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HomeMy WebLinkAbout20230691.tiffRESOLUTION RE: APPROVE REVISIONS TO 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 Board has been presented with Revisions to the Investment Policy for the County of Weld, State of Colorado, by and through the Board of County Commissioners of Weld County, on behalf of the Treasurer's Office, with further terms and conditions being as stated in said revised investment policy, and WHEREAS, after review, the Board deems it advisable to approve said revised investment 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 Revised Investment Policy for the County of Weld, State of Colorado, by and through the Board of County Commissioners of Weld County, on behalf of the Treasurer's Office, be, and hereby is, approved. The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 13th day of March, A.D., 2023. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: dit4400 4•1‘044.. Weld County Clerk to the Board BY: APP my Attorney Date of signature: 03/I 6 /23 OS- Mik- -eman, Chair erry L. B ck, Pro-Tem Sco t K. Jam evin D. Ross Lori Saine ce:TR(QF) FI(RRfcPfs ) 03/17123 2023-0691 TR0031 Table of Contents I. INTRODUCTION 2 II. SCOPE 2 III. INVESTMENT OBJECTIVES 2 IV. DELEGATION OF AUTHORITY 4 V. PRUDENCE AND INDEMNIFICATION 4 VI. ETHICS AND CONFLICTS OF INTEREST 4 VII. INTERNAL CONTROLS 5 VIII. ELIGIBLE INVESTMENTS AND TRANSACTIONS 5 IX. PROHIBITED INVESTMENT VEHICLES AND PRACTICES 8 X. RISK MANAGEMENT AND DIVERSIFICATION 9 XI. INVESTMENT POOLS/MUTUAL FUNDS 10 XII. COMPETITIVE TRANSACTIONS 10 XIII. SELECTION OF BROKER/DEALERS 10 XIV. SELECTION OF BANKS AND SAVINGS AND LOANS 11 XV. SAFEKEEPING AND CUSTODY 11 XVI. PERFORMANCE BENCHMARKS 12 XVII. REPORTING 12 XVIII. POLICY REVISIONS 13 Exhibit I 13 Glossary of Investment Terms 14 2023-0691 o3/ Bo0 TV -o031 1 WELD COUNTY INVESTMENT POLICY 2023 I. INTRODUCTION The Board of County Commissioners of Weld County has appointed an oversight committee, known as the Investment Advisory Committee, comprised of the Treasurer, the Director of Finance and Administration, CFO, Controller, and the Chair and Chair Pro-tem of the Board of County Commissioners, to oversee compliance of the County's investments with this Investment Policy and to provide advice to the Board of County Commissioners and the Treasurer regarding investments and any necessary changes to this Investment Policy. 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 recommended for adoption by the Weld County Investment Advisory Committee on March 6, 2023. IL SCOPE The following investment policy addresses the methods, and procedures 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: 1. General fund, 2. Special Revenue funds, 3. Debt Service funds. 4. Capital Projects funds, 5. Enterprise fund, 6. Internal Service funds, 7. Trust and Agency funds - Expendable Trust funds & Agency funds, and 8. Any new fund created by the governing body, unless specifically exempted by the governing body 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: 2 a) Limiting investments to the safest types of securities; b) Pre -qualifying the financial institutions, broker/dealers, and advisors with which the County does business, and c) 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: a) 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 b) 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, can 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 bat extreme circumstances. 3. Yield: The County's portfolio shall earn a competitive market rate of return an 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. After safety and liquidity, Weld County staff, investment advisors and fund managers will only consider financial factors when seeking the highest rate of return. Weld County will not base investment decisions on Environmental, Social and Governance (ESG) factors. 3 IV. DELEGATION OF AUTHORITY Authority to manage the investment program is granted to the 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 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 Treasurer. The Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. The 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. Investment Advisors shall be registered with the Securities Exchange Commission under the Investment Advisors Act of 1940. Advisors shall be subject to the provisions of this Policy, and shall not, under any circumstances, take custody of any County funds or securities. 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" (CR5 15-1-304, Standard for Investments.) The Director of Finance, 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 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. V. 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." All participants in the investment process shall act as custodians of the public trust. Investment officials shall recognize that the investment portfolio is subject to public review and evaluation. Thus, employees and officials involved in the investment process shall refrain from personal business activity that could create a conflict of interest or the appearance of a conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. Employees and investment officials shall disclose to the Board of County Commissioners 4 any material interests in financial institutions with which they conduct business, and they shall further disclose any large personal financial/investment positions that could be related to the performance of the investment portfolio. Employees and officers shall refrain from undertaking any personal investment transactions with the same individual with whom business is conducted on behalf of the County. VI. INTERNAL CONTROLS The Treasurer is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the entity are protected from loss, theft or misuse. The internal control structure shall be designed to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognizes that (1) the cost of a control should not exceed the benefits likely to be derived; and (2) the valuation of costs and benefits requies estimates and judgments by management. Periodically, as deemed appropriate by the County and/or the Board of County Commissioners, an independent analysis by an external auditor shall be conducted to review internal controls, account activity and compliance with policies and procedures. 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 24-75-601, et seq. Funds -Legal Investments for Governmental Units; CRS 24-75-603, et seq. Depositories; and CRS 24-75-702, et seq. Local Governments -Local Government Pooling. Any revisions on extensions of these sections of the CRS will be assumed to be part of this policy immediately upon being enacted. The credit quality of any eligible investment will be evaluated using the following Nationally Recognized Statistical Rating Organizations (NRSROs): Standard & Poor's, Moody's or Fitch (or any of their successor agencies). This investment policy further defines the following types of securities and transactions as eligible for use by the County: L U.S. Treasury Obligations fully guaranteed by, or for which the full faith and credit of the United States Treasury is pledged for payment. A. Maturities shall not exceed five years from the date of trade settlement. B. There are no limits on the dollar amount or percentage that the County may invest in U.S. Treasuries. 2. Federal Agency and Instrumentality Securities issued by or fully guaranteed as to principal and interest by federal agencies or U.S. Government Sponsored Enterprises (GSEs). Subordinated securities are not permissible under this policy. A. Maturities shall not exceed five (5) years from the date of trade settlement. B. There are no limits on the dollar amount or percentage that the County may invest in federal Agency and GSE securities. No more than 35% of the total portfolio may be invested in any single Agency/GSE issuer. 5 3. 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. The Master Repurchase Agreement will be substantially in the form developed by the Securities Industry and Financial Markets Association (SIFMA). 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. No more than 50% of the portfolio may be invested in repurchase agreements and no more than 10% may be invested with a single counterparty. 4, Local Government Investment Pools authorized under CRS 24-75-701, 702 et seq., provided they A. are managed to a stable value ($1 per share); B. Are "no-load" (i.e., no commission or fees shall be charged on purchases or sales of shares) and charge no 12b1 fees; C. Limit assets of the fund to securities authorized by state statute; D. Have a maximum stated maturity and weighted average maturity in accordance with Rule 2a-7 of the Investment Company Act of 1940. E. Have a rating of AAAm by Standard and Poor's or Aaa by Moody's, or AAAmmf by Fitch Investors Service. F. A maximum of 100% of the portfolio may be invested in local government investment pools with a single pool constituting no more than 35% of the portfolio. 5. Certificates of Deposit or savings accounts in state or national banks or in state or federally chartered savings and loans that are state approved depositories per CRS 24-75-603, et seq. (as evidenced 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 or the Savings and Loan Association Public Deposit Protection Act. [Allow CD purchases up to the FDIC limit in US banks outside of Colorado.] A. Maturities shall not exceed five (5) years from the date of settlement. B. No more than 30% of the total portfolio may be invested in certificates of deposit. C. No more than 5% of the total portfolio may be invested in any one issuer. 6 Money Market Mutual Funds registered under the Investment Company Act of 1940, provided they: A. Have a constant daily net asset value per share of $1.00; B. Are "no load" (i.e.: no commission or fee shall be charged on purchases or sales of shares) and charge no 12b1 fees; C. Limit assets of the fund to securities authorized by state statute; D. Have a maximum stated maturity and weighted average maturity is accordance with Rule 2a-7 of the Investment Company Act of 1940; and E. Have a rating of AAAm by Standard and Poor's or Aaa by Moody's, or AAAmmf by Fitch Investors Service. F. A maximum of 100% of the portfolio may be invested in money market mutual funds with a single fund constituting no more than 35% of the portfolio. 