City of Culver City, California
Agenda Item Report
Meeting Date: 08/01/2011 Item Number: JC-1
JOINT CITY COUNCIL / REDEVELOPMENT AGENCY BOARD AGENDA ITEM:
Adoption of Resolutions Approving the Annual Investment Policy for Fiscal Year
2011/2012.
Contact Person/Dept.:
Jeff S. Muir/Finance
Phone Number: 310/253-5865
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Public Hearing: [] Action Item: [] Attachments: [X]
Commission Action Required: Yes [] No [X] Date: _______________
Public Notification: (E-Mail) Meetings and Agendas – City Council (08/03/11); Meetings
and Agendas – Redevelopment Agency (08/03/11)
Department Approval:
Jeff Muir (07/19/11)
City Attorney Approval:
Carol Schwab (by H. Baker) (08/03/11)
Chief Financial Officer Approval:
Jeff Muir (07/19/11)
City Manager Approval:
John M. Nachbar (08/03/11)
RECOMMENDATION:
Staff recommends that the City Council and Agency Board adopt respective
resolutions approving the Annual Investment Policy for Fiscal Year 2011/2012.
BACKGROUND / DISCUSSION:
Effective January 1, 1996, the filing of the Annual Statement of Investment Policy
(Policy) became a requirement of State law. In Fiscal Year 2003/2004, the State
Legislature suspended this requirement to avoid Mandated Cost Reimbursements to
local governments. However, sound practice is to continue the annual filing. The
City and Agency last approved the Annual Investment Policy for Fiscal Year
2010/2011 in August 2010.
The attached proposed Policy is in compliance with Sections 53600 through 53684
of the Government Code, which govern investment requirements for California public
agencies. The Chief Financial Officer (who has also been designated as the City
Treasurer by the City Manager) is delegated primary authority for managing the City
and Redevelopment Agency investment portfolio. Previously, there were separate
(though identical) investment policies adopted by the City and Redevelopment
Agency. The attached policy will be applicable to both entities.
The only proposed change to the Policy from that approved by the City Council for
Fiscal Year 2010/2011 is to add the authority to invest in the Investment Trust of
California, doing business as CalTRUST. The California State Association of City of Culver City, California
Agenda Item Report
Counties Finance Corporation and the League of California Cities created
CalTRUST to provide a convenient method for local agencies to pool their assets for
investment. Recently enacted legislation authorizes local agencies to directly invest
in joint investment pools, such as CalTRUST. There is no requirement that a local
agency become a JPA member. As a joint powers authority, CalTRUST is governed
by a Board of Trustees made up of local treasurers and investment officers. The
Board of Trustees sets overall policy for CalTRUST in full compliance with the
Government Code and selects and supervises the activities of the Investment
Manager and other agents. Local agencies have three account options – Money
Market, Short-Term, or Medium-Term accounts. Staff is primarily interested in the
Short-Term account, although authorization for all three is included in the revised
policy document (which would allow the Chief Financial Officer/City Treasurer to
make appropriate investment decisions based upon the changing cash position of
the City and Agency).
FISCAL ANALYSIS:
There is no fiscal impact associated with the approval of the Investment Policy and
the adoption of these Resolutions.
ATTACHMENTS:
1. Proposed City Council Resolution
2. Exhibit ‘A’ - Fiscal Year 2011-2012 Annual Investment Policy
3. Proposed Redevelopment Agency Resolution
MOTION:
That the City Council and Agency Board:
Adopt respective resolutions approving the Annual Investment Policy for Fiscal
Year 2011/2012
MEETING DATE: 08/08/2011
AGENDA ITEM: Adoption of Resolutions Approving the Annual
Investment Policy for Fiscal Year 2011/2012
ATTACHMENTS
1. Agency Resolution
1-2
2. City Resolution 3
3. Exhibit “A” 4-38
“Exhibit A”
City of
Culver City
Annual Investment Policy
For Fiscal Year 2011-2012
Jeff Muir
Chief Financial Officer / City Treasurer City of Culver City
Annual Investment Policy
Fiscal Year 2011-2012
TABLE OF CONTENTS
Introduction ............................................................................................................... 1
Delegation of Authority ........................................................................................... 1
Ethics and Conflicts of Interest ............................................................................... 2
Prudence ................................................................................................................... 2
Prudent Investor Rule ............................................................................................... 2
Internal Controls ...................................................................................................... 3
Investment Objectives ............................................................................................. 3
Performance Evaluation ......................................................................................... 4
Diversification .......................................................................................................... 4
Portfolio Segregation ............................................................................................... 4
Bond Issuance Arbitrage Rebate ........................................................................... 5
Maximum Maturities ................................................................................................. 5
Portfolio Reporting .................................................................................................. 6
Qualified Dealers .................................................................................................... 7
Safekeeping of Securities ...................................................................................... 8
Collateralization ...................................................................................................... 8
Authorized Investments ........................................................................................... 9
Ineligible Investments ............................................................................................. 13
Investment Advisory Committee ......................................................................... 13
Investment Policy Adoption ................................................................................ 13
Glossary ................................................................................................................... 14
CITY OF CULVER CITY
ANNUAL INVESTMENT POLICY
FOR FISCAL YEAR 2011-2012
1
1. INTRODUCTION
This statement of Investment Policy is intended to provide specific criteria
for the prudent investment of City funds. The ultimate investment goal is to
enhance the economic status of the City while protecting funds under
management and meeting the daily cash flow demands of the City. The
investment policy conforms to all Federal, State and local laws governing
the investment of monies under the control of the Chief Financial Officer /
City Treasurer.
This investment policy applies to the City's Investment Portfolio and
Redevelopment Agency Portfolio. These portfolios encompass all monies
under the direct oversight of the Chief Financial Officer / City Treasurer and
include the General Fund, Reserve Funds, Special Revenue Funds, Debt
Service Funds, Capital Project Funds, Proprietary Funds, Trust and Agency
Funds, and any other funds that may be created.
2. DELEGATION OF AUTHORITY
The Charter of the City of Culver City and the authority granted by City
Council assign the responsibility of investing unexpended cash to the City
Treasurer. The Chief Financial Officer has been appointed to also serve as
the City Treasurer. The Chief Financial Officer may delegate daily
investment activity, such as carrying out the Treasurer's investment
instructions, confirming treasury transactions, and other routine activities.
