sale; and
b) the total of all reverse repurchase agreements owned does not exceed 10
percent of the base value of the portfolio; and
c) the agreement does not exceed a term of 92 days, unless the agreement
includes a written codicil guaranteeing a minimum earning or spread for
the entire period between the sale of a security using a reverse
repurchase agreement and the final maturity date of the same security.
LAW (Local Agency Investment Fund) - A special fund in the State Treasury which
local agencies may use to deposit funds for investment. There is no minimum
investment period and the minimum transaction is $5,000, in multiples of $1,000
above that, with a maximum balance of $20,000,000 for any agency. However, any
investment with LAIF must comply with other self-imposed restrictions as specified
in this Investment Policy. The City is restricted to a maximum of ten transactions
per month. It offers high liquidity because deposits can be converted to cash in 24
hours and no interest is lost. All interest is distributed to those agencies
participating on a proportionate share basis determined by the amounts deposited
and the length of time they are deposited. Interest is paid quarterly. The State
retains an amount for reasonable costs of making the investments, not to exceed one-
quarter of one percent of the earnings. California Government Code §16429.3 states,
in part:
"money placed with the State Treasurer for deposit in the Local Agency
Investment Fund by cities, counties, or special districts shall not be
subject to impoundment or seizure by any state official or state agency."
Orange County Treasurer's Pool - A special fund in the County Treasury which local
agencies may use to deposit funds for investment. The City may not invest more
than 35% of its surplus money with the Orange County Treasurer's Pool. However,
any investment with the Orange County Treasurer's Pool must comply with other
self-imposed restrictions as specified in this Investment Policy. The County
Treasurer charges 12.5 basis points (.125%) to all pool participants for its direct costs.
Direct Costs include proper staffing, bank and custodial fees, software maintenance
fees, and other indirect costs relating to the investment. Investment earnings are
distributed to the pool participants on a monthly basis, net of the above charges. The
earnings are credited to the participants accounts on either the last day of each
month or the first day of the subsequent month.
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Money Market Mutual Funds - Shares of beneficial interest issued by diversified
management companies. To be eligible for investment, shares must:
1. attain the highest rating provided by Moody's Investors Service, Inc., which is
currently "Aaa," and/or Standard and Poor's Corporation, which is currently
"AAA;" and
2. the investment adviser managing the shares must be registered with the
Securities and Exchange Commission with not less than five year's experience
investing in instruments authorized under California Government Code §53601
subdivisions (a) to (m) inclusive, and with assets under management in excess
of five hundred million dollars ($500,000,000); and
3. the purchase price of shares shall not include any commission that these
companies may charge; and
4. investment in shares shall not exceed 15 percent of surplus funds.
However, any investment in a money market mutual fund must comply with other
self-imposed restrictions as specified in this Investment Policy.
Asset -Backed and Mortgage -Backed Security - Bonds backed by payments from
receivables/mortgages having a maximum of five years maturity. These securities
must have an "AA" or better rating by Moody's Investors Services, Inc., and/or
Standard and Poor's Corporation. No more than 20% of the City's surplus money
may be invested in these securities.
V. INVESTMENT OF BOND PROCEEDS
When investing proceeds from the issuance of bonds, the City of Costa Mesa will
follow this Investment Policy when determining allowable investments. Should the
trust agreement of a particular bond issue be more restrictive than the City's policy
on permitted investments, then the trust agreement will take precedence.
VI. CITY CONSTRAINTS
The City of Costa Mesa operates its pooled idle cash investments under the Prudent
Man rule. This provides a broad spectrum of prudent investment opportunities
consistent with current State of California legislation and other imposed legal
restrictions. The City Treasurer or his/her designee will evaluate local banks and
savings institutions and may invest idle cash funds with such institutions when the
criteria for prudent investment previously stated are met. The City operates its
investment pool according to State and self-imposed constraints. It does not buy
stocks; it does not speculate; it does not deal in futures or options. Any investment
extending beyond a five-year period requires prior City Council approval.
Additionally, a minimum of 40% of the outstanding investments must mature within
a one-year time period.
