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RESOLUTION NO. 06-345
A RESOLUTION AMENDING RESOLUTION NO. 05-378
WHICH AMENDED THE INVESTMENT POUCY FOR ST.
LUCIE COUNTY, FL.ORIDA, BY FURTHER AMENDING THE
INVESTMENT POUCY
WHEREAS, the Board of County Commissioners of St. L.ucie county, Florida, has made
the following determinations:
1. Pursuant to Section 218.415, Florida Statutes, on or befoN Oçtober 1, 1995,
çounties that have custody of public funds in excessofthe amounts needed to meet current
expenses who elect to conduct investment activity themselves rather than depositing these
fun<ls in the Local Government Surplus FUnds Trust Fund for investment by the State Board
of Administration, are required to conduçt such investment activity in acçordance with a
written investmènt plan and an investment policy a<lopted by the Board of County
Commissioners or in the alternative to invest in specified low-risk instruments.
2, On September 26, 1995, the BOard adopted Resolution No. 95-168 which
a<lopte<lan investment policy as recqmmende<l by the Investment Subcommittee of the St.
Lucie County Citizens Budget Review Committee.
3. On December 6,1995, the Investment committee recommended thatthe Board
adopt certain amendments to the investment poliçy; and on January 2, 1996,theBoard
adopted Resolution No. 95-275 which amended the investment policy and incorporated the
recommended changes of the Investment Committee.
4. On December 3,1997, the Investment Committee recommendedthatthe Board
adopt certain amendments to the investment policy and on December 16, 1997, the Board
adopted Resolution No. 97-190 which amended the investment policy and incorporated the
recommended changes of the Investment Committee.
5. On April 4, 2001, the Investment Committee recommended that the Board
adopt certain amendments to the investment policy, and on April 24, 2001. the Board adopted
Resolution No. 01-95 which amended the investment policy and incorporated the recommended
changes of the Investment Committee.
6. On September 21, 2005, the Investment Committee recommended that the
Board adopt certain amendments to the investment policy and on October 11, 2005, the Board
adopt~dResqllltion No, 05-378 whiçh e¡mendedthei!'westment policy and incorporated the
recommended changes of the Investment Committee.
7. On October 25,2006, th~ InY~stnwntCommittee recommende<:Jthat the ßoard
adopt çerte¡in changes to the investment policy, which amendments are attached as Exhibit
"All,
NQW, THEREFORE, BE IT RESOLVED. by the Board of County Commissioners of St.
Lucie County, Florida:
1. This Board does hereby adoPt. the e¡m~ndments to the investment policy
attaçhed hereto and made a part hereof as Exhibit "A", pursuant to Section 218.415, Florida
Statutes.
2. Except as e¡mended her~in, the reme¡iningterms and conditions of Resolution No.
05-378, as amended, shall remain in full force and effect.
3. This resolution shall take effect on adoption.
After motion and second, the vote on this resolution was as follows:
Chairman Chris Cre¡ft
Vice Chairman Joseph E. Smith
Commissioner Paule¡ A, Lewis
Commissioner Doug Coward
Commissioner Charles Grande
AYE
AYE
AYE
AYE
AYE
ATTEST:
~~/
Deputy Clerk
Chairman
BY:
EXHIBIT "A"
ST. LUCIE COUNTY
INVESTMENT POLICY
TABLE OF CONTENTS
I. SCOPE ............ ........................................................................................................................................1
II. INVE STMENT ...... .............................,.....,..,.......,...............................................................................1
III. INVESTMENT PERFORMANCE ANt) REPORTING ...........................................................1,2
IV. PRUDENCE AND ETHICAL STANDARDS ...............................................................................2
V. AUTHORIZED INVESTMENTS ..,........,..............................................................................2,3,4
VI. MA TURITY AND LIQUIDITY REQUIREMENTS ............................................................4,5
VII. PORTFOLIO COMPOSITION ..,...........................................................................................6 ,7,8
VIII. RISK AND DIVERSIFICA TION ................................................................................................ 8
IX. AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS .................................. 8
X. THIRD PARTY CUSTODIAL AGREEMENTS ..........................................................................9
XI. MASTER REPURCHASE AGREEMENT ...................................................................................... 9
XII. BID REQUIREMENTS ............................. ................................... .............................................. 9 ,10
XIII. INTERNAL CONTROLS .................................................................... ..................................... 11,12
I. SCOPE
Thisinye;¡tment policy applies to all~urpl~sfunds held by or for the benefit of the
St. lljcieCounty Board of County Commissioners,hereinafter referred to as the COllnty.