7. Corporate or Bank Securities denominated in United States dollars. A. Bonds, notes, debentures and medium -term notes issued by a corporation or bank which is organized and operated within the United States, wlh remaining maturities not exceeding three years from the date of trade settlement. Such securities, at the time of purchase, must be rated at least AA - by Standard & Poor's, Aa3 by Moody's, or AA- by Fitch by at least two services that rate the issue. B. Commercial paper with maturities not exceeding 270 days from the date of trade settlement that is rated at least A-1 by Standard and Poor's, P-1 by Moody's, or F-1 by Fitch at the time of purchase by at least two services that rate the commercial paper. C. Eligible Banker's Acceptances with original maturities not exceeding 180 days from the date of trade settlement. Banker's Acceptances shall be rated at least A-1 by Standard and Poor's, P-1 by Moody's, or F-1 by Fitch at the time of purchase by at least two services that rate them. D. The term "Bank Security" includes Negotiable Certificates of Deposit issued by banks organized and chartered within the United States. These instruments are investment securities and not deposits as described in Section VIII, 5. Negotiable Certificates of Deposit must have a final maturity not exceeding three years from the date of trade settlement and must be issued by institutions which have short-term debt obligations rated at least A-1 by Standard and Poor's, P-1 by Moody's, or F-1 by Fitch at the time of purchase by at least two services that rate the issue. or long-term obligations rated at least AA- by Standard & Poor's, Aa3 by Moody's, or AA- by Fitch by at least two services that rate the issue. E. At no time shall the book value of investments in corporate and bask securities total more than 50% of the total book value of the County's portfolio with no greater than 5% exposure to any single issuer. F. No subordinated security may be purchased. 7 $ Municipal Securities of state or local governments with a maturity not exceeding five years from the date of trade settlement. A. General obligation and revenue obligation securities of this state or any political subdivision of this state must be rated at the time of purchase at least "A-" or its equivalent by at least two NRSROs. B. General obligation and revenue obligation securities of any other state or political subdivision of any other state must be rated at the time of purchase at least "AA-" or its equivalent by at least two NRSROs. C. No more than 30% of the total portfolio may be invested in municipal securities. D. No more than 5% of the total portfolio may be invested in the securities of any single issuer. 9. Supranationals, provided that: A. Issues are US dollar denominated senior unsecured unsubordinated obligations issued or unconditionally guaranteed by the World Bank. B. The securities are rated at the time of purchase at least "AA" or its equivalent by an NRSRO. C. No more than 30% of the total portfolio may be invested in these securities. D. No more than 10% of the portfolio may be invested in any single issuer. E. The maximum maturity does not exceed five (5) years. Eligible Investment Summary The following table summarizes the eligible investment requirements stated in the above section. Security Type Maximum Portfolio % Maximum Issuer % Maturity Restrictions Minimum Rating U.S. Treasuries 100% 100% 5 years N/A U.S. Agencies and Instrumentalities 100% 35% 5 years N/A Repurchase Agreements 50% 10% 180 Days A -1/A Local Government Investment Pools 100% 35% 2a-7 AAA Certificates of Deposits (CD) 30% 5% 5 years N/A Money Market Mutual Funds 100% 35% 2a-7 AAA Corporate or Bank Securities 50% 5% 3 Years AA - Commercial Paper 5% 270 Days A-1 Bankers' Acceptances 5% 180 Days A-1 Negotiable Certificates of Deposits 5% 5 Years A-1/AA- Municipal Bonds (Colorado/Other) 30% 5% 5 years A-/AA- Supranationals 20% 10% 5 Years AA Any deviation from this list must be pre -approved by the Board of Weld County Commissioners in writing. VIII. PROHIBITED INVESTMENT VEHICLES AND PRACTICES State law notwithstanding, any investments not specifically authorized pursuant to this approved Investment Policy are prohibited, including but not limited to: 1. Futures and options 2. Investment in inverse floaters, range notes, or mortgage derived interest -only strips 8 3. Investment in any security that could result in a zero -interest accrual if held to maturity 4. Trading securities for the sole purpose of speculating on the future direction of interest rates 5. Purchasing or selling securities on margin 6. The purchase of foreign currency denominated securities IX. RISK MANAGEMENT AND DIVERSIFICATION It is the intent of the County to diversify the investments in 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. Mitigating Credit Risk in the Portfolio Credit risk is the risk that a security or a portfolio will lose some or all of its value due to a real or perceived change in the ability of the issuer to repay its debt. The County will mitigate credit risk by adopting the following strategies: 1. The County may elect to sell a security prior to its maturity and record a capital gain or loss in order to improve the quality, liquidity or yield of the portfolio in response to market conditions or the County's risk preferences. 2. If securities owned by the County are downgraded by a nationally recognized statistical ratings organization (NRSRO) to a level below the quality required by this Investment Policy, it will be the County's policy to review the credit situation and make a determination as to whether to sell or retain such securities in the portfolio. A. If a security is downgraded, the Treasurer will use discretion in determining whether to sell or hold the security based on its current maturity, the economic outlook for the issuer, and other relevant factors. B. If a decision is made to retain a downgraded security in the portfolio, its presence in the portfolio will be monitored and reported to the Investment Advisory Committee. Mitigating Market Risk in the Portfolio Market risk is the risk that the portfolio value will fluctuate due to changes in the general level of interest rates. The County recognizes that, over time, longer -term portfolios have the potential to achieve higher returns. On the other hand, longer -term portfolios have higher volatility of return. The County will mitigate market risk by providing adequate liquidity for short-term cash needs, and by making longer -term investments only with funds that are not needed for current cash flow purposes. The County, therefore, adopts -the following strategies to control and mitigate its exposure to market risk: 1. Investments shall be limited to maturities not exceeding five (5) years unless otherwise approved in writing by the Board of Weld County Commissioners for special circumstances (e.g., the reinvestment of bond proceeds). 2_ The County shall maintain at least 10% of its total investment portfolio in instruments maturing in 90 days or less. 3. The maximum percent of callable securities (does not include "make whole call" securities as defined in the Glossary) in the portfolio will be 20%. 4. The duration of the portfolio will at all times be approximately equal to the duration (typically, plus or minus 20%) of a Market Benchmark, an index selected by the County based on the County's investment objectives, constraints and risk tolerances. 9 X. INVESTMENT POOLS/MUTUAL FUNDS The County shall conduct a thorough investigation of any local government investment pool or money market mutual fund prior to making an investment, and on a continual basis thereafter. There shall be a questionnaire developed which will answer the following general questions: 1. A description of eligible investment securities, and a written statement of investment policy and objectives. 2. A description of interest calculations and how it is distributed, and how gains and losses are treated. 3. A description of how the securities are safeguarded (including the settlement processes), and how often the securities are priced, and the program audited. 4. A description of who may invest in the program, how often, what size deposit and withdrawal are allowed. 5. A schedule for receiving statements and portfolio listings. 6. Are reserves, retained earnings, etc. utilized by the pool/fund? 7. A fee schedule, and when and how is it assessed. 8. Is the pool/fund eligible for bond proceeds and/or will it accept such proceeds? XI. COMPETITIVE TRANSACTIONS Each investment transaction shall be competitively transacted with broker/dealers who have been authorized by the County. Securities shall be purchased at the then best offering price based on the market conditions at that time. XII. SELECTION OF BROKER/DEALERS AND FINANCIAL INSTITUTIONS ACTING AS BROKER/ DEALERS AND FINANCIAL INSTITUTIONS PROVIDING INVESTMENT SERVICES. The 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/investment bank, bank, or savings and loan institution must meet at least one of the following criteria: 1. Report voluntarily to the Federal Reserve Bank of New York; 2. Be recognized as a Primary Dealer by the Federal Reserve Bank of New York or have a primary dealer within its holding company structure; or 3. .Qualify under Securities and Exchange Commission (SEC) Rule 15c3-1 (Uniform Net Capital Rule). Broker/dealers and other financial institutions will be selected by the Treasurer on the basis of their expertise in public cash management and their ability to provide service to the County's account. Each investment firm authorized by the Treasurer shall be a FINRA reporting broker/dealer. Broker/Dealers must supply the Treasurer with audited financials and shall also attest in writing that they have received a copy of this policy. Selection of broker/dealers used by an external investment adviser retained by the County will be at the sole discretion of the adviser. Where possible, transactions with broker/dealers shall be selected on a competitive basis and their bid or offering prices shall be recorded. If there is no other readily available competitive offering, best efforts will be made to document quotations for comparable or alternative securities. 