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VII. SAFEKEEPING AND COLLATERALIZATION
All security transactions, including collateral for repurchase agreements, entered into
by the City shall be conducted on a delivery -versus -payment (DVP) basis. Securities
will be held by a third party custodian designated by the City Treasurer or his/her
designee.
Collateralization will be required on two types of investments: certificates of deposit
and repurchase (and reverse repurchase) agreements. In order to anticipate market
changes and provide a level of security for all funds, a minimum collateralization
level is required.
Surplus funds must be deposited in State or national banks, State or Federal savings
and loan associations, or State or Federal credit unions within the State of California.
The deposits cannot exceed the amount of the bank's or savings and loan's paid-up
capital and surplus.
The bank or savings and loan must secure public funds deposits with eligible
securities having a market value of 110% of the total amount of the deposits. State
law also allows as an eligible security, first trust deeds having a value of 150% of the
total amount of the deposits. A third class of collateral is 105% in the form of a letter
of credit drawn on the Federal Home Loan Bank.
The City Treasurer or his/her designee may waive security for that portion of a
deposit which is insured pursuant to Federal law. Currently, the first $100,000 of
a deposit is federally insured. Deposits in excess of $100,000 are collateralized as
previously indicated.
VIII. DERIVATIVE INVESTMENTS
A derivative is a generic term often used to categorize a wide variety of financial
instruments whose value "depends on" or is "derived from" the value of an underlying
asset, reference rate, or index.
Investments in derivative instruments are limited to debt securities that have
periodic increases, or step-up interest rate adjustments that provide upward mobility
in yield return. Investments in debt securities which contain a callable feature are
also allowable, but must comply with other restrictions as specified in this
Investment Policy.
Investments purchased after June 19, 1995, in derivative instruments known as
"inverse floaters," "dual index," or "stepped inverse" securities that produce higher
than market yields at purchase date (when interest rates are low), but have the
possibility of producing low or no coupon rates as market interest rates rise through
the life of the instrument are not allowable. Furthermore, investments in range
notes or interest -only strips that are derived from a pool of mortgages are not
allowable. However, debt securities that have a floor or a built-in feature that
prevents the instrument from potentially returning no yield are allowable.
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DC REPORTING
Under provisions of Section 53646 of the California Government Code, the Treasurer
or his/her designee shall render a quarterly investment report to the City Council, the
City Manager, and the City Attorney within 30 days following the end of the quarter
covered by the report. However, as a matter of practice, a monthly report shall be
submitted listing the type of investments, institution, date of maturity, amount of
deposit, rate of interest, current market value for all securities, and such other data
as may be required by the City Council on a monthly basis. Furthermore, an
Investment Oversight Committee comprised of the following individuals will meet
quarterly to review the City's portfolio and investment strategy.
Mayor, or his/her designee
City Manager
Three Members who are either residents or conduct business within the City
and have experience in banking, securities trading, or financial planning.
Additionally, an annual audit of the City's investment portfolio will be conducted by
an independent Certified Public Accounting firm and a report of results will be made
available.
X. QUALIFIED DEALERS
The City of Costa Mesa shall transact business only with banks, savings and loans,
and registered investment securities dealers. The City will limit the number of
broker/dealers authorized to do business with the City to one (1) broker/dealer for
every $15,000,000 of portfolio size.
The City Treasurer or his/her designee will maintain a list of financial institutions
authorized to provide investment services. In addition, a list will also be maintained
of approved broker/dealers who are authorized to provide investment services in the
State of California. These may include "primary" and "regional" broker/dealers with
offices located in the State of California. All financial institutions and broker/dealers
who desire to become, qualified bidders for investment transactions must be approved
by and supply the City Treasurer or his/her designee with a completed broker/dealer
questionnaire.
XI. POLICY REVIEW
This Statement of Investment Policy shall be reviewed at least annually to ensure its
consistency with the overall objectives of preservation of principal, liquidity and
return, and its relevance to current law, financial and economic trends.
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I.
CITY OF COSTA MESA
IIWESTMENT GUIDELINES AND STRATEGY
GUIDELINES - Guidelines are established to direct and control activities in
such a manner that previously established goals are achieved.