The Chief Financial Officer shall establish written investment policy
procedures for the operation of the investment program consistent with this
policy. The procedures should include reference to: safekeeping, PSA
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 Chief Financial Officer.
The Chief Financial Officer is responsible for the investment of bond
proceeds whether held by the City or with a fiscal agent. The Bond
Proceeds portfolio(s) shall be segregated from the Pooled Investment
Portfolio of the City and will be structured with maturities (or maintain an
average maturity) sufficient to meet construction draws, debt service
payments and other short-term liabilities. For purposes of efficiency, the
Chief Financial Officer may instruct each fiscal agent to purchase certain
securities regarding the investment of bond proceeds. City of Culver City Investment Policy Revised 2011
2
The Chief Financial Officer may delegate management of the Culver City
Investment Portfolio and Redevelopment Agency Portfolio to a contract
management firm that has full authority to execute investment transactions
on behalf of the City. In the event the contract management firm is not
able to execute investment transactions, the Chief Financial Officer and
Revenue Division Manager have the authority to execute investment
transactions.
3. ETHICS AND CONFLICTS OF INTEREST
Officers and employees involved in the investment process shall refrain
from personal business activity that conflicts with proper execution of the
investment program or that impairs their ability to make impartial
investment decisions. Employees and investment officials shall disclose any
material financial interests that could be related to the performance of the
City's investment policy annually or as necessary.
4. PRUDENCE
The Chief Financial Officer operates the City's pooled cash investment
program under the Prudent Investor Rule, Government Code Section
53600.3, and applicable State laws. This affords a broad spectrum of
investment opportunities so long as the investment is deemed prudent and
permissible by the State of California, various bond indentures and this
policy. The Chief Financial Officer strives to invest 100% of idle funds.
5. PRUDENT INVESTOR RULE
When investing, reinvesting, purchasing, acquiring, exchanging, selling, and
managing public funds, the Chief Financial Officer shall act with care, skill,
prudence, and diligence under the circumstances then prevailing that a
prudent person acting in a like capacity and familiarity with those matters
would use in the conduct of funds of a like character and with like aims to
safeguard the principal and maintain the liquidity needs of the agency. All
such investments, reinvestments, purchases, acquisitions, exchanges, and
sales shall be made subject to and in accordance with this policy and the
provisions of Sections 16429.1 and 53600 through 53684 of the Government
Code and other applicable laws and regulations.
City of Culver City Investment Policy Revised 2011
3
6. INTERNAL CONTROLS
The Chief Financial Officer shall establish procedures that separate the
internal responsibility for management and accounting of the investment
portfolio. An analysis by an external independent auditor shall be
conducted annually to review internal controls, account activity and
compliance with policies and procedures.
7. INVESTMENT OBJECTIVES
The City's cash management system is designed to accurately monitor and
forecast revenues and expenditures, thus enabling the Chief Financial
Officer to invest funds to the fullest extent possible. The Chief Financial
Officer maintains a diversified portfolio to accomplish the primary
objectives in the order of safety, liquidity, and yield.
Safety: The safety/risk associated with an investment refers to the potential
loss of principal, accrued interest or a combination of these. The Chief
Financial Officer seeks to mitigate credit risk by monitoring financial
institutions with which he/she will do business, and by careful scrutiny of the
credit worthiness of the investment instruments as well as the institutions.
Such resources as Moody's and Standard & Poor's rating services are
utilized for this review. The Treasurer seeks to mitigate interest rate risk
through diversification of instruments as well as maturities.
Liquidity: The portfolio will be structured with sufficient liquidity to allow the
Chief Financial Officer to meet anticipated cash requirements. This will be
accomplished through the purchase of a diversity of instruments to include
those with active secondary markets, those that can match maturities to
expected cash needs, and the State Local Agency Investment Fund with
immediate withdrawal provisions.
Yield: A competitive market rate of return is the third objective of the
investment program after the fundamental requirements of safety and
liquidity have been met. The portfolio shall be managed to consistently
attain a market rate of return throughout budgetary and economic cycles.
Whenever possible, and consistent with risk limitations and prudent
investment management, the City will seek to augment returns above the
market average rate of return through the implementation of active
portfolio management strategies. City of Culver City Investment Policy Revised 2011
4
8. PERFORMANCE EVALUATION
Investment performance is continually monitored and evaluated by the
Chief Financial Officer. Investment portfolio reports are generated on a
quarterly basis and submitted to the City Council, City Manager and
Investment Committee.
The investment portfolio reports are to be submitted within 30 days of the
end of the reporting period. The monthly average yield of the Culver City
Pooled Investment Portfolio will be compared to the monthly average 6-
month CMT (Constant Maturity Treasury) as calculated by the Federal
Reserve Bank of New York. As an added reference, the monthly average
yield of the Culver City Pooled Investment Portfolio will be compared to the
monthly average 2-year CMT as calculated by the Federal Reserve Bank of
New York.
9. DIVERSIFICATION
The City will diversify use of investment instruments to avoid unreasonable
risks inherent in over-investing in specific instruments, individual financial
institutions, or maturities.
Market price volatility shall be controlled through maturity diversification, as
well as ensuring adequate liquidity is available to meet cash flow
requirements, thereby precluding the need to sell instruments at a market
loss.
Risk of default will be controlled by acquiring instruments such as
Government Securities, or by diversifying the portfolio within the constraints
and parameters of Section 17 of this Policy, Authorized Investments.
10. PORTFOLIO SEGREGATION
Within the overall funds managed by the Chief Financial Officer, bond
funds shall be invested in conformance with the permitted investment
criteria documented in each bond indenture or guiding resolution.
Furthermore, bond proceeds held by fiscal agents shall also be segregated
and invested in accordance with each indenture.
The primary purpose in managing bond proceeds to structure investment
maturities to meet current and future liabilities. The preservation of
principal and the maintenance of liquidity are the most important factors City of Culver City Investment Policy Revised 2011
5
regarding the investment of bond proceeds. Portfolio yield is not a primary
factor since the portfolio structure, eligible investment assets and maturity
restrictions are governed by draws and expenditure schedules of the issues.
Performance will be based upon maximizing permitted positive arbitrage
within the context of principal preservation as a first priority (pre-1986 Tax
Reform Act issuances) or minimizing or eliminating negative arbitrage
(yield-restricted issues).