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. 10 The County may purchase commercial paper from direct issuers even though they are not on the approved broker/dealer list as long as the paper meets the criteria outlined in item 7 of the section "VIII' titled "Eligible Investments and Transactions." A list of approved Broker/Dealers, Banks, and Savings & Loan institutions is included in various "Resolutions" performed by the Board of County Commissioners of Weld County, Colorado. XIII. SELECTION OF BANKS AND SAVINGS AND LOANS (DESIGNATION UNDER CRS 11-10.5-106 (Banks) and CRS.11-47-105 (Savings & Loan)) AS DEPOSITORIES AND PROVIDERS OF GENERAL BANKING SERVICES AND ASSET POOLS AS DEPOSITORIES The Treasurer shall maintain a list of authorized banks, savings and loans, and public asset pools as depositories for Weld County funds 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 is required to be designated an eligible public depository by the state banking board and a savings and loan must be designated an eligible public depository by the state commissioner of Banking. Additionally, banks or savings and loans, in the judgment of the Treasurer, who no longer offer adequate safety or service to the County, will be removed from the approved list. The list will be updated annually if any changes are requested to insure compliance. Depositories shall be selected based on ratings and competitive rates of return. XIV. SAFEKEEPING AND CUSTODY 1. The Treasurer 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 have a Bauer rating of 3 stars or better out of possible 5 -star rating. Custodian banks will be selected on the basis of their safety and ability to provide service to the County's account with 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 as needed. Custodial banks should be in the highest rating categories. Delivery -versus -Payment (DVP). All investment transactions shall be conducted on a delivery -versus -payment basis. SAFEKEEPING All purchased securities will be perfected in the name of the County. Sufficient evidence to title shall be consistent with modem investment, banking and commercial practices. All investment securities, except non-negotiable certificates of deposit, local government investment pools, and money market funds, purchased by the County will be held by a PDPA eligible Colorado State bank or 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). All non -book entry (physical delivery) securities shall be held by Weld County's designated custodian bank for the benefit of 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. XV. PERFORMANCE BENCHMARKS The investment portfolio shall be designed to attain a market -average rate of return throughout budgetary and economic cycles, taking into account the County's risk constraints, the cash flow characteristics of the portfolio, and state and local laws, ordinances or resolutions that restrict investments. The Treasurer shall select an appropriate, readily available index to use as a market benchmark. The Treasurer shall monitor and evaluate the portfolio's performance relative to the market benchmark. The Treasurer shall present to the Investment Advisory Committee of Weld County a review of the current investments and the portfolio's adherence to appropriate risk levels and a comparison between the portfolio's total return and the established investment objectives and goals. XVI. REPORTING Accounting and reporting on the County's investment portfolio shall conform to Generally Accepted Accounting Principles (GAAP) and the Governmental Accounting Standards. QUARTERLY REPORTS The CFO or Treasurer will submit a quarterly investment report to the Investment Advisory Committee which provides full disclosure of the County's investment activities within 30 days after the end of the quarter. These reports will disclose, at a minimum, the following information about County's portfolio: 1. An asset listing showing par value, cost and independent third -party fair market value of each security as of the date of the report, the source of the valuation, type of investment, issuer, maturity date, interest rate and interest rate. 2. Transactions for the period. 3. A description of the funds, investments and programs managed by contracted parties (i.e. local government investment pools and outside money managers) 4. A one -page summary report that shows: a.) Average maturity of the portfolio and modified duration of the portfolio; b.) Maturity distribution of the portfolio; c.) Percentage of the portfolio represented by each investment category; d.) Average portfolio credit quality; and, e.) Time -weighted total rate of return for the portfolio for the prior one month, three months, twelve months and since inception compared to the County's market benchmark returns for the same periods; 12 5. A statement of compliance with the Investment Policy, including a schedule of any transactions or holdings which do not comply with this Policy, including a justification for their presenco in the portfolio and a timetable for resolution. ANNUAL REPORTS A comprehensive annual report will be presented to the Board of County Commiss_oners. This report will include comparisons of the County's return to the market benchmark return, suggest policies and improvements that might enhance the investment program, and will include an investment plan for the coming year. XVIII. POLICY REVISIONS This investment policy shall he reviewed at least annually by the Director of Finance and 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 Treasurer as necessary, provided the changes in no way affect the substance or irtent of this policy. Exhibit I Authorized Personnel The following persons are authorized to transact investment business and wire funds for investment purposes on behalf of the Weld County: Treasurer Assistant Treasurer INVESTMENT COMMITTEE 13 Glossary of Investment Terms AGENCIES. Shorthand market terminology for any obligation issued by a government -sponsored entity (GSE), or a federally related institution. Most obligations of GSEs are not guaranteed by the full faith and credit of the US government. Examples are: FFCB. The Federal Farm Credit Bank System provides credit and liquidity in the agricultural industry. FFCB issues discount notes and bonds. FHLB. The Federal Home Loan Bank provides credit and liquidity in the housing market. FHLB issues discount notes and bonds FHLMC. Like FHLB, the Federal Home Loan Mortgage Corporation provides credit and liquidity in the housing market. FHLMC, also called "FreddieMac" issues discount notes, bonds and mortgage pass - through securities. FNMA. Like FHLB and FreddieMac, the Federal National Mortgage Association was established to provide credit and liquidity in the housing market. FNMA, also known as "FannieMae," issues discount notes, bonds and mortgage pass -through securities. GNMA. The Government National Mortgage Association, known as "GinnieMae," issues mortgage pass - through securities, which are guaranteed by the full faith and credit of the US Government. PEFCO. The Private Export Funding Corporation assists exporters. Obligations of PEFCO are not guaranteed by the full faith and credit of the US government. TVA. The Tennessee Valley Authority provides flood control and power and promotes development in portions of the Tennessee, Ohio, and Mississippi River valleys. TVA currently issues discount notes and bonds. ASKED. The price at which a seller offers to sell a security. ASSET BACKED SECURITIES. Securities supported by pools of installment loans or leases or by pools of revolving lines of credit. AVERAGE LIFE. In mortgage -related investments, including CMOs, the average time to expected receipt of principal payments, weighted by the amount of principal expected. BANKER'S ACCEPTANCE. A money market instrument created to facilitate international trade transactions. It is highly liquid and safe because the risk of the trade transaction is transferred to the bank which "accepts" the obligation to pay the investor. BENCHMARK. A comparison security or portfolio. A performance benchmark is a partial market index, which reflects the mix of securities allowed under a specific investment policy. BID. The price at which a buyer offers to buy a security. BROKER. A broker brings buyers and sellers together for a transaction for which the broker receives a commission. A broker does not sell securities from his own position. CALLABLE. A callable security gives the issuer the option to call it from the investor prior to its maturity. The main cause of a call is a decline in interest rates. If interest rates decline since an issuer issues securities, it will likely call its current securities and reissue them at a lower rate of interest. Callable securities have reinvestment risk as the investor may receive its principal back when interest rates are lower than when the investment was initially made. CERTIFICATE OF DEPOSIT (CD). A time deposit with a specific maturity evidenced by a certificate. Large denomination CDs may be marketable. CERTIFICATE OF DEPOSIT ACCOUNT REGISTRY SYSTEM (CDARS). A private placement service that allows local agencies to purchase more than $250,000 in CDs from a single financial institution (must be a participating institution of CDARS) while still maintaining FDIC insurance coverage. CDARS is currently the only entity providing this service. CDARS facilitates the trading of deposits between the institution and other participating institutions in amounts that are less than $250,000 each, so that FDIC coverage is maintained. COLLATERAL. Securities