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HomeMy WebLinkAbout20030595 RESOLUTION RE: ADOPT WELD COUNTY INVESTMENT POLICY WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, the Department of Finance and Administration has presented an Investment Policy to the Board of County Commissioners of Weld County, for consideration and approval, and WHEREAS, after review, the Board deems it advisable to adopt said policy, a copy of which is attached hereto and incorporated herein by reference. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that the Weld County Investment Policy be, and hereby is, adopted. The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 5th day of March, A.D., 2003. BOARD OF COUNTY COMMISSIONERS A �I /�, WE COUNTY,/COLO DO ATTEST: fa e,Y"�`f / /' t D ' E. Long, Ch it Weld County Clerk to thg Boarr4 a, � < ' c f? 1 I Robert D. asden, Pro-Tem BY: ee rn i Deputy Clerk to the Board M. J. eile AP AS TO EXCUSED Willis H. Jerke ount Attor y WA `/ Glenn Vaad Date of signature: // 2003-0595 FI0037 �' 0 Fa 7R WELD COUNTY INVESTMENT POLICY I. INTRODUCTION Section 6-1 of the Weld County Home Rule charter was amended by the Weld County voters on November 8, 2001, making the office of County Treasurer appointed by the Board of Weld County Commissioners, effective January 1, 2003. The County Commissioners, in consultation with the County's auditors, decided per a resolution dated October 7, 2002, to place the Weld County Treasurer's Office under the Division of Finance and Administration, and to combine the position of County Treasurer with the existing Controller's position. In order to fulfill their fiduciary responsibilities concerning the Treasurer's investments the Board of Weld County Commissioners decided that an oversight committee, known as the Investment Advisory Committee, should be created which includes the Treasurer, Chief Deputy Treasurer, Director of Finance and Administration, Chair, and Chair Pro- tem of the Board of Weld County Commissioners. This Investment Policy replaces any previous Investment Policy or Investment Procedures of Weld County. The investment guidelines outlined below have been written to comply with various regulatory requirements under which Weld County operates. This Investment Policy was endorsed and adopted by the Weld County Investment Advisory Committee on February 12, 2003. The Board of Weld County Commissioners adopted the policy on March 5, 2003. II. SCOPE The following investment policy addresses the methods, and procedures which must be exercised to ensure effective and judicious fiscal and investment management of the County's funds. This policy shall apply to the investment management of all financial assets and funds under control of the County except for its employee retirement system fund, which is organized and administered separately by the Weld County Retirement Board. These investment transactions/activities are accounted for in the government's annual financial report and include the following: • General fund, • Special Revenue funds, • Debt Service funds. • Capital Projects funds, • Enterprise fund, • Internal Service funds, • Trust and Agency funds - Expendable Trust funds & Agency funds, and • Any new fund created by the governing body. unless specifically exempted by the governing body 2003-0595 III. INVESTMENT OBJECTIVES All funds which are held for future disbursement shall be deposited and invested by the County in accordance with Colorado State Statutes and ordinances and resolutions enacted by the Board of Weld County Commissioners in a manner to accomplish the following objectives: 1. Safety of Funds: Safety of principal is the foremost objective of the investment program. Investments shall be undertaken in a manner that seeks to ensure the preservation of capital in the overall portfolio. The objective will be to mitigate credit risk and interest rate risk. a) Credit Risk. The County will minimize credit risk, the risk of loss due to the failure of the security issuer, by • Limiting investments to the safest types of securities; • Pre-qualifying the financial institutions, broker/dealers, and advisors with which the County does business, and • Diversifying the investment portfolio so that potential losses on individual securities will be minimized. b) Interest Rate Risk: The County will minimize the risk that the market value of securities in the portfolio will fall due to changes in general interest rates by: • Structuring the investment portfolio so that securities mature sufficiently close to cash requirements for ongoing operations, thereby minimizing the potential need to sell securities on the open market prior to maturity and • Investing operating funds primarily in short- to intermediate-term securities, approved local government investment pools, approved money market mutual funds and repurchase agreements. 