11. BOND ISSUANCE ARBITRAGE REBATE
The U.S. Tax Reform Act of 1986 requires the City to perform annual
arbitrage calculations and rebate excess earnings to the U.S. Treasury for
investment returns that exceed the allowable interest earnings limit of each
bond issue. The arbitrage calculation process must be conducted for the
investment of proceeds of bond issues sold after the effective date of this
law. This arbitrage calculation will be contracted out to provide the
necessary technical expertise to comply with this regulation. The City's
investment position relative to the interest rate arbitrage restrictions is to
have safety and the highest permitted return the law allows as the highest
priority while ensuring the preservation of principal and liquidity.
12. MAXIMUM MATURITIES
(1) Operating Portfolio
In accordance to California Government Code Section 53601, The
City will not invest in any securities maturing more than five (5) years
from the settlement date of purchase. If the Chief Financial Officer
desires to make investments longer than five years, express authority
to make those investments, either specifically or as part of an
investment program, must be approved by the City Council no less
than three months prior to the investment. In no event will securities
with maximum maturities beyond four years exceed 40% of the
portfolio’s total carrying cost at the time of purchase. City of Culver City Investment Policy Revised 2011
6
(2) Bond Proceeds
The Bond Proceeds portfolio held by the City and/or fiscal agents will
be structured with maturities sufficient to meet current and future
disbursements and other liabilities consistent with the purpose of
each bond issue. The Chief Financial Officer may match maturities
to defined future liabilities or may structure the portfolio in such a
manner as to maintain an average maturity and a defined liquidity
percentage necessary to meet estimated liabilities. In no event will
securities be purchased with final maturities that exceed a
specifically defined future liquidity requirement (such as bond
reserve fund availability requirement) or liability.
13. PORTFOLIO REPORTING
On a quarterly basis, or as otherwise requested by the City Manager, the
Chief Financial Officer shall provide to the City Council an investment
portfolio report indicating each of the City's investments (a description that
adequately describes the security), the purchase date, maturity date, cost
basis, current cost value (book value), interest rate, weighted average
maturity, and current unrealized loss or gain. Various investment types will
be categorized and grouped in the same structure as the qualified
investment categories identified in this policy. The portfolio report shall
include a statement certifying the ability of the City to meet its expenditure
requirements for the next six months, or provide an explanation as to why
sufficient money shall, or may, not be available. The report will also include
comments on the fixed income markets and economic conditions, and the
effect, if any, on the portfolio structure and investment strategy. The report
shall also detail all repurchase and reverse repurchase positions and
associated liabilities.
The investment portfolio report shall include mark-to-market information for
all investments. A monthly market value will be obtained for each security
owned by the City. For purposes of reporting, the market value of each
security may be obtained from the City’s custodian bank or other pricing
source(s) utilized by the City’s designated investment management firm
(registered investment advisor).
The City shall record interest revenue on a modified accrual basis of
accounting that is typical for reporting and recording of interest earnings,
accretions and premium amortizations. Securities held by a fiscal agent
shall also be recorded on a modified accrual basis of accounting. The
Chief Financial Officer will report year-end investments in conformance City of Culver City Investment Policy Revised 2011
7
with GASB 31 and GASB 40.
The Chief Financial Officer will perform a monthly reconciliation of all funds
included in the investment portfolios. The reconciliation shall utilize all
available information including the City's books, the Demand Deposit Bank
account, the custodian's statement and the fiscal agent's statement.
14. QUALIFIED DEALERS
The Chief Financial Officer shall transact business only with Registered
Investment Advisors, banks, savings and loans, and broker dealers. The
dealers should be primary dealers regularly reporting to the New York
Federal Reserve Bank, or approved regional or secondary market dealers
that qualify under the Securities and Exchange Commission Rule 15C3-1
(uniform net capital rule).
A list of security broker/dealers approved to conduct business with the City
shall be maintained. Every three years, the City shall issue a Request for
Qualifications (RFQ) to be submitted by broker/dealers that wish to
conduct business with the City. The City shall conduct a review and
evaluation process of submitted proposals and provide a list of
recommended broker/dealers to the Investment Committee and City
Council for approval. Approved broker/dealers shall be required to
execute the Acknowledgement of Compliance Standards for Investment
Transactions prior to conducting business with the City.
The Chief Financial Officer may direct a fiscal agent to execute investment
transactions on behalf of the City for funds held by that fiscal agent.
The City may purchase A|1010|, P|1010| rated commercial paper from its direct issuer
if it presents a higher return than in the secondary market.
The Chief Financial Officer shall send annually a copy of the current
investment policy by electronic mail to all broker/dealers approved to do
business with the City. Broker/dealers shall be required to provide a
certification acknowledging receipt of the policy and their most recent
audited financial statements upon receipt of policy. Chief Financial Officer
will review financials and report back to the Investment Committee.
Confirmation of receipt of this policy shall be considered evidence that the
dealer understands the City's investment policies and agrees to sell the City
only appropriate investments.
City of Culver City Investment Policy Revised 2011
8
15. SAFEKEEPING OF SECURITIES
To protect against losses caused by the collapse of individual securities
dealers, all securities owned by the City shall be held in safekeeping by a
third party bank trust department acting as agent for the City under the
terms of a custody agreement or PSA agreement (repurchase agreement
collateral) or, in the case of funds held by the fiscal agent, the fiscal agent
shall segregate and report securities held on the City's behalf. Any trade
executed by a dealer is required to settle on a delivery versus payment
basis with the City's safekeeping agent.
Fiscal agents in receipt of City of Culver City bond proceeds will settle
security transactions on a delivery versus payment method based upon
instructions provided by the Chief Financial Officer or the City's investment
advisor. The fiscal agents will issue monthly custodian statements
evidencing securities held in safekeeping, including the receipt of interest
and maturity proceeds, the disbursement of funds for the purchase of
securities, and the receipt of any sale proceeds.
16. COLLATERALIZATION
All demand deposits, time deposits and repurchase agreements are to be
fully collateralized with securities authorized by the California Government
Code and the City.
(1) The eligible collateral for repurchase agreements must be those
investments authorized by Section 53651 of the California
Government Code. The Chief Financial Officer may specify the type
of eligible collateral for use in repurchase agreements. Eligible
collateral must be in book entry form. Collateral is valued at current
market plus accrued interest through the date of valuation.