1. Investment Transaction. Every investment transaction must be
authorized and reviewed by the Treasurer or his/her designee.
2. Pooled Cash. Whenever practical, local agency cash is consolidated into
one bank account and invested on a pooled concept basis. Interest
earnings are allocated quarterly according to month-end cash and
investment balances for each fund.
3. Competitive Bids. Purchase and sales of securities are made on the
basis of competitive offers and bids when practical.
4. Cash Forecast. The cash flow for the City is analyzed with the receipt
of revenues and maturity of investments scheduled so that adequate
cash will be available to meet disbursement requirements.
5. Investment Limitations. Security purchases and holdings are main-
tained within statutory limits imposed by the California Government
Code. Current limits are:
Bankers Acceptances
Commercial Paper
Negotiable Certificates of Deposit
Reverse Repurchase Agreements
Medium Term Notes
Money Market Mutual Funds
Asset-Backed/Mortgage-Backed Securities
40% Section 53601(f)
30% Section 53601(g)
30% Section 53601(h)
20% Section 53601(i)
30% Section 53601Q)
15% Section 53601(k)
20% Section 53601(n)
6. Liquidity. The marketability of a security is considered at the time of
purchase, as the security may have to be sold at a later date to meet
unanticipated cash demands.
7. Diversification. The portfolio should consist of a mix of various types
of securities, issuers, and maturities.
8. Evaluate Certificates of Deposit
(a) Certificates of Deposit shall be evaluated in terms of FDIC
coverage. For deposits in excess of the insured maximum of
$100,000, approved collateral at full market value shall be
required. (California Government Code Section 53652 and/or
53651(m) and 53651.2(a)(1).
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II.
(b) Negotiable Certificates of Deposit shall be evaluated in terms of
the credit worthiness of the issuer, as these deposits are
uninsured and uncollateralized promissory notes,
STRATEGY - Strategy refers to the ability to manage financial resources in the
most advantageous manner.
1. Economic Forecasts. Economic Forecasts are obtained periodically from
economists and financial experts through bankers and brokers to assist
the Treasurer or his/her designee with the formulation of an investment
strategy for the local agency.
2. Implementing Investment Strategy. Investment transactions are
executed which conform with anticipated interest rate trends and the
current investment strategy plan.
3. Rapport. A close working relationship is maintained with large vendors
of the city. The objective is to pinpoint when large disbursements will
clear the city's bank account. It is essential for good cash control that
such large expenditures be anticipated, estimated as to dollar amount,
and communicated to the Treasurer or his/her designee for liquidity
planning purposes.
4. Preserve Portfolio Value. Field standards are developed in order to
maintain earnings near the market and to preserve the value of the
portfolio.
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CITY OF COSTA MESA
INVESTMENT PROCEDURES
INTERNAL CONTROL - GUIDELINES
OBJECTIVES OF INTERNAL CONTROL
Internal control is the plan of organization and all the related systems established
by the management's objective of ensuring, as far as practicable:
• The orderly and efficient conduct of its business, including adherence to
management policies.
• The safeguarding of assets.
• The prevention or detection of errors and fraud.
• The accuracy and completeness of the accounting records.
• The timely preparation of reliable financial information.
LIMITATIONS OF INTERNAL CONTROL
No internal control system, however elaborate, can by itself guarantee the
achievement of management's objectives. Internal control can provide only
reasonable assurance that the objectives are met, because of its inherent limitations,
including:
• Management's usual requirement that a control be cost-effective.
• The direction of most controls at recurring, rather than unusual, types of
transactions.
• Human error due to misunderstanding, carelessness, fatigue, or distraction.
• Potential for collusion that circumvents controls dependent on the segregation
of functions.
• Potential for a person responsible for exercising control abusing that
responsibility; a responsible staff member could be in a position to override
controls which management has set up.
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CITY OF COSTA MESA
INTERNAL CONTROL - GUIDELINES
ELEMENTS OF INTERNAL CONTROL
Elements of a system of internal control are the means by which an organization can
satisfy the objectives of internal control. These elements are:
1. ORGANIZATION
Specific responsibility for the performance of duties should be assigned and
lines of authority and reporting clearly identified and understood.