2. Liquidity of Funds: The investment portfolio shall remain sufficiently liquid to meet all operating requirements that may be reasonably anticipated. To ensure that adequate funds are available to pay the County's projected financial obligations, investments will be purchased that reasonably match the anticipated cash disbursements of the County. Since all possible cash demands cannot be anticipated, the portfolio shall consist largely of securities with active secondary or resale markets so that the potential for a realized loss, if an early liquidation of a security is necessary, will be minimized. A core of stable funds may be identified through cash flow analysis that is available for investing in longer-term securities. Although the market value of these longer-- term securities may fluctuate significantly, the fluctuation will not affect the liquidity of the portfolio since they can be held to maturity in all but extreme circumstances. 3. Yield: The County's portfolio shall earn a competitive market rate of return on available funds throughout budgetary and economic cycles. In meeting this objective, investment management personnel will take into account the County's investment risk constraints and cash flow needs. The County's overall investment program shall be designed and managed with a degree of professionalism that is worthy of the public trust. The County recognizes that no investment is totally free of risk and that the investment activities of the County are a matter of public record. Accordingly, the County recognizes that occasional measured losses are inevitable in a diversified portfolio and shall be considered within the context of the overall portfolio's return, provided that this policy has been followed and that the sale of a security prior to maturity is in the best long-term interest of the County. Securities shall not be sold prior to maturity with the following exceptions: • A declining credit security could be sold early to minimize loss of principal; • A security swap would improve the quality yield or target duration in the portfolio, or • Liquidity needs of the portfolio require that the security be sold. IV. DELEGATION OF AUTHORITY Authority to manage the investment program is granted to the Controller/Treasurer derived from Article 11 of the Weld County Home Rule Charter. Responsibility for the operation of the investment program is hereby delegated to the Controller/Treasurer, who shall carry out established written procedures and internal controls for the operation of the investment program consistent with this investment policy. Procedures shall include references to: safekeeping, delivery vs. payment, investment accounting, repurchase agreements and banking services contracts. No person may engage in an investment transaction except as provided under the terms of this policy and the procedures established by the Controller/Treasurer. The Controller/Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. The Controller/Treasurer may engage the support services of outside professionals, so long as it can be demonstrated that these services produce a net financial advantage and necessary financial protection of the County's resources. Such services may include engagement of financial advisors in conjunction with debt issuance, portfolio management support, special legal representation, third party custodial services, and appraisal of independent rating services. V. PRUDENCE AND INDEMNIFICATION The standard of prudence, as defined by the Colorado Revised Statutes, to be used for managing the County's assets is the "prudent investor" rule applicable to a fiduciary, which states that a prudent investor "shall exercise the judgment and care, under circumstances then prevailing, which men of prudence, discretion, and intelligence exercise in the management of the property of another, not in regard to speculation but in regard to the permanent disposition of funds, considering the probable income as well as the probable safety of their capital" (CRS 15-1-304, Standard for Investments.) The Director of Finance, Controller/Treasurer and other authorized persons acting in accordance with written procedures and exercising due diligence shall be relieved of personal responsibility for an individual security's credit risk or market price changes provided deviations from expectations are reported in a timely fashion and the liquidity and the sale of securities are carried out in accordance with the terms of this policy. The Controller/Treasurer will be responsible for ensuring that sufficient liquidity exists to maintain the County's operations in the event of adverse market conditions or claims. VI. ETHICS AND CONFLICTS OF INTEREST As noted in Section 16-9 (2) (b) of the Weld County Home Rule Charter: "Neither