(a) The cost value (book value) of collateral pledged for demand
deposits must at all time be equal to or greater than the
amount on deposit, plus accrued interest, in accordance with
the following ratio:
U.S. Treasury Securities 110%
(b) The cost value (book value) of collateral pledged for
repurchase agreements must at all time be equal to or greater
than the par amount, plus accrued interest, with the following
ratios: City of Culver City Investment Policy Revised 2011
9
U.S. Treasury Securities 102%
U.S. Government Agencies 102%
Cash (in immediately available funds) 100%
(2) It is the policy of the City to require reports at least on a quarterly
basis from institutions with which the Chief Financial Officer has
pledged security interest. The Chief Financial Officer shall monitor
the adequacy of collateralization to ensure that balances are
collateralized in accordance with the ratios approved herein.
(3) With regard to repurchase agreements, it is the policy of the City to
initiate a margin call in the event pledged collateral falls below the
appropriate ratio.
(4) Collateralized investments and deposits often require substitution of
collateral. Any broker or financial institution requesting substitution
must contact the City for approval in the event the counterparty to
the transaction is not authorized under agreement with the City to
make substitutions.
17. AUTHORIZED INVESTMENTS
The City is governed by the California Government Code, Sections 53600
et. seq. Within the context of these limitations and based on the cost at
the time of purchase, the following investments are authorized as further
limited herein:
Authorized Investment Summary Matrix
Category Percent
A. US Treasuries no limit
B. US Agencies no limit
C. Bankers’ Acceptances 25%
D. Commercial Paper 15%
E. Repurchase Agreements 25%
F. Reverse Repurchase Agreements 15%
G. Local Agency Investment Fund (LAIF) Per State limit
H. Municipal Bonds no limit
I. Corporate Medium Term Notes 20%
J. Money Market Mutual Funds 20% City of Culver City Investment Policy Revised 2011
10
K. CalTrust MMF and Short-Term Funds no limit
L. CalTrust Medium-Term Fund 15%
A. United States Treasury Bills, Bonds, and Notes, or those for which the
full faith and credit of the United States are pledged for payment of
principal and interest. There is no limitation as to the percentage of
the portfolio that can be invested in this category.
B. Obligations issued by the Government National Mortgage
Association (GNMA), the Federal Farm Credit Bank System (FFCB),
the Federal Home Loan Bank Board (FHLB), Federal Home Loan
Mortgage Corporation (FHLMC), Federal National Mortgage
Association (FNMA), and the Student Loan Marketing Association
(SLMA). Although there is no percentage limitation on these issues,
no more than 30% of the cost (book) value of the portfolio will be
invested in any one agency.
C. Bills of exchange or time drafts drawn on and accepted by a
commercial bank, otherwise known as Bankers’ Acceptances.
Bankers’ Acceptances purchased may not exceed 180 days to
maturity or 25% of the cost (book) value of the portfolio. No more
than 5% of the cost (book) value of the porfolio may be invested in
Bankers’ Acceptances issued by any one bank. Prior to the
purchase of any Banker’s Acceptance, the portfolio manager shall
review the rating of the issuing bank. Bankers’ Acceptances of
issuing financial institutions shall have both a short and long term
rating in the highest category by at least one nationally recognized
rating agency at the time of purchase.
D. Commercial Paper ranked P1 by Moody's Investor Services and A1 by
Standard and Poor's and issued by a domestic corporation having
assets in excess of $500 million. The commercial paper must also
have an A or better rating for the issuers debt, other than
commercial paper, if any, as provided by Moody's or Standard and
Poor's. Purchase of commercial paper from corporations on
negative credit watch by a major rating agency shall be prohibited.
Purchases of eligible Commercial Paper may not exceed 270 days
to maturity nor represent more than 10% of the outstanding paper of
an issuing corporation. Purchases of Commercial Paper may not
exceed 15% of the cost value of the portfolio at time of purchase.
No more than 5% of the cost value of the portfolio may be invested
in Commercial Paper issued by any one corporation. Corporate
Medium Term Note and bankers’ acceptance holdings shall be
considered when calculating the maximum dollar amount in any City of Culver City Investment Policy Revised 2011
11
issuer name.
Upon any announcement of negative credit watch or downgrade
by a major rating agency of any issue within the portfolio, the
investment manager should contact the Chief Financial Officer and
recommend a course of action. If at any time a security falls below
“investment grade,” the investment manager should obtain the best
bid and take the necessary steps toward liquidation.
E. Repurchase agreements. The City may invest in repurchase
agreements with banks and primary dealers with whom the City has
entered into a master repurchase agreement that specifies terms
and conditions of repurchase agreements. No more than 25% of the
cost value of the portfolio may be invested in repurchase
agreements at any time. The maturity of repurchase agreements
shall not exceed 75 days.
The cost value of securities used as collateral for repurchase
agreements shall be monitored daily by the Chief Financial Officer
and will not be allowed to fall below the margin ratios specified in
Section 16 (1)(b) of this policy. In order to conform with provisions of
the Federal Bankruptcy Code which provides for the liquidation of
securities held as collateral for repurchase agreements, the only
securities acceptable as collateral shall be securities that are direct
obligations of, or that are fully guaranteed as to principal and
interest by, the United States Government such as Treasury bills,
Treasury notes or Treasury bonds with less than a five year maturity.
F. Reverse repurchase agreements. The City may invest in reverse
repurchase agreements only with those banks and primary dealers
with whom the City has entered into a master repurchase
agreement outlining terms and conditions of repurchase and reverse
repurchase agreements. The City may only invest in reverse
repurchase agreements for the following purpose:
1. The City may enter into reverse repurchase agreements
when funds obtained through the reverse can be
reinvested in a higher yielding security to obtain
additional interest income for the City at a spread
deemed to be acceptable by the Chief Financial
Officer under then prevailing market conditions. Reverse
repurchase agreements entered into in accordance
with this paragraph may not exceed 75 days to maturity City of Culver City Investment Policy Revised 2011
12
and must be matched as to maturity and dollars
invested with its corresponding reinvestment. No more
than 15% of the cost value (book value) of the portfolio
may be invested in reverse repurchase agreements.
2. Reverse repurchase agreements may be used for
liquidity purposes when it is determined that the portfolio
has sufficient additional collateral coming due within the
term of the reverse repurchase agreement equal to or
exceeding the amount of the reverse repurchase
agreement.
G. Local Agency Investment Fund (LAIF). The City may invest in the LAIF
established by the State Treasurer for the benefit of local agencies
up to the maximum permitted by State law.