Th.~se policies were adoptedu~ingSe<;tions 125.31 and 218.415, Floridc:t,5tatutes.
Bond proceeds may be further limited orexpan~~dbytheir respective bond resolutions or
coven¡mtsand shall not be considered to bein conflict with the Investment Policy.
II. INVESTMENT OBJECTIVES
TheÇounty shall strive to achieve with each investment opportunity, the following
objectives, in ORDER OF PRIORITY:
1. SAFETY - The primaryobjeçtive of the County's investment activities is the
protection of investment capital.
2. UQUIDITY - The çOllnty's investment strategy will provide sufficient
liquidity such that cash flow requirements are met through the utilization of
marketable securities withstrllctured maturities.
3. INVESTMENT INCQME- Ininve~ting public fllnds, the COllnty will strive to
maximize the return on the portfolio but will minimize investment risk.
III. INVESTMENT PERFORMANCE AND REpQRTING
A portfolio report shall be prepared eoçh quarter by the Finance Director or
designoted staff member, and be provided to the Çlerk of the Çircllit Court and
appropriotemonagement staff. The report will also .be made avoilable to the Board of
County Commissioners and Investment Committee. The report shall include a breakdown of
the portfolio as well as its overall performance and the current market pricing at month-
end.
A detailed analysis of the investment portfolio will be prepared by the Finance
Director and presented to the Board of County Commissioners and Investtn~ntS~mtT\ittee
on a quarterly basis. The report shall include information relating to tran;¡Qçtions,morket
values, performance and adherence to policy. The Clerk of Court is authorized to utilize an
investment accounting service to obtain necessary information. The · Board of< COllnty
Commissioners will conduct an annual meeti¡;g to review of the investment portfolio and
evaluate the investment policy.
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The ßoard of County Commissioners will appoint an Investment Committee that will
serve in anaçlvisory capacity and report to the. Board of County Commissioners. Each
Commissipner will select pne of the five Investment Committee members who will possess
relevantfina.nçi,¡ experience. The Inv<;lstment Çommittee will rely on the, Çl<;lrk of the
Court, Finance Director, and their stafffor support. The Investment Committee and the
Board of/County COmmissioners shall receive a copy of the portfolio. priçing qnalysis,
p~eÞ(:\~ecl)e'tt~çtRi~6 P(!~t·t' se~vice and sRsIIßIs¡¡ receive c¡¡pies of all trai'l$actiei'l acl'/ice$
preparecl 10'1 apprG'/ed erelœrs.
The Çlerk of the Circuitcoyrtshal.lb.enotified immediately upon exceptions from
currently approved investment policies by the Finance Director.
In the event of an emergencysiìt,ationrequiring noncompliance with policy
guidelines, theF'inance Director shall attempt to s<;hedule a special cOmmittee meeting to
discuss the proposed action, If a spe.cialcommittee meeting is not possible due to time
conStrail'1tsorsçheduling problems, the FinanceJ')irector shall individually notify a minimum
of three committee members to obtain approval of the proposed action.
IV. PRUDENCE AND ETHICAl. STANDARDS
The "prudent person" standard shall be used in the management of the overall
investment· portfolio.
The Finance Director, ançl other perSPnsperforming the investmentfunçtion, shall
act as a "prudent person" in açcorçlançe.withthese written policies and procedures,
exercising due diligence and investing in investments authorized by law.
The "prudent person" stançlarçl is herewith understood to mean the foll9win9:
Investmentsshall be made with Judgment and care, under circumstances then prevailing,
which persons of prudence, discretion, and intelligence exercise in themanCige.ment of
their own affairs, not for speculation, but for investment, considering the probable safety
of their capital as well as the probable income to be derived.
V. AUTHORIZED INVESTMENTS
The Clerk of the Court acting through the Finance Director,. or other designee of
the Clerk's office, shall purchase or sell investment securities at prevailing)market rates"
with a preference to par bonds or those at a discount. Authorized instruments are as
follows:
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A, Th~ LQcal Gov~rnm~nt Sµrph,¡s Fµl'1dsTrµst Fµnd, the State Investment Pool
administered by the State Board of AdministratiQn, also known as S.BA
B. The Florida Local Governm~nt Investment Trµst, also known a.s the F.L.G.I.T,
administered by the Florida AssQdation of CQµrt Clerks and Comptrollers and the Florida
AssodatiQn of Counties.