the Treasurer nor employees of the Treasurer's Office shall have any proprietary interest in any financial institution in which the County maintains deposits." VII. ELIGIBLE INVESTMENTS AND TRANSACTIONS All investments will be made in accordance with the Colorado Revised Statutes (CRS) as follows CRS 11-10.5-101, et seq. Public Deposit Protection Act, CRS 11-47.101, et seq. Savings and Loan Association Public Deposit Protection Act; CRS 11-60-101, et seq. U.S. Agency Obligations; CRS 24-75-601, et seq. Funds-Legal Investments for Governmental Units; CRS 24-75-603, et seq. Depositories; and CRS 24-75-701, et seq. Local Governments-Local Government Pooling. (Reference Annex 1.) Any revisions on extensions of these sections of the CRS will be assumed to be part of this policy immediately upon being enacted. This investment policy further restricts the investment of County funds to the following types of securities and transactions: 1. Treasury Obligations: Treasury bills,Treasury notes,Treasury bonds and Treasury STRIPS with maturities not exceeding five years from the date of purchase. 2. Federal Instrumentality Securities: Debentures, discount notes, global securities, callable securities and stripped principal on coupons with maturities not exceeding five years from the date of purchase issued by the following only: Federal National Mortgage Association (FNMA), Federal Farm Credit Banks (FFCB), Federal Home Loan Banks (FHLB), Federal Home Loan Mortgage Corporation (FHLMC), and Student Loan Marketing Association (SLMA). For the purposes of this paragraph, a "weighted average life" will not constitute a stated final maturity. To be approved, federal instrumentality securities must be rated AAA by either Moody's or Standard 86 Poor's. 3. Eligible Bankers Acceptances with an original maximum maturity not exceeding 90 days, issued on domestic banks or branches of foreign banks domiciled in the U.S. and operating under U.S. banking laws with a minimum of$250 million combined capital and surplus (CRS 24-75-601.1f), whose senior long-term debt is rated, at the time of purchase AA by Standard&Poor's,Aa by Moody's. on AA by Fitch IBCA, Duff and Phelps and deposits of the issuing bank must be insured by the Federal Deposit Insurance Corporation (FDIC). 4. Repurchase Agreements with a defined termination date of 180 days or less collateralized by U. S. Treasury and agency securities listed in item 1 and 2 above with a maturity not exceeding 10 years. Title must transfer to the County of Weld or the County must have a perfected security interest. For the purpose of this section, the term "collateral" shall mean "purchased securities" under the terms of the County's approved Master Repurchase Agreement. The purchased securities shall have a fixed coupon rate and an original minimum market value including accrued interest of 102 percent of the dollar value of the transaction and the collateral maintenance level shall be 102 percent. Collateral shall be held in the County's custodial bank as safekeeping agent, and the market value of the collateral securities shall be marked-to-the-market daily based on that day's bid price. Repurchase Agreements shall be entered into only with dealers who have executed a Master Repurchase Agreement with the County and who are recognized as Primary Dealers with the Market Reports Division of the Federal Reserve Bank of New York. A copy of the County's approved Master Repurchase Agreement is included in Annex III and a list of dealers who have an executed Master Repurchase Agreements with the County are listed in Annex III. Approved counterparties to repurchase agreements shall have at least a short-term debt rating of A-1 or the equivalent and a long-term debt rating of A or the equivalent from one on more nationally recognized organizations which regularly rates such obligations. 5. Local Government Investment Pools authorized under CRS 24-75-701, 702 which: 1) are "no-load" (i.e., no commission fees shall be charged on purchases on sales of shares); 2) have an objective of maintaining a constant daily net asset value per share (usually $1.00 per share); 3) limit assets of the fund to securities authorized in this investment policy; 4) have a maximum stated maturity and weighted average maturity in accordance with Federal Securities Law Regulation 2A-7; and 5) have a rating of AAAm by Standard & Poor's or AAA by Moody's or AAA/V-1+ by Fitch IBCA, Duff& Phelps. 