H. Bonds issued by local agencies in the State of California, including
bonds payable solely out of the revenues from a revenue-producing
property owned, controlled, or operated by the local agency or by a
department, bond, agency, or authority of the local agency rated
“AA” or better. "AA" rated bonds shall be limited to 36 months
maximum maturity and "AAA" rated bonds shall be limited to 60
months maximum maturity.
Upon any announcement of negative credit watch or downgrade
by a major rating agency of any issue within the portfolio, the
investment manager should contact the Chief Financial Officer and
recommend a course of action. If at any time a security falls below
“investment grade,” the investment manager should obtain the best
bid and take the necessary steps toward liquidation.
I. Corporate medium term notes issued by a domestic corporation
having assets in excess of $500 million and having an “AA” or better
rating criteria at time of purchase on its long-term debentures as
provided by Moody's or Standard and Poor's. Purchase of corporate
medium term notes from corporations on negative credit watch by a
major rating agency shall be prohibited. "AA" rated medium term
notes shall be limited to 36 months maximum maturity and "AAA"
rated medium term notes shall be limited to 60 months maximum
maturity. The aggregate total of all purchased medium term notes
may not exceed 20% of the cost value of the portfolio. No more
than 5% of the cost value of the portfolio may be invested in
corporate medium term notes issued by any one corporation. City of Culver City Investment Policy Revised 2011
13
Commercial Paper and bankers’ acceptance holdings shall be
considered when calculating the maximum percentage in any issuer
name.
Upon any announcement of negative credit watch or downgrade
by a major rating agency of any issue within the portfolio, the
investment manager should contact the Chief Financial Officer and
recommend a course of action. If at any time a security falls below
“investment grade,” the investment manager should obtain the best
bid and take the necessary steps toward liquidation.
J. Money Market Mutual funds having a rating of AAA/Aaa or an
equivalent by one or more national rating agencies with no load
and maintained at $1 par value. No more than 20% of portfolio
value should be invested in this category; investment in a single
mutual fund will not to exceed 10% of the cost value (book value) of
the total portfolio exclusive of the fiscal agent cash portfolio, and the
City's investment in any specific mutual fund will not exceed 2% of
that mutual fund's total assets.
K. Investment Trust of California (CalTrust). The City may invest in the
Money Market Fund and Short-Term fund established by this Joint
Powers Authority. There is no limit on the percentage of the portfolio
that can be invested in these funds.
L. Investment Trust of California (CalTrust). The City may invest in the
Medium-Term fund established by this Joint Powers Authority. No
more than 15% of portfolio value should be invested in this category.
18. INELIGIBLE INVESTMENTS
Investments not described herein including, but not limited to, equity
securities such as common stocks, preferred stocks, convertibles, inverse
floaters, range notes and interest-only strips that are derived from a pool of
mortgages are prohibited from use in this portfolio. The City is prohibited
from entering into a margin agreement and/or borrowing on margin.
19. INVESTMENT COMMITTEE
An Investment Committee shall be established consisting of but not limited
to the Chief Financial Officer, members of the Chief Financial Officer’s staff, City of Culver City Investment Policy Revised 2011
14
a City Council member, the City Manager and Community Development
Director.
20. INVESTMENT POLICY ADOPTION
The City Council shall review and adopt this Investment Policy annually.City of Culver City Investment Policy Revised 2011
15
GLOSSARY
AGENCIES - Agencies of the Federal government set up to supply credit to
various classes of institutions (e.g., S&L's, small business firms, students,
farmers, housing agencies, etc.) Examples include Federal Home Loan
Mortgage Corporation (FHLMC), Federal National Mortgage Association
(FNMA), Federal Home Loan Bank (FHLB) and Federal Farm Credit Bank
(FFCB).
ASK/OFFER - The price at which securities are offered. (The price at which a
firm will sell a security to an investor)
BANKERS’ ACCEPTANCE (BA) - A draft or bill of exchange accepted by a
bank or trust company. The accepting institution guarantees payment of
the bill as well as the issuer.
BASIS POINT - One one-hundredth of a percent (i.e., 0.01%)
BEAR MARKET - A period of generally pessimistic attitudes and declining
market prices.
BID PRICE - The price at which a broker/dealer will buy securities from an
investor.
BOND EQUIVALENT YIELD - The basis on which yields on notes and bonds are
quoted.
BOOK VALUE (COST VALUE) - The purchase price of the security as recorded
on the City’s books.
BROKER/DEALER – An individual or firm acting as principal in a securities
transaction.
BULL MARKET - A period of generally optimistic attitudes and increasing
market prices.
CALLABLES - Securities that the issuer has the right to redeem prior to
maturity.
CERTIFICATE OF DEPOSIT (CD) - A time deposit with a specific maturity
evidenced by a certificate. Large denomination CD's are typically
negotiable.
CMT - Constant Maturity Treasury – An index of the average yield on United City of Culver City Investment Policy Revised 2011
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States Treasury securities adjusted to a constant maturity.
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.
COMMERCIAL PAPER - Commercial Paper is issued by leading industrial and
financial firms to raise working capital. The maturities are from 3 to 180 days,
usually sold on a discount basis. The City and Redevelopment Agency only
buys Commercial Paper issued by corporations with the highest possible
credit rating. Investments in Commercial Paper may not exceed 25% of the
City or Redevelopment Agency’s's surplus funds.
CORPORATE MEDIUM TERM NOTE - A security issued by a corporation doing
business in the U.S. with a maturity not to exceed five years.
COST VALUE (BOOK VALUE) - The purchase price of the security as recorded
on the City’s books.
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 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.
DEBENTURE - A bond secured only by the general credit of the issuer.
DELIVERY VS PAYMENT - Delivery of securities with a simultaneous exchange
of money.
DEMAND ACCOUNT – An account with a commercial bank from which
check withdrawals may be made at any time.
DERIVATIVES - Financial products that are dependent for their value on (or
derived from) an underlying financial instrument, a commodity, or an index
representing values of groups of such instruments or assets.
DISCOUNT - The difference between the cost price of a security and its
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.
DIVERSIFICATION - Dividing investment funds among a variety of securities City of Culver City Investment Policy Revised 2011
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offering independent returns.
FEDERAL CREDIT AGENCIES - Agencies 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 agency that
insures bank deposits, currently up to $250,000 100,000 per deposit. Note
that this is set to revert back to $100,000 per deposit on December 31, 2009
unless extended by Congress.
FEDERAL FUNDS RATE – Interest rate charged by one institution lending
federal funds to another.