C, NegQtiable dir~ct obligations of, or Qbligations the principal and interest of
which ar~!.Il'1conditionally guaranteed by, the United States Government. Such securities
will indude, but nM be limited to, the following:
1. Treasury Bills
2. Treasury Notes
3. Treasury Bonds
D. Bonds, d~bentures, not~:¡or 8th~r ~vidence Qf indebtedn~ss issued or
guarant~ed by United Stat~s ç¡g~nçi~siPf'ovid~q ?!.Ic), obligations are. bç¡çk~d by the full
faith and credit of the United States Government. Such securities will indude, but not be
limited to, the following:
1. Farmers Home Adt¡\inistration
2. GQvernment NationalMQrtgage Assodation (GNMA)
E. Bonds, d~bentures, notes of Of' Qt~~f' evid~nce of ind~bt~dn~ss issued or
gµarç¡nteed by United States Governmentagenci~s(Federal Instrumentalities) which are
not full faith and credit agendes limited to the following:
1. Federal Farm Credit Bank (FFCB)
2. Federal Home Loan Bank or its district banks (FHLB)
3. Federal NatiQnal MQrtgage Assodation (FNMA)
4. Federal Home Loan Mortgage Corporation (Freddie-Macs)
F. Non-negotiable interest-bearing time certificç¡tes of d~posit, mQn~y market
accounts or savings ç¡ccounts in banks/savings and loan assodations organi:¡:~d under the
laws of the United States, doing business and sitµated in this state, proviqed that ç¡ny such
deposits are secured by the Florida Security for Public Deposits Act, Chapter 280, Florida
Statutes.
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G. Repurchase agreements collateralized by Treasury Bills or Notes having a
maturity of two (2) years or less.
Investment in derivative products is not authorized, For the purposes of
this policy derivative products are defined as financial arrangements whose value are
derived from changes in an underlyin9 variable such as a stock, bond, stock index, interest
rate index, currency, commodity, etc. Derivative investments include, but are not limited
to: futures contracts, options contracts, forward contracts, interest rate swaps. interest
rate floor or ceilinq contracts, and linked index investments.
VI. MATURITY AND LIQUIDITY RI;QUIRI;MENTS
To the extent possible, an att~tr\ptwill be mClde to match investment maturities
with known cash needs and ClnticipClt~dcClsh.flow r~quirements. Investments, including
investment pools, of current operating Junds shall have maturities of up to five (5) years,
The Finançe Director and oth~r p~rsonsp~rforming the investment function will provide
an appropriqte mix of maturities to mClximizethe return on the portfolio while minimizing
investment risk. Investment of bond reServ~s, çonstruction funds, and other non-
operCltingfunds shall have a t~rm apprQpriat~tQ the need for funds, atld in accordance
with debt covenants, but shall not exceed five (5) years, unless permitted by the terms of
the bond documents.
II'wçstl'llei'lts dø flet l'!ecesSßril)'Ra"eJe~el1'1¡¡defer tke sameleflgtk af time tkat
tke fUflds are availaBle. Tke Basic criteria fer ceflsideratiel'! fer iflvestmeflts are as
felleVls:
.... Keep maturities skert ifl a peried.ofceflstarltly risil'!g iflterest rates Basea efl
Treasury bill auctieAS er tke dail'! federal fUAdsrate.
B, Keep maturities skeF't iA a >eríed ef al'l il'lverted treasury yield curve (skert
term rates kigker tkal'! len§l term rates).
C. ,'.',atl:lrities skeuld be lefl§ltkefled whel'! the treasur)' yield ci; rve i:; I'!ermal aRd
is e)(pected te remail.!tRatwlJtfbasedeAeceRemicrepertstalleRasawkele.Tfle yield
curve is Mrmal wReR skert term rates are lewer thal'l lel'lg term rates.
D. Maturities SREll:lld ~e leflgtkeRed whel'l iRterest rates are e)(pected te fall
based 61'1 ecel'lemic re\3erts tal<el'l as a whale.