or cash pledged by a borrower to secure repayment of a loan or repurchase agreement. Also, securities pledged by a financial institution to secure deposits of public monies. COLLATERALIZED MORTGAGE OBLIGATIONS (CMO). Classes of bonds that redistribute the cash flows of mortgage securities (and whole loans) to create securities that have different levels of prepayment risk, as compared to the underlying mortgage securities. COMMERCIAL PAPER. The short-term unsecured debt of corporations. COST YIELD. The annual income from an investment divided by the purchase cost. Because it does not give effect to premiums and discounts which may have been included in the purchase cost, it is an incomplete measure of return. COUPON. The rate of return at which interest is paid on a bond. 14 CREDIT RISK. The risk that principal and/or interest on an investment will not be paid in a timely manner due to changes in the condition of the issuer. CURRENT YIELD. The annual income from an investment divided by the current market value. Since the mathematical calculation relies on the current market value rather than the investor's cost, current yield is unrelated to the actual return the investor will earn if the security is held to maturity. DEALER. A dealer acts as a principal in security transactions, selling securities from and buying securities for his own position. DEBENTURE. A bond secured only by the general credit of the issuer. DELIVERY VS. PAYMENT (DVP). A securities industry procedure whereby payment for a secusty must be made at the time the security is delivered to the purchaser's agent. DERIVATIVE. Any security that has principal and/or interest payments which are subject to uncertainty (but not for reasons of default or credit risk) as to timing and/or amount, or any security which represents a component of another security which has been separated from other components ("Stripped" coupons and principal). A derivative is also defined as a financial instrument the value of which is totally or partially derived from the value of another instrument, interest rate, or index. DISCOUNT. The difference between the par value of a bond and the cost of the bond, when the cost is below par. Some short-term securities, such as T -bills and banker's acceptances, are known as discount securities. They sell at a discount from par and return the par value to the investor at maturity without additional interest. Other securities, which have fixed coupons, trade at a discount when the coupon rate is lower than the current market rate for securities of that maturity and/or quality. DIVERSIFICATION. Dividing investment funds among a variety of investments to avoid excessive exposure to any one source of risk. DURATION. The weighted average time to maturity of a bond where the weights are the present values of the future cash flows. Duration measures the price sensitivity of a bond to changes in interest rates. (See modified duration). FEDERAL FUNDS RATE. The rate of interest charged by banks for short-term loans to other banks. The Federal Reserve Bank through open -market operations establishes it. FEDERAL OPEN MARKET COMMITTEE. A committee of the Federal Reserve Board that establishes monetary policy and executes it through temporary and permanent changes to the supply of bank reserves. LEVERAGE. Borrowing funds in order to invest in securities that have the potential to pay earniigs at a rate higher than the cost of borrowing. LIQUIDITY. The speed and ease with which an asset can be converted to cash. LOCAL GOVERNMENT INVESTMENT POOL. An investment by local governments in which their money is pooled as a method for managing local funds. MAKE WHOLE CALL. A type of call provision on a bond that allows the issuer to pay off the remaining debt early. Unlike a call option, with a make whole call provision, the issuer makes a lump sum payment that equals the net present value (NPV) of future coupon payments that will not be paid because of the call. With this type of call, an investor is compensated, or "made whole." MARGIN. The difference between the market value of a security and the loan a broker makes using that security as collateral. MARKET RISK. The risk that the value of securities will fluctuate with changes in overall market conditions or interest rates. MARKET VALUE. The price at which a security can be traded. MARKING TO MARKET. The process of posting current market values for securities in a portfolio. MATURITY. The final date upon which the principal of a security becomes due and payable. MEDIUM TERM NOTES. Unsecured, investment -grade senior debt securities of major corporations which are sold in relatively small amounts on either a continuous or an intermittent basis. MTNs are highly flexible debt instruments that can be structured to respond to market opportunities or to investor preferences. MODIFIED DURATION. The percent change in price for a 100 -basis point change in yields. Modcied duration is the best single measure of a portfolio's or security's exposure to market risk. MONEY MARKET. The market in which short-term debt instruments (T -bills, discount notes, commercial paper, and banker's acceptances) are issued and traded. MORTGAGE PASS -THROUGH SECURITIES. A securitized participation in the interest and principal cash flows from a specified pool of mortgages. Principal and interest payments made on the mortgages are passed through to the holder of the security. MUNICIPAL SECURITIES. Securities issued by state and local agencies to finance capital and operating expenses. 15 MUTUAL FUND. An entity which pools the funds of investors and invests those funds in a set of securities which is specifically defined in the fund's prospectus. Mutual funds can be invested in various types of domestic and/or international stocks, bonds, and money market instruments, as set forth in the individual fund's prospectus. For most large, institutional investors, the costs associated with investing in mutual funds are higher than the investor can obtain through an individually managed portfolio. NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION (NRSRO). A credit rating agency that the Securities and Exchange Commission in the United States uses for regulatory purposes. Credit rating agencies provide assessments of an investment's risk. The issuers of investments, especially debt securities, pay credit rating agencies to provide them with ratings. The three most prominent NRSROs are Fitch, S&P, and Moody's. NEGOTIABLE CD. A short-term debt instrument that pays interest and is issued by a bank, savings or federal association, state or federal credit union, or state -licensed branch of a foreign bank. Negotiable CDs are traded in a secondary market and are payable upon order to the bearer or initial depositor (investor). PREMIUM. The difference between the par value of a bond and the cost of the bond, when the cost is above par. PREPAYMENT SPEED. A measure of how quickly principal is repaid to investors in mortgage securities. PREPAYMENT WINDOW. The time period over which principal repayments will be received on mortgage securities at a specified prepayment speed. PRIMARY DEALER. A financial institution (1) that is a trading counterparty with the Federal Reserve in its execution of market operations to carry out U.S. monetary policy, and (2) that participates for statistical reporting purposes in compiling data on activity in the U.S. Government securities market. PRUDENT PERSON (PRUDENT INVESTOR) RULE. An investment standard outlining the fiduciary responsibilities of public funds investors relating to investment practices. REALIZED YIELD. The change in value of the portfolio due to interest received and interest earned and realized gains and losses. It does not give effect to changes in market value on securities, which have not been sold from the portfolio. REGIONAL DEALER. A financial intermediary that buys and sells securities for the benefit of its customers without maintaining substantial inventories of securities and that is not a primary dealer. REPURCHASE AGREEMENT. Short-term purchases of securities with a simultaneous agreement to sell the securities back at a higher price. From the seller's point of view, the same transaction is a reverse repurchase agreement. SAFEKEEPING. A service to bank customers whereby securities are held by the bank in the customer's name. STRUCTURED NOTE. A complex, fixed income instrument, which pays interest, based on a formula tied to other interest rates, commodities or indices. Examples include inverse floating rate notes which have coupons that increase when other interest rates are falling, and which fall when other interest rates are rising, and "dual index floaters," which pay interest based on the relationship between two other interest rates - for example, the yield on the ten- year Treasury note minus the Libor rate. Issuers of such notes lock in a reduced cost of borrowing by purchasing interest rate swap agreements. SUPRANATIONAL. A Supranational is a multi -national organization whereby member states transcend national boundaries or interests to share in the decision making to promote economic development in the member countries. TOTAL RATE OF RETURN. A measure of a portfolio's performance over time. It is the internal rate of return, which equates the beginning value of the portfolio with the ending value; it includes interest earnings, realized and unrealized gains, and losses in the portfolio. U.S. TREASURY OBLIGATIONS. Securities issued by the U.S. Treasury and backed by the full faith and credit of the United States. Treasuries are considered to have no credit risk and are the benchmark for interest rates on all other securities in the US and overseas. The Treasury issues both discounted securities and fixed coupon notes and bonds. TREASURY BILLS. All securities issued with initial maturities of one year or less are issued as discounted instruments and are called Treasury bills. The Treasury currently issues three- and six-month T -bills at regular weekly auctions. It also issues "cash management" bills as needed to smooth