6. Time Certificates of Deposit or savings accounts in state or national banks or in state or federally chartered savings and loans which are state approved depositories per CR5 24-75-603, et seq. (as evidenced by a certificate issued by the State Banking Board) and are insured by the FDIC. Certificates of deposit which exceed the FDIC insured amount shall be collateralized in accordance with the Colorado Public Deposit Protection Act. 7. Money Market Mutual Funds registered under the Investment Company Act of 1940 which: 1) are "no-load" (i.e., no commission fee shall be charged on purchases or sales of shares); 2) have a policy to maintain a constant daily net asset value per share (usually $1.00); 3) limit assets of the fund to those securities authorized in this Policy; 4) have a maximum stated maturity and weighted average maturity in accordance with Federal Securities Regulation 2A-7; and 5) are rated either AAAm by Standard & Poor's or AAA by Moody's or Fitch Investors Service. It is the intent of the County that the foregoing list of authorized securities be strictly interpreted. Any deviation from this list must be pre-approved by the Board of Weld County Commissioners in writing. VIII. INVESTMENT DIVERSIFICATION It is the intent of the County to diversify the investments within the portfolio to avoid incurring unreasonable risks inherent in over-investing in specific instruments, individual financial institutions or maturities. The asset allocation in the portfolio should, however, be flexible depending upon the outlook for the economy, the securities market, and the County's anticipated cash flow needs. A minimum of 50% of the investable assets of the County will be maintained in those securities listed in items 1, 2, 4, and 5 under Eligible Investments and Transactions. IX. INVESTMENT MATURITY AND LIQUIDITY Investments shall be limited to maturities not exceeding five years unless otherwise approved in writing by the Board of Weld County Commissioners for special circumstances (e.g. the reinvestment of bond proceeds). In addition, the weighted average maturity of the total portfolio shall at no time exceed 1 year. The County shall maintain at least 5% of its total investment portfolio in instruments maturing in 90 days or less. In the case of callable securities, the first call date shall be used as the maturity date for investment purposes if, due to the level of interest rates, the security is likely to be called prior to maturity. If due to the level of interest rates, the callable security is likely to go to maturity, then that date will be used as the final maturity. In all cases for accounting purposes, however, the final maturity date of the callable securities shall be used as the maturity of the security in order to disclose the maximum maturity liability in the County's financial reports. X. COMPETITIVE TRANSACTIONS Each investment transaction shall be competitively transacted with broker/dealers who have been authorized by the County. At least three broker/dealers shall be contacted for each transaction and their bid and offering prices shall be recorded. If the County is offered a security for which there is no other readily available competitive offering, quotations for comparable or alternative securities will be documented. When purchasing original issue instrumentality securities,no competitive offerings will be required as all dealers in the selling group offer those securities at the same original issue price. XI. SELECTION OF BROKER/DEALERS AND FINANCIAL INSTITUTIONS ACTING AS BROKER/DEALERS The Controller/Treasurer shall maintain a list of authorized broker/dealers and financial institutions which are approved for investment purposes, and it shall be the policy of the County to purchase securities only from those authorized institutions and firms. To be eligible, a firm/bank must meet at least one of the following criteria: 1. Be recognized as a Primary Dealer by the Market Reports Division of the Federal Reserve Bank of New York, 2. Report voluntarily to the Market Reports Division of the Federal Reserve Bank of New York, 3. Meet the securities dealer's capital adequacy requirements of the New York Federal Reserve Bank and provide written certification to the County that the requirements have been met on a continuous basis for the previous twelve-month period. (The capital requirements are found in the New York Federal Reserve Bank publication entitled, Capital Adequacy Guidelines for Governmental Securities Dealers), or 4. Be an FDIC member and meet criteria in Section XII, "Selection of Banks and Savings and Loans as Depositories and Providers of General Banking Services. Broker/dealers and other financial institutions will be selected by the Controller/Treasurer on the basis of their expertise in public cash management and their ability to provide service to the County's account. Each broker/dealer, bank or savings and loan that has been authorized by the Controller/Treasurer shall be required to submit and annually update a County approved Broker/Dealer Information Request Form which includes the firm's most recent financial statements. The Treasurer/Controller shall maintain a file of the most recent Broker/Dealer Information