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 FHLBs
is to liquefy the housing related assets of its members who must purchase
stock in their district Bank.
FEDERAL NATIONAL MORTGAGE ASSOCIATION (FNMA) - FNMA, like GNMA
was charted under the Federal National Mortgage Association Act in 1938.
FNMA is a federal corporation working under the auspices of the
Department of Housing and Urban Development (HUD). 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
corporation. 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 will 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 of bank credit and money.
FINANCIAL ADVISOR - A firm or bank that acts in a financial advisory
capacity with respect to a new issue of municipal securities pursuant to a
written contract. City of Culver City Investment Policy Revised 2011
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FISCAL AGENT - A financial institution with trust powers which acts in a
fiduciary capacity for the benefit of the bondholders in enforcing the terms
of the bond contract.
GOVERNMENT 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. Security holder is protected by full faith
and credit of the U.S. Government. Ginnie Mae securities are backed by
the FHA, VA or FmHA mortgages. The term "pass-throughs" is often used to
describe Ginnie Maes.
INTERNAL RATE OF RETURN - Rate of return over the life of a security on
variables.
INVESTMENT TRUST OF CALIFORNIA (dba CalTRUST) – A Joint Powers
Authority investment pool administered by the California State Association
of Counties, and sponsored by the League of California Cities.
LIQUIDITY - A liquid asset is one that can be converted easily and rapidly
into cash without a substantial loss of 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 investment and reinvestment.
MARKET VALUE - The price at which a security is trading, usually the
liquidation value.
MONEY MARKET MUTUAL FUNDS – Open-ended mutual fund that invests in
commercial paper, banker’s acceptances, repurchase agreements,
government securities, certificates of deposit and other highly liquid and
safe securities, and pays money market rates of interest. The fund’s net
asset value remains a constant $1 a share, with the interest rate increasing
or decreasing.
OFFER PRICE - The price at which a broker/dealer will offer securities to an
investor.
OPEN MARKET OPERATIONS - Federal Reserve activity. Under the Federal
Reserve Act, the Fed uses purchases and sales of Government and Federal City of Culver City Investment Policy Revised 2011
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Agency securities to add to or subtract from commercial bank reserves.
Goals are to sustain economic growth, high employment and reasonable
price stability.
PAPER GAIN OR LOSS - Term used for unrealized gain or loss on securities
being held in a portfolio based on comparison of current market quotes
and their original cost. This situation exists as long as the security is held
while there is a difference between cost value (book value) and the
market value.
PRIMARY DEALER - A group of government securities dealers that submits
daily reports of market activity, positions and monthly financial 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.
PSA - The Public Securities Association is the international organization of
banks, dealers and brokers that underwrite, trade and sell municipal
securities, mortgage-backed securities, money market securities and U.S.
government and federal agency securities.
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, the current income return.
SAFEKEEPING - The service provided by banks and trust companies for
clients when the bank or trust company stores the securities, takes in
coupon payments, and redeems issues at maturity.
SPREAD - a) The yield or price difference between the bid and offer on an
issue; b) the yield or price difference between different issues.
SWAP - The sale of one issue and the simultaneous purchase of another for
some perceived advantage.
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 BONDS – U.S. Treasury securities that have initial maturities of
more than ten years.
TREASURY NOTES - Intermediate-term coupon bearing U.S. Treasury City of Culver City Investment Policy Revised 2011
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securities having initial maturities of from one year to ten years.
TRUSTEE - A financial institution with trust powers that acts in a fiduciary
capacity for the benefit of the bondholders in enforcing the terms of the
bond contract.
WHEN ISSUED BASIS (WI) - A term applied to securities that are traded
before they are actually issued with the stipulation that transactions are null
and void if securities are not issued.
YIELD CURVE - Yield calculations of various maturities at a given time to
observe spread difference.
YIELD TO MATURITY - The current coupon yield minus any premium above
par, or plus any discount from par in the purchase price with the
adjustment spread over the period from date of purchase to maturity. Exhibit A
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CITY OF CULVER CITY
Request for Qualifications
Selection of Broker/Dealer Firms
I. Introduction:
The City of Culver City (City) has issued a Request For Qualifications (RFQ) for
the purpose of maintaining an Approved List of qualified broker/dealers. It is the
intent of the City to promote an open and thorough process, subject to periodic
review, where qualified broker/dealer firms may be added (or removed) from the
Approved List. The Approved List will be in effect for a period of three (3) years.
At the conclusion of the three year period the City will issue a new RFQ. The
approval process will be conducted by the City’s Investment Committee (IC).
The RFQ process will include specific criteria that the City of Culver City believes
is necessary for broker/dealer firms to efficiently and competitively “offer or bid”
eligible securities to be purchased and sold by the City’s Investment Manager.
Broker/dealers on the Approved List will be used strictly for trade execution
purposes only.
The IC, Chief Financial Officer, designated City staff, and the City’s Investment
Manager will participate in the evaluation process. After a review of RFQ
responses and consideration of staff’s recommendation, the IC will make the final
selection of broker/dealers for inclusion on the List. Each firm on the list will be
required to complete an Acknowledgement of Compliance Standards for
Investment Transactions (Attachment 1). Once the Approved List of all qualified
firms has been completed by the IC, the City’s Investment Manager will utilize
such firms when executing investment transactions for the various portfolios of the
City.
The City’s Investment Manager will meet (or discuss via conference call) with the
approved broker/dealer firms for the purpose of reviewing the City’s Investment
Policy (Attachment 2), defining the types of investment strategies that may be
employed during differing bond market environments, identifying various eligible
investments to be utilized for the portfolios, reviewing the securities selection
process and how securities are evaluated prior to purchase, and reviewing other
technical matters relevant to promoting an efficient and competitive trade
execution process.
The City’s Investment Manager will review the quality of the broker/dealer
coverage based upon the criteria as presented in this RFQ, and notify the IC, City
staff, and the Chief Financial Officer of any deficiencies in the quality of coverage.
Recommendations to add or delete may be made at any time, as recommended
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by the City’s Investment Manager and approved by the Chief Financial Officer and
the IC.
The number of broker/dealers on the City’s approved list will vary based upon the
need to balance a competitive process within the context of manageable and
efficient executions.
II. Brief Overview of the City of Culver City’s Investment Program
The City of Culver City (the City) is a statutory (home rule) Government operating
under the laws of the State of California and the City’s Municipal Code. The City’s
main portfolio, comprised of operating funds, ranges in size from $100 - $150MM.