2. PERSONNEL
Personnel should have capabilities commensurate with their responsibilities.
Personnel selection and training policies together with the quality and quantity
of supervision are thus important.
3. SEGREGATION OF FUNCTIONS
Segregation of incompatible functions reduces the risk that a person is in a
position both to perpetrate and conceal errors or fraud in the normal course of
duty. If two parts of a transaction are handled by different people, collusion
is necessary to conceal errors or fraud. In particular, the functions that should
be considered when evaluating segregation of functions are authorization,
execution, recording, custody of assets, and performing reconciliations.
4. AUTHORIZATION
All transactions should be authorized by an appropriate responsible individual.
The responsibilities and limits of authorization should be clearly delineated.
The individual or group authorizing a specific transaction or granting general
authority for transactions should be in a position commensurate with the
nature and significance of the transactions. Delegation of authority to
authorize transactions should be handled very carefully.
5. CONTROLS OVER AN ACCOUNTING SYSTEM
Controls over an accounting system include the procedures, both manual and
computerized, carried out independently to ascertain that transactions are
complete, valid, authorized, and properly recorded.
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CITY OF COSTA MESA
CASH CONTROLS
PROCEDURES PERFORMED BY AUDITORS WITH RESPECT TO CASH RECEIPTS
A. City procedures and controls are reviewed. Some of the system strengths are:
1. Receipts are controlled upon receipt by proper registration devices.
2. Receipts are reconciled on a daily basis.
3. Amounts are deposited intact.
4. All bank accounts are authorized by City Council.
5. Cash counts are done by two or more individuals.
6. Bank reconciliations are reviewed.
7. Prompt posting of cash receipt entries in books.
8. Receipt forms are prenumbered, accounted for, and physically secured.
9. Proper approval required for write-offs of customer accounts.
10. Checks are restrictively endorsed upon receipt or when run through
cash register.
11. Adequate physical security over cash.
12. Individuals that handle cash do not post to customer account records or
process billing statements.
13. Adequate supervision of Finance Department operations.
B. Significant revenues are confirmed directly with payor and compared with City
books to make sure amounts are recorded properly.
C. Cash balances are substantiated by confirming all account balances recorded
in books. Bank reconciliations are reviewed for propriety and recalculated by
the auditor. All significant reconciling items on bank reconciliations are
verified as valid reconciling items by proving to subsequent bank statements.
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r
CITY OF COSTA MESA
SEGREGATION OF RESPONSIBILITIES OF
THE TREASURY FUNCTIONS
Function
1. Authorization of Investment
Transactions:
Formal Investment Policy should be:
• Prepared By:
• Submitted To:
Investment Transactions
should be approved by
2. Execution of investment
transactions
3. Timely recording of investment
transactions:
Recording of investment
transactions in the
Treasurer's records
Recording of investment
transactions in the
accounting records
4. Verification of investment,
i.e., match broker confirma-
tion to Treasurer's records
5. Safeguarding of Assets and Records:
Reconciliation of Treasurer's
records to the accounting records
Reconciliation of Treasurer's
records to bank statements and
safekeeping records
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Responsibility
Treasurer
City Council
Treasurer
Assistant Director of Finance
Revenue Supervisor
Accountant
Assistant Director of Finance
Revenue Supervisor
Accountant
CITY OF COSTA MESA
SEGREGATION OF RESPONSIBILITIES OF
THE TREASURY FUNCTIONS
(Continued)
Function
5. Safeguarding of Assets and Records
(continued):
Annual review of (a) financial
institution's financial condition,
(b) safety, liquidity, and potential
yields of investment instruments.
6. Periodic review of investment
portfolio as prepared by
Treasurer including:
Responsibility
Assistant Director of Finance with
Treasurer's approval
Independent Auditors
• Investment types
• Purchase Price
• Market values
• Maturity dates
• Investment yields
• Conformance to stated investment policy
• Safekeeping reports
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