Forms submitted by each firm approved for investment purposes. Broker/Dealers shall also attest in writing that they have received a copy of this policy. A list of approved Broker/Dealers is included in Annex IV to this policy. XII. SELECTION OF BANKS AND SAVINGS AND LOANS (DESIGNATION UNDER CRS 11-47-101) AS DEPOSITORIES AND PROVIDERS OF GENERAL BANKING SERVICES The Controller/Treasurer shall maintain a list of authorized banks, savings and loans, and public asset pools as depositories for Weld County funds (Annex V) which are approved by the Board of Weld County Commissioners by resolution per CRS 30-10-708 to provide depository and other banking services for the County. To be eligible for authorization, a bank or savings and loan must be a member of the FDIC and must meet the minimum credit criteria (described below) of credit analysis provided by commercially available bank rating services. Banks or savings and loans failing to meet the minimum criteria, or in the judgment of the Controller/Treasurer no longer offering adequate safety to the County, will be removed from the list. The list will be updated annually to insure current compliance. Depositories shall be selected through the County's procurement process, which shall include a formal request for proposal issued every five years. The County shall utilize the commercially available bank rating services of PMA Financial Network, Inc. or Sheshunoff Public Finance Bank Rating Service to perform a credit analysis on banks and savings and loans seeking authorization. Data obtained from the bank rating services will include factors covering overall rating, liquidity policy, credit risk policy, interest rate policy, profitability, and capital policy. To be eligible for designation to provide banking services, a financial institution shall meet the following criteria: 1. Have a Sheshunoff Public Finance Peer Group Rating of 30 or better on a scale of zero to one hundred with one hundred being the highest quality for the most recent reporting quarter before the time of selection; or 2. Have a PMA Financial Network, Inc. overall rating of three or better on a scale of one to five with one being the highest quality for the most recent reporting quarter before the time of selection. 3. Qualify as a depository of public funds in Colorado as defined in CR3 24-75-603 and CRS 11-47-118, and provide the County certification of such qualification. The Controller/Treasurer shall obtain a copy of the Federal Financial Institutions Examination Council (FFIEC) Consolidated reports of Condition and Income (Call Report) on each approved financial institution after the end of the June and December calendar quarters. The Controller/Treasurer shall also maintain a file of the most recent credit rating analysis reports performed for each approved financial institution by one of the rating firms listed above. A list of approved banks is included in Annex V. A credit analysis will be performed at least semi-annually on all approved banks and savings and loans. XIII. SAFEKEEPING AND CUSTODY The Treasurer/Controller shall approve one or more financial institutions to provide safekeeping and custodial services for the County. A County approved Safekeeping Agreement shall be executed with each custodian bank prior to utilizing that bank's safekeeping services. To be eligible for designation as the County's safekeeping and custodian bank, a financial institution shall meet the following criteria: 1. Have a Sheshunoff Public Finance Peer Group Rating of 20 or better on a scale of zero to one hundred with one hundred being the highest quality for the most recent reporting quarter before the time of selection; or 2. Have a PMA Financial Network, Inc. overall mating of three minus or better on a scale of one to five with one being the highest quality for the most recent reporting quarter before the time of selection. Custodian banks will be selected on the basis of their ability to provide service to the County's account and the competitive pricing of their safekeeping related services. Custodian banks shall be selected through the County's procurement process,which shall include a formal request for proposal issued every five years. The Controller/Treasurer shall obtain a copy of the FFIEC Consolidated Reports of Condition and Income (Call Report) to the County on each approved safekeeping financial institution after the end of the June and December calendar quarters. The Controller/Treasurer shall also maintain a file of the credit rating analysis reports performed for each approved financial institution. A list of approved banks is included in Annex V. It is the intent of the County that all purchased securities be perfected in the name of the County. Sufficient evidence to title shall be consistent with modern investment, banking and commercial