out cash flows. TREASURY NOTES. All securities issued with initial maturities of two to ten years are called Treasury notes and pay interest semi-annually. TREASURY BONDS. All securities issued with initial maturities greater than ten years are called Treasury bonds. Like Treasury notes, they pay interest semi-annually. VOLATILITY. The rate at which security prices change with changes in general economic conditions or the general level of interest rates. YIELD TO MATURITY. The annualized internal rate of return on an investment which equates the expected cash flows from the investment to its cost. 16 Table of Contents I. INTRODUCTION 2 II. SCOPE 2 III. INVESTMENT OBJECTIVES 3 IV. DELEGATION OF AUTHORITY 4 V. PRUDENCE AND INDEMNIFICATION 5 VI. ETHICS AND CONFLICTS OF INTEREST 5 VII. INTERNAL CONTROLS 5 VIII. ELIGIBLE INVESTMENTS AND TRANSACTIONS 6R IX. PROHIBITED INVESTMENT VEHICLES AND PRACTICES 9 X. RISK MANAGEMENT AND DIVERSIFICATION 9 XI. INVESTMENT POOLS/MUTUAL FUNDS 10 XII. COMPETITIVE TRANSACTIONS 1138 XIII. SELECTION OF BROKER/DEALERS 113-0 XIV. SELECTION OF BANKS AND SAVINGS AND LOANS 11 XV. SAFEKEEPING AND CUSTODY 1234 XVI. PERFORMANCE BENCHMARKS 1332 XVII. REPORTING 1312 POLICY REVISIONS 1433 Exhibit I 141-3 Glossary of Investment Terms 1534 WELD COUNTY INVESTMENT POLICY 2023 I. INTRODUCTION The Board of County Commissioners of Weld County has appointed an oversight committee, known as the Investment Advisory Committee, comprised of the Treasurer, the Director of Finance and Administration, CFO, Controller, and the Chair and Chair Pro-tem of the Board of County Commissioners, to oversee compliance of the County's investments with this Investment Policy and to provide advice to the Board of County Commissioners and the Treasurer regarding investments and any necessary changes to this Investment Policy. 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 recommended for adoption by the Weld County Investment Advisory Committee on March 6, 2023. II. SCOPE The following investment policy addresses the methods, and procedures 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: 1. General fund, 2. Special Revenue funds, 3. Debt Service funds. 4. Capital Projects funds, 5. Enterprise fund, 6. Internal Service funds, 7. Trust and Agency funds - Expendable Trust funds & Agency funds, and 8. Any new fund created by the governing body, unless specifically exempted by the governing body 2021-3112 2 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: a) Limiting investments to the safest types of securities; b) Pre -qualifying the financial institutions, broker/dealers, and adh isors with which the County does business, and c) 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: a) 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 b) 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, can be minimized. 3 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. After safety and liquidity, Weld County staff, investment advisors and fund managers will only consider financial factors when seeking the highest rate of return. Weld County will not base investment decisions on Environmental, Social and Governance (ESG) factors. IV. DELEGATION OF AUTHORITY Authority to manage the investment program is granted to the 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 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 Treasurer. The Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. The 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. Investment Advisors shall be registered with the Securities Exchange Commission under the Investment Advisors Act of 1940. Advisors shall be subject to the provisions of this Policy, and shall not, under any circumstances, take custody of any County funds or securities. 4 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" (CR5 15-1-304, Standard for Investments.) The Director of Finance, 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 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." All participants in the investment process shall act as custodians of the public trust. Investment officials shall recognize that the investment portfolio is subject to public review and evaluation. Thus, employees and officials involved in the investment process shall refrain from personal business activity that could create a conflict of interest or the appearance of a conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. Employees and investment officials shall disclose to the Board of County Commissioners any material interests in financial institutions with which they conduct business, and they shall further disclose any large personal financial/investment positions that could be related to the performance of the investment portfolio. Employees and officers shall refrain from undertaking any personal investment transactions with the same individual with whom business is conducted on behalf of the County. VII. INTERNAL CONTROLS The Treasurer is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the entity are protected from loss, theft or misuse. The internal control structure shall be designed to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognizes that (1) the cost of a control should not exceed the benefits likely to be derived; and (2) the valuation of costs and benefits requires estimates and judgments by management. Periodically, as deemed appropriate by the County and/or the Board of County Commissioners, an independent analysis by an external auditor shall be conducted to review internal controls, account activity and compliance with policies and procedures. 5 VIII. 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 24-75-601, et seq. Funds -Legal Investments for Governmental Units; CRS 24-75-603, et seq. Depositories; and CRS 24-75-702, et seq. Local Governments -Local Government Pooling. Any revisions on extensions of these sections of the CRS will be assumed to be part of this policy immediately upon being enacted. The credit quality of any eligible investment will be evaluated using the following Nationally Recognized Statistical Rating Organizations (NRSROs): Standard & Poor's, Moody's or Fitch (or any of their successor agencies). This investment policy further defines the following types of securities and transactions as eligible for use by the County: 1. U.S. Treasury Obligations fully guaranteed by, or for which the full faith and credit of the United States Treasury is pledged for payment. A. Maturities shall not exceed five years from the date of trade settlement. B. There are no limits on the dollar amount or percentage that the County may invest in U.S. Treasuries. 2. Federal Agency and Instrumentality Securities issued by or fully guaranteed as to principal and interest by federal agencies or U.S. Government Sponsored Enterprises (GSEs). Subordinated securities are not permissible under this policy. A. Maturities shall not exceed five (5) years from the date of trade settlement. B. There are no limits on the dollar amount or percentage that the County may invest in federal Agency and GSE securities. No more than 35% of the total portfolio may be invested in any single Agency/GSE issuer. 3 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 6 Reserve Bank of New York. The Master Repurchase Agreement will be substantially in the form developed by the Securities Industry and Financial Markets Association (SIFMA). 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. No more than 50% of the portfolio may be invested in repurchase agreements and no more than 10% may be invested with a single counterparty. Local Government Investment Pools authorized under CRS 24-75-701, 702 et seq., provided they A. are managed to a stable value ($1 per share); B. Are "no-load" (i.e., no commission or fees shall be charged on purchases or sales of shares) and charge no 12b1 fees; C. Limit assets of the fund to securities authorized by state statute; D. Have a maximum stated maturity and weighted average maturity in accordance with Rule 2a-7 of the Investment Company Act of 1940. E. Have a rating of AAAm by Standard and Poor's or Aaa by Moody's, or AAAmmf by Fitch Investors Service. F. A maximum of 100% of the portfolio may be invested in local government investment pools with a single pool constituting no more than 35% of the portfolio. 5. Certificates of Deposit or savings accounts in state or national banks or in state or federally chartered savings and loans that are state approved depositories pir CRS 24-75-603, et seq. (as evidenced 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 or the Savings and Loan Association Public Deposit Protection Act. [Allow CD purchases up to the FDIC limit in US banks outside of Colorado.] A. Maturities shall not exceed five (5) years from the date of settlemen-. B. No more than 30% of the total portfolio may be invested in certificates of deposit. C. No more than 5% of the total portfolio may be invested in any one issuer. 6. Money Market Mutual Funds registered under the Investment Company Act of 1940, provided they: A. Have a constant daily net asset value per share of $1.00; B. Are "no load" (i.e.: no commission or fee shall be charged on purchases or sales of shares) and charge no 12b1 fees; C. Limit assets of the fund to securities authorized by state statute; D. Have a maximum stated maturity and weighted average maturity in accordance with Rule 2a-7 of the Investment Company Act of 1940; and E. Have a rating of AAAm by Standard and Poor's or Aaa by Moody's, or AAAmmf by Fitch Investors Service. 7 F. A maximum of 100% of the portfolio may be invested in money market mutual funds with a single fund constituting no more than 35% of the portfolio. 