The Operating Portfolio primarily contains various Federal Agency obligations,
both non-callable and callable. The City also maintains a bond proceeds portfolio
and several Special Districts accounts, primarily comprised of short-maturity
securities. The City’s investment program is governed under California
Government Code 53601 and is further defined by an adopted Investment Policy.
III. Minimum Qualifications of Respondents
Candidate broker/dealers:
(1) Must be licensed to operate as a broker/dealer in the State of California.
(2) Must be employed by a firm that qualifies under the Securities and
Exchange Commission Rule 15C3-1 (Uniform net capital rule).
(3) Must be in good standing with the appropriate regulatory agencies.
Note: Good standing includes both the broker/dealer firm as well as the
registered representative assigned to the City’s account.
(4) Must have a working knowledge of the State of California Government
Code § 53601 that governs public funds investment.
Note: Selected broker/dealers must sign the City’s approved Investment
Policy as an acknowledgement of receipt and comprehension.
(5) Must provide audited annual financial statements and SEC 10K reports
evidencing the current and historical profitability of the firm.
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(6) Must have institutional fixed-income experience.
Broker/dealer firms and the registered representative assigned to the City’s
account must be experienced in the area of institutional fixed-income.
Specific experience illustrating knowledge of the one to five year yield curve
will be considered during the review process. The City’s Investment
Manager may utilize approved broker/dealers where they demonstrate their
most efficient and competitive executions. However, all broker/dealers
must be capable of offering all eligible securities, as defined in the City’s
approved Investment Policy. Such offerings may include US Treasury Bills,
commercial paper, bankers’ acceptances, US Treasury Notes, and federal
agency discount notes, and new-issue and secondary Federal agency
obligations.
(7) Participation in New-Issue Federal Agency Securities
Broker/dealers will be asked to provide details of the amount and structure
of new-issue federal agency issues sold to institutional accounts over the
preceding three-year period.
IV. Additional Criteria:
In addition to the minimum requirements set forth in the RFQ, the City may elect to
include the following additional criteria during the evaluation process:
1. Registered representatives who are employed by a broker/dealer
firm whose offices are located in Southern California, preferably
within the City of Culver City, and the registered representative of the
broker/dealer is working at the California location.
2. Registered representatives of broker/dealers who provide coverage
to other California local agencies with portfolios similar to the City of
Culver City.
3. Total capital and/or capital adequacy ratio of the firm.
4. Whether the firm is self-clearing or has outside clearance
arrangements.
Note: The clearing arrangements of broker/dealers with total
capital of less than $10MM will be examined before any firm is
added to the approved list.
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5. The current and historical profitability of the firm.
6. If the firm has insurance to cover any losses that may be attributable
to errors that have impacted the City’s investment program (i.e.,
unresolved delivery problems, delivery of incorrect securities).
V. Submittal Information
Statements of Qualifications must be submitted to the Purchasing Agent, City of
Culver City, no later than January 9, 2008 at 5:30 p.m.
If hand delivered to the Civic Center, proposals shall be submitted to the
Receptionist for the Purchasing Agent at the Reception Desk located on the first
floor. Statements of Qualifications shall be submitted in sealed envelopes marked
on the outside, “Broker-Dealer Services, RFQ No. 07-2253.” Responses are
limited to 20 pages total. Submit one (1) original, one copy, and a PDF on CD of
the Statement of Qualifications. The original Statement of Qualifications must be
unbound. Confidential financial information should be submitted in a separate
sealed envelope, marked, “Confidential.”
Submit Statements of Qualifications to:
By mail:
City of Culver City
Purchasing Agent
P.O. Box 19575
Culver City, CA 92623-9575
Overnight or hand delivery:
City of Culver City
c/o Receptionist for Purchasing Agent
1 Civic Center Plaza
Culver City, CA 92606-5208
Any requests for clarification or other questions concerning this RFQ must be
submitted in writing and sent via email to Donna Mullally at dmullally@ci.Culver
City.ca.us, with a copy to Tracy Hamilton at tphamilton@ci.Culver City.ca.us, no
later than December 20, 2007 at 5:30 p.m.
LATE STATEMENTS OF QUALIFICATIONS WILL NOT
BE ACCEPTED
The City of Culver City reserves the right to reject any or all Statements of
Qualifications, to waive any informality in any Statement of Qualifications, and to
select the Statements of Qualifications that best meet the City’s needs.
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Please respond to the following items using this form along with additional
sheets if needed.
Request for General Information from Broker/Dealer Candidate
1. Name of firm:
Address – Local:
Headquarters:
Telephone – Local:
Headquarters:
2. Primary Representative (provide an attachment if more space is required)
Name:
Title:
Telephone:
Email Address:
Address:
Additional Staff
Name:
Title:
Telephone:
E-mail Address:
Address:
Name:
Title:
Telephone:
E-mail Address:
Address:
Provide background information concerning the account representatives
listed in above. Please include information on the individual’s employment
history as it relates to the securities industry, official licenses and
certificates, the history and details of any disciplinary actions or complaints
and the disposition of each as well as the history of any arbitration or
litigation, the nature of the case and status or disposition.
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3. Has/have the representative(s) listed in No. 2 been authorized by the firm to
be the account representative(s) for the City of Culver City?
Yes _________ No __________
If Yes, by whom?______________________________________________
4. Has/have the representative(s) listed in No. 2 obtained all required licenses
to operate as a broker/dealer in the State of California?
Yes __________ No __________
5. Please list the name, and title of the immediate supervisor of the account
representative(s) named in your response to No. 2 above.
1. ______________________________________________________
2. ______________________________________________________
6. Briefly describe any formal program of supervision of the account
representative(s) named in No. 2 if your firm has established such a
program.
____________________________________________________________
____________________________________________________________
____________________________________________________________
____________________________________________________________
7. Is the firm a:
Primary Dealer ____ Regional Dealer ____ Brokerage Firm ____
8. Has the firm consistently complied with the Federal Reserve Bank’s capital
adequacy guidelines? Include certified documentation of your current
capital adequacy as measured by Federal Reserve standards.
9. Please provide the firm’s and primary representative’s experience in
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covering fixed income institutional accounts, in particular public entities.
Please indicate the percentage of the firm’s accounts that are comprised of
public entities.
10. Please provide the following information regarding at least four comparable
clients with whom any of the representatives listed in No. 2 have an
established relationship.