practices. All investment securities, except non-negotiable certificates of deposit and money market funds, purchased by the County will be delivered by either book entry or physical delivery and will be held in third-party safekeeping by a County approved custodian bank, its correspondent New York bank or the Depository Trust Corporation (DTC). The County's perfected ownership of all book entry securities shall be evidenced by a safekeeping receipt on a related document issued to the County by the custodian bank that acts as the County's safekeeping agent. The safekeeping receipt shall state that the securities are held in the Federal Reserve system either in a Customer Account/1030 for the custodian bank which will name the County as"customer" or in a Trust Account/1050 with the trust department named as agent for the County. All non-book entry (physical delivery) securities shall be held by the custodian bank's correspondent bank in New York City and the custodian bank shall issue a safekeeping receipt or a related document to the County evidencing that the securities are held by the correspondent bank for the County. The County may utilize the services of the Depository Trust Corporation (DTC) as a depository for delivery of non-wireable securities. All custodies securities that are registered shall be registered in the name of the County or in the name of a nominee of the County or in the name of the custodian or its nominee or, if in a clearing corporation, in the name of the clearing corporation or its nominee. The County's custodian will be required to furnish the County with monthly reports of holdings of custody securities as well as an account analysis report of monthly securities activity. XIV. PERFORMANCE BENCHMARKS The County of Weld shall use as a goal a dynamic benchmark rate of return for the County's investment portfolio that corresponds to the yield for the current U.S. Treasury security that matches the weighted average maturity of the portfolio. However, it is intended that the benchmark yield should not be less than the monthly average yield of the Colorado Local Government Liquid Asset Trust (COLOTRUST) measured on an annualized basis. All fees involved with managing the portfolio should be included in the computation of the portfolio's rate of return. The Controller/Treasurer shall present to the Investment Advisory Committee of Weld County , at least semi-annually, a review of the portfolio's adherence to appropriate risk levels and a comparison between the portfolio's total return and the established investment objectives and goals. XV. REPORTING Accounting and reporting on the County's investment portfolio shall conform to Generally Accepted Accounting Principles (GAAP) and the Governmental Accounting Standards Board (GASB) recommended practices. On a monthly basis, an investment report shall be prepared and submitted to the Director of Finance, who will provide it to the County Commissioners in a timely manner, listing the investments held by the County, the current market valuation of the investments and performance results. The report shall include a summary of investment earnings during the period. A record shall be maintained by the County of all bids and offerings for security transactions in order to ensure that the County receives competitive pricing. Reports prepared by outside advisors shall be sent to the Treasure/Controller. XVII. POLICY REVISIONS This investment policy shall he reviewed annually by the Director of Finance and Controller/Treasurer and may be amended by the Investment Advisory Committee of Weld County as conditions warrant. The data contained in the annexes to this policy may be updated by the Controller/Treasurer as necessary, provided the changes in no way affect the substance or intent of this policy. Annex I Authorized Personnel The following persons are authorized to transact investment business and wire funds for investment purposes on behalf of the Weld County: Donald Warden, Director of Finance Claud Hanes, Comptroller/Treasurer Ken Sigley, Chief Deputy Treasurer Annex II Applicable Statutes The following Colorado Revised Statutes are applicable to the investment operations of the County of Weld: CRS 11-10.5-101, et seq., Public Deposit Protection Act; CRS11-47-101, et seq., Savings and Loan Association Public Deposit Protection Act; CRS 11-47-118, et seq., Public moneys to be deposited only in eligible public depositories; CRS 11-60-101, et seq., U.S. Agency Obligations; CRS 24-75-601, et. Seq., Funds-Legal Investments for Governmental Units; CRS 24-75-603, et seq., Depositories; CRS 24-75-701, et seq., Local Governments-Local Government Pooling. CRS 30-10-708, et. Seq. Deposit of Funds in Banks and Savings and Loan Associations Annex III Master Repurchase Agreement The attached Master Repurchase Agreement