7. Corporate or Bank Securities denominated in United States dollars. A. Bonds, notes, debentures and medium -term notes issued by a corporation or bank which is organized and operated within the United States, with remaining maturities not exceeding three years from the date of trade settlement. Such securities, at the time of purchase, must be rated at least AA - by Standard & Poor's, Aa3 by Moody's, or AA- by Fitch by at least two services that rate the issue. B. Commercial paper with maturities not exceeding 270 days from the date of trade settlement that is rated at least A-1 by Standard and Poor's, P-1 by Moody's, or F-1 by Fitch at the time of purchase by at least two services that rate the commercial paper. C. Eligible Banker's Acceptances with original maturities not exceeding 180 days from the date of trade settlement. Banker's Acceptances shall be rated at least A-1 by Standard and Poor's, P-1 by Moody's, or F-1 by Fitch at the time of purchase by at least two services that rate them. D. The term "Bank Security" includes Negotiable Certificates of Deposit issued by banks organized and chartered within the United States. These instruments are investment securities and not deposits as described in Section VIII, 5. Negotiable Certificates of Deposit must have a final maturity not exceeding three years from the date of trade settlement and must be issued by institutions which have short-term debt obligations rated at least A-1 by Standard and Poor's, P-1 by Moody's, or F-1 by Fitch at the time of purchase by at least two services that rate the issue. or long-term obligations rated at least AA- by Standard & Poor's, Aa3 by Moody's, or AA- by Fitch by at least two services that rate the issue. E. At no time shall the book value of investments in corporate and bank securities total more than 50% of the total book value of the County's portfolio with no greater than 5% exposure to any single issuer. F. No subordinated security may be purchased. 8. Municipal Securities of state or local governments with a maturity not exceeding five years from the date of trade settlement. A. General obligation and revenue obligation securities of this state or any political subdivision of this state must be rated at the time of purchase at least "A-" or its equivalent by at least two NRSROs. B. General obligation and revenue obligation securities of any other state or political subdivision of any other state must be rated at the time of purchase at least "AA-" or its equivalent by at least two NRSROs. C. No more than 30% of the total portfolio may be invested in municipal securities. D. No more than 5% of the total portfolio may be invested in the securities of any single issuer. 9. Supranationals, provided that: A. Issues are US dollar denominated senior unsecured unsubordinated 8 obligations issued or unconditionally guaranteed by the World Bank. B. The securities are rated at the time of purchase at least "AA" or its equivalent by an NRSRO. C. No more than 30% of the total portfolio may be invested in these securities. D. No more than 10% of the portfolio may be invested in any single issuer. E. The maximum maturity does not exceed five (5) years. Eligible Investment Summary The following table summarizes the eligible investment requirements stated in the ahave section. Security Type Maximum Portfolio % Maximum Issuer % Restrictions Maturity Minimum Rating U.S. Treasuries 100% 100% 5 years N/A U.S. Agencies and Instrumentalities 100% 35% 5 years N/A Repurchase Agreements 50% 10% 180 Days A -1/A Local Government Investment Pools 100% 35% 2a-7 AAA Certificates of Deposits (CD) 30% 5% 5 years N/A Money Market Mutual Funds 100% 35% 2a-7 AAA Corporate or Bank Securities 50% 5% 3 Years AA - Commercial Paper 5% 270 Days A-1 Bankers' Acceptances 5% 180 Days A-1 Negotiable Certificates of Deposits 5% 5 Years A-1/AA- Municipal Bonds (Colorado/Other) 30% 5% 5 years A-/AA- Supranationals 20% 10% 5 Years AA Any deviation from this list must be pre -approved by the Board of Weld County Commissioners in writing. IX. PROHIBITED INVESTMENT VEHICLES AND PRACTICES State law notwithstanding, any investments not specifically authorized pursuant to this approved Investment Policy are prohibited, including but not limited to: 1. Futures and options 2. Investment in inverse floaters, range notes, or mortgage derived interest -only strips 3. Investment in any security that could result in a zero -interest accrual if held to maturity 4. Trading securities for the sole purpose of speculating on the future direction of interest rates 5. Purchasing or selling securities on margin 6. The purchase of foreign currency denominated securities X. RISK MANAGEMENT AND DIVERSIFICATION It is the intent of the County to diversify the investments in 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, anc the County's anticipated cash flow needs. 9 Mitigating Credit Risk in the Portfolio Credit risk is the risk that a security or a portfolio will lose some or all of its value due to a real or perceived change in the ability of the issuer to repay its debt. The County will mitigate credit risk by adopting the following strategies: 1. The County may elect to sell a security prior to its maturity and record a capital gain or loss in order to improve the quality, liquidity or yield of the portfolio in response to market conditions or the County's risk preferences. 2. If securities owned by the County are downgraded by a nationally recognized statistical ratings organization (NRSRO) to a level below the quality required by this Investment Policy, it will be the County's policy to review the credit situation and make a determination as to whether to sell or retain such securities in the portfolio. A. If a security is downgraded, the Treasurer will use discretion in determining whether to sell or hold the security based on its current maturity, the economic outlook for the issuer, and other relevant factors. B. If a decision is made to retain a downgraded security in the portfolio, its presence in the portfolio will be monitored and reported to the Investment Advisory Committee. Mitigating Market Risk in the Portfolio Market risk is the risk that the portfolio value will fluctuate due to changes in the general level of interest rates. The County recognizes that, over time, longer -term portfolios have the potential to achieve higher returns. On the other hand, longer -term portfolios have higher volatility of return. The County will mitigate market risk by providing adequate liquidity for short-term cash needs, and by making longer -term investments only with funds that are not needed for current cash flow purposes. The County, therefore, adopts the following strategies to control and mitigate its exposure to market risk: 1. Investments shall be limited to maturities not exceeding five (5) years unless otherwise approved in writing by the Board of Weld County Commissioners for special circumstances (e.g., the reinvestment of bond proceeds). 2. The County shall maintain at least 10% of its total investment portfolio in instruments maturing in 90 days or less. 3. The maximum percent of callable securities (does not include "make whole call" securities as defined in the Glossary) in the portfolio will be 20%. 4. The duration of the portfolio will at all times be approximately equal to the duration (typically, plus or minus 20%) of a Market Benchmark, an index selected by the County based on the County's investment objectives, constraints and risk tolerances. XI. INVESTMENT POOLS/MUTUAL FUNDS The County shall conduct a thorough investigation of any local government investment pool or money market mutual fund prior to making an investment, and on a continual basis thereafter. There shall be a questionnaire developed which will answer the following general questions: 1. A description of eligible investment securities, and a written statement of investment policy and objectives. 2. A description of interest calculations and how it is distributed, and how gains and losses are treated. 3. A description of how the securities are safeguarded (including the settlement processes), and how often the securities are priced, and the program audited. 4. A description of who may invest in the program, how often, what size deposit and withdrawal are allowed. 5. A schedule for receiving statements and portfolio listings. 10 6. Are reserves, retained earnings, etc. utilized by the pool/fund? 7. A fee schedule, and when and how is it assessed. 8. Is the pool/fund eligible for bond proceeds and/or will it accept such proceeds? XII. COMPETITIVE TRANSACTIONS Each investment transaction shall be competitively transacted with broker/dealers who have been authorized by the County. Securities shall be purchased at the then best offering price based on the market conditions at that time. XIII.SELECTION OF BROKER/DEALERS AND FINANCIAL INSTITUTIONS ACTING AS BROKER/ DEALERS AND FINANCIAL INSTITUTIONS PROVIDING INVESTMENT SERVICES. The 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/investment bank, bank, or savings and loan institution must meet at least one of the following criteria: 1. Report voluntarily to the Federal Reserve Bank of New York; 2. Be recognized as a Primary Dealer by the Federal Reserve Bank of New York or have a primary dealer within its holding company structure; or 3. .Qualify under Securities and Exchange Commission (SEC) Rule 15c3-1 (Uniform Net Capital Rule). Broker/dealers and other financial institutions will be selected by the Treasurer on the basis of their expertise in public cash management and their ability to provide service to the County's account. Each investment firm authorized by the Treasurer shall be a FINRA reporting broker/dealer. Broker/Dealers must supply the Treasurer with audited financials and shall also attest in writing that they have received a copy of this policy. Selection of broker/dealers used by an external investment adviser retained by the County will be at the sole discretion of the adviser. Where possible, transactions with broker/dealers shall be selected on a competitive basis and their bid or offering prices shall be recorded. If there is no other readily available competitive offering, best efforts will be made to document quotations for comparable or alternative securities. 