Client Name:
Contact Person:
Address:
Phone:
Length of relationship:
Client Name:
Contact Person:
Address:
Phone:
Length of relationship:
Client Name:
Contact Person:
Address:
Phone:
Length of relationship:
Client Name:
Contact Person:
Address:
Phone:
Length of relationship:
11. Does the firm self-clear securities? Yes _____ No _____
If no, please provide specific details of the firm’s clearing arrangements.
Include details of your firm’s internal process for ensuring that delivery in
good order occurs on settlement date.
12. Describe the firm’s insurance to cover losses that may occur if securities
are not delivered, or if the delivery of incorrect securities causes a loss to
the City.
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13. Is the firm able to offer all eligible securities as defined in the City’s
Investment Policy?
Please respond to the following questions in a comprehensive manner by
providing specific details of the Firm’s agency offerings.
1. Participation in New-Issue Federal Agency Securities
Please discuss each of the following categories, where relevant, regarding
your firm’s participation and experience as a participant in the underwriting
of new-issue Federal Agency obligations. Provide specific information
such as issuance size, structure, and par amount sold attributable to your
firm:
(1) Approved by one or more federal agencies as an underwriter of their
debt issuance program; name the federal agencies.
(2) Participated as a selling group member of one or more federal
agencies.
(3) The firm regularly obtains federal agency securities from selling
group members during syndication periods.
(4) The firm has experience as a sole underwriter.
2. Reverse Inquiries
Detail the firm’s experience in underwriting and/or participating in “reverse
inquiries”, including the structure of such underwritings.
3. Structure of Past Issuances
Please provide information regarding the type (i.e., discount notes, fixed or
floating rate) and call structure of issuances in which the firm participated as
an underwriter. Please provide information regarding the types and
structures in which the firm participated as a selling group member.
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4. Participation in the Secondary Market
Please describe your firm’s capacity to “offer” or “bid” secondary market
issues. Has the firm regularly offered and delivered specifically defined
securities or structures as requested by your institutional client(s)? If an
order for specific securities was not filled, has the firm offered alternative
securities with similar structures (and price) that “fit” the institutional client’s
criteria? Please provide examples.
5. Access to Inventory
Does the firm maintain its own inventory positions that can be accessed by
the City’s Investment Manager? If not, please discuss the firm’s ability to
acquire an inventory of specific securities, as identified by the City’s
Investment Manager.
At the option of the City’s Investment Manager the firm may be asked to
offer other securities of similar structure and yield spread. Please provide
past examples of inventory items that your firm has listed (for consideration
by your institutional clients), including accompanying specifics of the
offerings.
6. Order-Based Transactions
On occasion, the City’s Investment Manager may periodically request an
offering of securities that fits the current investment strategy where the
market yield of such securities is priced at a yield spread versus the yield of
various “benchmark” securities. Please describe past transactions,
including the firm’s ability to fill such orders in a timely manner and at price
levels equivalent to the market’s existing yield spread basis, versus the
relevant benchmark securities, at the time of execution.
Explain your methods of pricing an offering; i.e., the price based upon a
yield spread basis and/or the spread of other comparable securities, or
both. Provide recent examples.
7. Delivery of Securities
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All firms must demonstrate their ability to deliver securities on settlement
date. Only delivery versus payment transactions to the City’s designated
custodian bank will occur. Regular delivery “fails” will be grounds for
removal as an approved broker/dealer. Please provide the number and
percentage of failed trades within the last year.
Note: The City utilizes a third party custodian bank and numerous trustee
accounts to safekeep its securities. All broker/dealers must deliver
securities to the custodian versus payment.
VI. Request for Broker/Dealer Candidate Disclosure
1. To the best of your knowledge, has there been any “material” litigation,
arbitration or regulatory proceedings, either pending, adjudicated or settled,
that the firm has been subject to within the last five years that involved
issues concerning the suitability of the sale or purchase of securities to
institutional clients or fraudulent or unfair practices related to the sale of
securities to an institutional client? If so, please describe each such matter
briefly. For purposes of this section, proceedings are “material” if your
independent accountant applying generally accepted accounting principles
determines that such proceedings required disclosure on your financial
statements.
2. Has this firm, or the representatives assigned to this account, been subject
to a regulatory agency, state or federal investigation for alleged improper,
disreputable, unfair or fraudulent activities related to the sale of securities or
money market instruments in the past five years that resulted in suspension
or censure? Are there outstanding claims? If yes, please explain.
3. Have any of your public-sector clients ever sustained or claimed a loss on a
securities transaction or loss of principal arising from a misunderstanding or
misrepresentation of the risk characteristics of a recommended instrument
purchased through your firm? If yes, please explain.
4. Describe the precautions taken by your firm to protect the interests of the
public when dealing with a governmental agency.
5. Please include annual audited financial statements with this RFQ for the
past three fiscal years which confirm compliance with the capital adequacy
standard and indicate the amount of the firm’s liquid capital. Also include
current fiscal year SEC 10K reports. Confidential financial information
should be submitted in a separate sealed envelope, marked, “Confidential.”
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6. Please include a letter from a Certified Public Accountant indicating there
are no material weaknesses in the firm’s internal control systems.
VII. Certification
I hereby certify that I have personally read the City of Culver City’s Investment
Policy and the California Government Code pertaining to the investments of the
City of Culver City; that the above information is true and correct to the best of my
knowledge; and that I am authorized to execute this RFQ on behalf of
_________________
Signed
Print Name
Title
Date
Counter signature by Company President or person in charge of government
securities operations:
Signed
Print Name
Title
Date
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Definitions:
A “Benchmark” security is a bond or note of a significantly large issuance size
whose yield at a moment in time is used to establish the price of another security,
based upon a yield spread. Both new-issue federal agencies and securities in the
secondary market are regularly offered on this basis. For example, the current 2-
yr, 3-yr, or 5-yr US Treasury Notes are primarily used when examining the yield
spread that exists in the bond market when determining the market price or yield
of a federal agency obligation as established by market forces. The shape of the
yield curve typically affects changes in yield spreads between asset classes.
A “Reverse Inquiry” occurs when the client selects a broker/dealer to underwrite
an issue (federal agency) based upon specific structural criteria defined by the
client. A firm participates in a reverse inquiry by selling portions of the issue size
to other clients. Selling a portion of the issue to other clients is more difficult since
the original structure was customized by the original client.Exhibit B
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