and Annex has been approved by the County of Weld. Wells Fargo Bank have an executed Master Repurchase Agreement on file with the County of Weld: Annex IV Approved Broker-Dealers The following broker/dealers have been approved by the County of Weld: Annex V Approved Designated Banks, Savings and Loans, and Public Asset Pools See the attached Board of Weld County Commissioners resolution dated February 19, 2003, for those banks, savings and loans, and public asset pools that have been approved as depositories for Weld County funds. Annex VI Approved Depositor and Custodian Banks The following depositories have been approved by the County of Weld. Wells Fargo Bank, N.A. GLOSSARY OF TERMS Bankers Acceptance A banker's acceptance (BA) can be defined as a time draft drawn on and accepted by a bank to pay a specified amount of money on a specified date. The draft is a primary and unconditional liability of the accepting bank. Bankers' acceptances typically are created for international trade transactions. Commercial Paper Commercial paper (CP) can be defined as a short-term unsecured promissory note issued for a specified dollar amount with a maturity that can be tailored to meet an investor's needs. Notes have maximum maturities of 270 days, with the majority of CP being issued in the 30-50 day range. Most CP is sold at a discount from face value although some can be interest bearing. Federal Farm Credit Bank (FFCB) The FFCB is a network of cooperatively owned lending institutions that provide credit services to farmers and farm-affiliated businesses. The Farm Credit Banks collectively issue consolidated system-wide discount notes, debentures and medium term notes. These securities do not carry direct U.S. government guarantees. Federal Home Loan Mortgage Corporation (FHLMC or Freddie Mac) FHLMC is a government-chartered corporation established in 1970 to help maintain the availability of mortgage credit for residential housing. FHLM buys qualified mortgage loans from the financial institutions that originate them, securitizes the loans, and distributes the securities through the dealer community. FHLMC also issues discount notes, debentures and medium term notes that finance the purchase of the mortgages. These securities do not carry direst U.S. government guarantees. Federal National Mortgage Association (FNMA or Fannie Mae) FNMA (Fannie Mae) is a congressionally chartered corporation, chartered in 1938. FNMA purchases conventional mortgages, pools them and sells them as mortgage backed securities to investors on the open market. FNMA sells debentures, discount notes and medium term notes to investors to finance their purchase of conventional mortgages. These securities do not carry direct U.S. government guarantees. Money Market Mutual Funds (MMMFs) MMMFs are an open-ended mutual fund, which invests only in money market investment instruments. MMMFs are sponsored by private companies and are regulated by and must be registered with the SEC. These funds fall under Investment Company Act of 1940 and they must comply with Rule 2a-7, which governs the credit quality, diversification practices, and maturities of portfolio securities. Repurchase Agreement (repo) A repurchase agreement (repo or RP) is a simultaneous transaction whereby an investor purchases securities (collateral) from a bank or a dealer for cash and the bank or dealer contractually agrees to repurchase the collateral security at the same price (plus interest) at a mutually agreed-upon future date. When the repurchase agreement is executed, the parties agree to a specified interest rate, or repo rate. Student Loan Marketing Association (Sallie Mae( Sallie Mae is a federally established corporation established in 1972 to provide financing for the federal Guaranteed Student Loan Program. Sallie Mae regularly enters the credit markets with short-term and non-guaranteed discount notes with maturities under one year and an extensive program of floating-rate notes with various maturities. These securities do not carry direct U.S. government guarantees. U.S. Treasury (Treasuries) Treasuries are marketable (negotiable) securities that are issued by the U.S. Treasury and carry the full faith and credit of the U S government. They are issued in three types - - bills, notes, and bonds. Treasury hills have maturities less than one year, do not have a coupon and are purchased at a discount to par value. Treasury notes and bonds have coupons that pay semi-annual interest and have original maturities of two years or greater. U.S. Treasury STRIPS (Separately Traded Registered Interest and Principal Securities) STRIPS are issued by the Treasury as zero-coupon securities and represent the principal or interest payments from selected Treasury notes and bonds. They carry the full faith and credit of the U.S. government. Hello