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. The County may purchase commercial paper from direct issuers even though they are not on the approved broker/dealer list as long as the paper meets the criteria outlined in item 7 of the section "VIII" titled "Eligible Investments and Transactions." A list of approved Broker/Dealers, Banks, and Savings & Loan institutions is included in various "Resolutions" performed by the Board of County Commissioners of Weld County. Colorado. XIV. SELECTION OF BANKS AND SAVINGS AND LOANS (DESIGNATION UNDER CRS 11-10.5-106 (Banks) and CRS.11-47-105 (Savings & Loan)) AS DEPOSITORIES AND PROVIDERS OF GENERAL BANKING SERVICES AND 11 ASSET POOLS AS DEPOSITORIES The Treasurer shall maintain a list of authorized banks, savings and loans, and public asset pools as depositories for Weld County funds 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 is required to be designated an eligible public depository by the state banking board and a savings and loan must be designated an eligible public depository by the state commissioner of Banking. Additionally, banks or savings and loans, in the judgment of the Treasurer, who no longer offer adequate safety or service to the County, will be removed from the approved list. The list will be updated annually if any changes are requested to insure compliance. Depositories shall be selected based on ratings and competitive rates of return. XV. SAFEKEEPING AND CUSTODY 1. The Treasurer 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 have a Bauer rating of 3 stars or better out of possible 5 -star rating. Custodian banks will be selected on the basis of their safety and ability to provide service to the County's account with 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 as needed. Custodial banks should be in the highest rating categories. Delivery -versus -Payment (DVP). All investment transactions shall be conducted on a delivery -versus -payment basis. SAFEKEEPING All purchased securities will be perfected in the name of the County. Sufficient evidence to title shall be consistent with modem investment, banking and commercial practices. All investment securities, except non-negotiable certificates of deposit, local government investment pools, and money market funds, purchased by the County will be held by a PDPA eligible Colorado State bank or 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). All non -book entry (physical delivery) securities shall be held by Weld County's designated custodian bank for the benefit of 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 12 holdings of custody securities as well as an account analysis report of monthly securities activity. XVI. PERFORMANCE BENCHMARKS The investment portfolio shall be designed to attain a market -average rate of return throughout budgetary and economic cycles, taking into account the County's risk constraints, the cash flow characteristics of the portfolio, and state and local laws, ordinances or resolutions that restrict investments. The Treasurer shall select an appropriate, readily available index To use as a market benchmark. The Treasurer shall monitor and evaluate the portfolio's perforrr ance relative to the market benchmark. The Treasurer shall present to the Investment Advisory Committee of Weld County a review of the current investments and the portfolio's adherence to appropriate risk levels and a comparison between the portfolio's total return and the established investment objectives and goals. XVII. REPORTING Accounting and reporting on the County's investment portfolio shall conform to Generally Accepted Accounting Principles (GAAP) and the Governmental Accourling Standards. QUARTERLY REPORTS The CFO Finance Director or Treasurer will submit a quarterly investment report to the Investment Advisory Committee which provides full disclosure of the County's investment activities withir 30 days after the end of the quarter. These reports will disclose, at a minimum, the following information abott County's portfolio: 1. An asset listing showing par value, cost and independent third -party fair market value of each security as of the date of the report, the source of the valuation, type of investment, issuer, maturity date, interest rate and interest rate. 2. Transactions for the period. 3. A description of the funds, investments and programs managed by conxacted parties (i.e. local government investment pools and outside money managers) 4. A one -page summary report that shows: a.) Average maturity of the portfolio and modified duration of the portfolio; b.) Maturity distribution of the portfolio; c.) Percentage of the portfolio represented by each investment category ; d.) Average portfolio credit quality; and, e.) Time -weighted total rate of return for the portfolio for the prior one month, three months, twelve months and since inception compared to the County's marIce,t benchmark returns for the same periods; 5. A statement of compliance with the Investment Policy, including a schedule of any transactions or holdings which do not comply with this Policy, including a justification for their presence in the portfolio and a timetable for resolution. ANNUAL REPORTS A comprehensive annual report will be presented to the Board of County Commissioners. This report will include comparisons of the County's return to the market benchmark return, suggest policies and improvements that might enhance the investment program, and will include an investment plan for tie coming year. 13 XVIII. POLICY REVISIONS This investment policy shall he reviewed at least annually by the Director of Finance and 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 Treasurer as necessary, provided the changes in no way affect the substance or intent of this policy. Exhibit I Authorized Personnel The following persons are authorized to transact investment business and wire funds for investment purposes on behalf of the Weld County: Treasurer Assistant Treasurer INVESTMENT COMMITTEE 14 Glossary of Investment Terms AGENCIES. Shorthand market terminology for any obligation issued by a government -sponsored entity (GSE), or a federally related institution. Most obligations of GSEs are not guaranteed by the full faith and credit of the US government. Examples are: FFCB. The Federal Farm Credit Bank System provides credit and liquidity in the agricultural industry. FFCB issues discount notes and bonds. FHLB. The Federal Home Loan Bank provides credit and liquidity in the housing market. FHLB issues discount notes and bonds. FHLMC. Like FHLB, the Federal Home Loan Mortgage Corporation provides credit and liquidity in the housing market. FHLMC, also called "FreddieMac" issues discount notes, bonds and mortgage pass - through securities. FNMA. Like FHLB and FreddieMac, the Federal National Mortgage Association was established to provide credit and liquidity in the housing market. FNMA, also known as "FannieMae," issues discount notes, bonds and mortgage pass -through securities. GNMA. The Government National Mortgage Association, known as "GinnieMac," issues mortgage pass - through securities, which are guaranteed by the full faith and credit of the US Government. PEFCO. The Private Export Funding Corporation assists exporters. Obligations of PEFCO are not guaranteed by the full faith and credit of the US government. TVA. The Tennessee Valley Authority provides flood control and power and promotes development in portions of the Tennessee, Ohio, and Mississippi River valleys. TVA currently issues discount notes and bonds. ASKED. The price at which a seller offers to sell a security. ASSET BACKED SECURITIES. Securities supported by pools of installment loans or leases or by pools of revolving lines of credit. AVERAGE LIFE. In mortgage -related investments, including CMOs, the average time to expected receipt of principal payments, weighted by the amount of principal expected. BANKER'S ACCEPTANCE. A money market instrument created to facilitate international trade transactions. It is highly liquid and safe because the risk of the trade transaction is transferred to the bank which "accepts" the obligation to pay the investor. BENCHMARK. A comparison security or portfolio. A performance benchmark is a partial market index, which reflects the mix of securities allowed under a specific investment policy. BID. The price at which a buyer offers to buy a security. BROKER. A broker brings buyers and sellers together for a transaction for which the broker receives a commission. A broker does not sell securities from his own position. CALLABLE. A callable security gives the issuer the option to call it from the investor prior to its maturity. The main cause of a call is a decline in interest rates. If interest rates decline since an issuer issues securities, it will likely call its current securities and reissue them at a lower rate of interest. Callable securities have reinvestment risk as the investor may receive its principal back when interest rates are lower than when the investment was initially made. CERTIFICATE OF DEPOSIT (CD). A time deposit with a specific maturity evidenced by a certificate. Large denomination CDs may be marketable. CERTIFICATE OF DEPOSIT ACCOUNT REGISTRY SYSTEM (CDARS). A private placement service that allows local agencies to purchase more than $250,000 in CDs from a single financial institutior (must be a participating institution of CDARS) while still maintaining FDIC insurance coverage. CDARS is currently the only entity providing this service. CDARS facilitates the trading of deposits between the institut:on and other participating institutions in amounts that are less than $250,000 each, so that FDIC coverage is maintained. COLLATERAL. Securities or cash pledged by a borrower to secure repayment of a loan or repurchase agreement. Also, securities pledged by a financial institution to secure deposits of public monies. COLLATERALIZED MORTGAGE OBLIGATIONS (CMO). Classes of bonds that redistribute the cash flows of mortgage securities (and whole loans) to create securities that have different levels of prepayment risk, as compared to the underlying mortgage securities. COMMERCIAL PAPER. The short-term unsecured debt of corporations. COST YIELD. The annual income from an investment divided by the purchase cost. Because it does not give effect to premiums and discounts which may have been included in the purchase cost, it is an incomplete measure of return. 15 COUPON. The rate of return at which interest is paid on a bond. CREDIT RISK. The risk that principal and/or interest on an investment will not be paid in a timely manner due to changes in the condition of the issuer. CURRENT YIELD. The annual income from an investment divided by the current market value. Since the mathematical calculation relies on the current market value rather than the investor's cost, current yield is unrelated to the actual return the investor will earn if the security is held to maturity. DEALER. A dealer acts as a principal in security transactions, selling securities from and buying securities for his own position. DEBENTURE. A bond secured only by the general credit of the issuer. DELIVERY VS. PAYMENT (DVP). A securities industry procedure whereby payment for a security must be made at the time the security is delivered to the purchaser's agent. DERIVATIVE. Any security that has principal and/or interest payments which are subject to uncertainty (but not for reasons of default or credit risk) as to timing and/or amount, or any security which represents a component of another security which has been separated from other components ("Stripped" coupons and principal). A derivative is also defined as a financial instrument the value of which is totally or partially derived from the value of another instrument, interest rate, or index. DISCOUNT. The difference between the par value of a bond and the cost of the bond, when the cost is below par. Some short-term securities, such as T -bills and banker's acceptances, are known as discount securities. They sell at a discount from par and return the par value to the investor at maturity without additional interest. Other securities, which have fixed coupons, trade at a discount when the coupon rate is lower than the current market rate for securities of that maturity and/or quality. DIVERSIFICATION. Dividing investment funds among a variety of investments to avoid excessive exposure to any one source of risk. DURATION. The weighted average time to maturity of a bond where the weights are the present values of the future cash flows. Duration measures the price sensitivity of a bond to changes in interest rates. (See modified duration). FEDERAL FUNDS RATE. The rate of interest charged by banks for short-term loans to other banks. The Federal Reserve Bank through open -market operations establishes it. FEDERAL OPEN MARKET COMMITTEE. A committee of the Federal Reserve Board that establishes monetary policy and executes it through temporary and permanent changes to the supply of bank reserves. LEVERAGE. Borrowing funds in order to invest in securities that have the potential to pay earnings at a rate higher than the cost of borrowing. LIQUIDITY. The speed and ease with which an asset can be converted to cash. LOCAL GOVERNMENT INVESTMENT POOL. An investment by local governments in which their money is pooled as a method for managing local funds. MAKE WHOLE CALL. A type of call provision on a bond that allows the issuer to pay off the remaining debt early. Unlike a call option, with a make whole call provision, the issuer makes a lump sum payment that equals the net present value (NPV) of future coupon payments that will not be paid because of the call. With this type of call, an investor is compensated, or "made whole." MARGIN. The difference between the market value of a security and the loan a broker makes using that security as collateral. MARKET RISK. The risk that the value of securities will fluctuate with changes in overall market conditions or interest rates. MARKET VALUE. The price at which a security can be traded. MARKING TO MARKET. The process of posting current market values for securities in a portfolio. MATURITY. The final date upon which the principal of a security becomes due and payable. MEDIUM TERM NOTES. Unsecured, investment -grade senior debt securities of major corporations which are sold in relatively small amounts on either a continuous or an intermittent basis. MTNs are highly flexible debt instruments that can be structured to respond to market opportunities or to investor preferences. MODIFIED DURATION. The percent change in price for a 100 -basis point change in yields. Modified duration is the best single measure of a portfolio's or security's exposure to market risk. MONEY MARKET. The market in which short-term debt instruments (T -bills, discount notes, commercial paper, and banker's acceptances) are issued and traded. MORTGAGE PASS -THROUGH SECURITIES. A securitized participation in the interest and principal cash flows from a specified pool of mortgages. Principal and interest payments made on the mortgages are passed through to the holder of the security. MUNICIPAL SECURITIES. Securities issued by state and local agencies to finance capital and operating expenses. 16 MUTUAL FUND. An entity which pools the funds of investors and invests those funds in a set of securities which is specifically defined in the fund's prospectus. Mutual funds can be invested in various types of domestic and/or international stocks, bonds, and money market instruments, as set forth in the individual fund's prospectus. For most large, institutional investors, the costs associated with investing in mutual funds are higher than the investor can obtain through an individually managed portfolio. NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION (NRSRO). A credit rating agency that the Securities and Exchange Commission in the United States uses for regulatory purposes. Credit rating agencies provide assessments of an investment's risk. The issuers of investments, especially debt securities, pay credit rating agencies to provide them with ratings. The three most prominent NRSROs are Fitch, S&P, and Moody's. NEGOTIABLE CD. A short-term debt instrument that pays interest and is issued by a bank, sav .ngs or federal association, state or federal credit union, or state -licensed branch of a foreign bank. Negotiable CDs are traded in a secondary market and are payable upon order to the bearer or initial depositor (investor). PREMIUM. The difference between the par value of a bond and the cost of the bond, when the cost is above par. PREPAYMENT SPEED. A measure of how quickly principal is repaid to investors in mortgage securities. PREPAYMENT WINDOW. The time period over which principal repayments will be received on mortgage securities at a specified prepayment speed. PRIMARY DEALER. A financial institution (1) that is a trading counterparty with the Federal Reserve in its execution of market operations to carry out U.S. monetary policy, and (2) that participates for statistical reporting purposes in compiling data on activity in the U.S. Government securities market. PRUDENT PERSON (PRUDENT INVESTOR) RULE. An investment standard outlining the fiduciary responsibilities of public funds investors relating to investment practices. REALIZED YIELD. The change in value of the portfolio due to interest received and interest earned and realized gains and losses. It does not give effect to changes in market value on securities, which have not been sold from the portfolio. REGIONAL DEALER. A financial intermediary that buys and sells securities for the benefit of its customers without maintaining substantial inventories of securities and that is not a primary dealer. REPURCHASE AGREEMENT. Short-term purchases of securities with a simultaneous agreement to sell the securities back at a higher price. From the seller's point of view, the same transaction is a reverse repurchase agreement. SAFEKEEPING. A service to bank customers whereby securities are held by the bank in the customer's name. STRUCTURED NOTE. A complex, fixed income instrument, which pays interest, based on a formula tied to other interest rates, commodities or indices. Examples include inverse floating rate notes which have coupons that increase when other interest rates are falling, and which fall when other interest rates are rising. and "dual index floaters," which pay interest based on the relationship between two other interest rates - for example, the yield on the ten- year Treasury note minus the Libor rate. Issuers of such notes lock in a reduced cost of borrowing by purchasing interest rate swap agreements. SUPRANATIONAL. A Supranational is a multi -national organization whereby member states transcend national boundaries or interests to share in the decision making to promote economic development in the member countries. TOTAL RATE OF RETURN. A measure of a portfolio's performance over time. It is the internal rate of return, which equates the beginning value of the portfolio with the ending value; it includes interest earnings, realized and unrealized gains, and losses in the portfolio. U.S. TREASURY OBLIGATIONS. Securities issued by the U.S. Treasury and backed by the full faith and credit of the United States. Treasuries are considered to have no credit risk and are the benchmark for interest rates on all other securities in the US and overseas. The Treasury issues both discounted securities and fixed coupon notes and bonds. TREASURY BILLS. All securities issued with initial maturities of one year or less are issued as discounted instruments and are called Treasury bills. The Treasury currently issues three- and six-month T -bills at regular weekly auctions. It also issues "cash management" bills as needed to smooth out cash flows. TREASURY NOTES. All securities issued with initial maturities of two to ten years are called Treasury notes and pay interest semi-annually. TREASURY BONDS. All securities issued with initial maturities greater than ten years are called Treasury bonds. Like Treasury notes, they pay interest semi-annually. VOLATILITY. The rate at which security prices change with changes in general economic conditions or the general level of interest rates. YIELD TO MATURITY. The annualized internal rate of return on an investment which equates the expected cash flows 17 Hello