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E. frem time te time, seç¡l:IritieSi'l'\t;!Y~ctF¡¡âeØ fer ather similap se9:1rities te
imfJra'/c 'lielâ, matl:lrity er ç¡reâit risl,. Far thes7t)' '1es ef traRsaç¡ti¡¡RS, a tel'lìfJer¡¡r'( less
mG'( be iRç¡l:Irreâ fer mel:lRtiR!!). I'yrfJeS¡¡¡s, I'r~vi~!i!d< the. Ie:;:; I:; mere. thaR eUset . by the
hi!!)her yielâ. The fellewiR!!) ç¡irç¡l:ImStaRees are ç¡el'\sidered al'I'rel'riate fer a swal' 131'\
e¡\ChaAge efseeuritiM te be eeRsidered:
1. The '(ield has iRereaseâ.
Marllet aberratiaRs are afteR eauseâ by sUl'fJl'( aRâ demaAâ eeRI-MieRS fer
I'artiel:llap securities. fer e)(aml'le, if a shert sUPI'I'( e¡lists fer a I'articl:Ilar matupity ral'\!!)e,
theR it mE!'f be od'loAtogeeus ta sw0l' trade aut ef the security iR a shert sUl'I'ly aAd iRte
,mether similar security iR a differeRt maturity raR!!)e.
2. The maturity has beeR reduced.
Marl(et aberratieRs ec.casia~aIlYef'eate a Sitl;latieR. where leR!!)er matl;lrity
secl:lritiesare yielâiR9 the same ¡¡I' lessithaRseç¡\:ipities with a sherter.mf.lturity, Pertfelie
E ualityeORbe il'lì '1reved by sV¡itç¡hiR9}rem the I¡¡Rger maturity seç¡l;Iri"ly te tRe sherter
matl:lrity v¡ith little er Re iRterest I'eAalt·f.
3. The E uality ef the iRvestl'lìeRthas iml'reved.
Marl,et aberratieRs eceasieRally ereate a situatieR where certaiR higher risl,
securities yield the same sr less thaR aR eE ui',aleRt lewer risl( seeurity. Pertfelie E uality
eaR be iml'reveâ by switç¡hiRg frem the higher risl( seeurity te a lewer rish seç¡urity witReut
ORY iRterest rate peRalty.
¡;.. A liquidity amount ofapproxitnatelytwe (2) three (3) months of anticipated
disbursements, exduding bond COtlstruction paYtnents or other bond PQyments made from
escrow or trust accounts, will be kept in relatively short-term investments. These would
include the State Investment Pool (SBA), F.L.G.I.T., money market accounts Certificates ef
Del'esit, u.s. Treasury Obli!!)atieRs and Repurchase Agreements.
G. Although maR',. scç¡l:Irities are aç¡eel'toble fer iRvestmeRtl:lSiR!!) the al:ltherized
list, samc are Ret very desirable fremaliE l:IiditystaRâl.¡¡iRt;aç¡earâiRgly.eRI... these
seCIJrities with aR aç¡ti-.e seeel'\dary marhet may be I'urehased frem that list.
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VII. PORTFOLIO COMPOSITION
Th¡-; following ar¡-; th¡-; guid¡-;Iin¡-;s for inv¡-;stm¡-;nts and limits on s¡-;curity issu¡-;s,
issu¡-;rs, cmdmatLiriti¡-;s as ¡-;stablish¡-;d by th~County. Th¡-; Financ¡-; Dir¡-;ctor, or th¡-;ir
appropriat¡-;d¡-;sign¡-;¡-;, aft¡-;r consLiltingwith.th¡-;CI¡-;rk of Circuit Court, shall hav¡-; th¡-; option
to furth¡-;r r¡-;strict or incr¡-;as¡-; inv¡-;stm¡-;l1tp¡-;rç¡-;ntClQ¡-;S from tim¡-; to tim¡-; bas¡-;d on mark¡-;t
conditions, Purchas¡-;s of inv¡-;stm¡-;ntsbo.s¡-;don bond cov¡-;nant r¡-;quir¡-;m¡-;nts shall not b¡-;
includ¡-;d in th¡-; portfolio composition ço.lculatipn. Th¡-; following maximum limits ar¡-;
guid¡-;Iin¡-;s ¡-;stablish¡-;d for div¡-;rsifìcation by instrum¡-;nt:
A. Th¡-; Local Gov¡-;rnm¡-;nt Surplus Trust Fund (SBA).
1. A maximum of aQto pf th¡-;portfolio may b¡-; inv¡-;st¡-;d in these TptJsts
th¡-; SBA, how¡-;v¡-;r, bond proç¡-;¡-;ds mayþ¡-; t~mporarìly d¡-;posit¡-;d in th¡-; TrtJst FtJl9d
InvÐstl\'\el9t Pa.als SBA until alt¡-;rnativ¡-; inv¡-;stm¡-;nts hav¡-; b¡-;¡-;n purchas¡-;d and ar¡-; not a
part of this calculation.
B. Th¡-; Local Gov¡-;rnm¡-;nt Inv¡-;stment Trust fund (F.L.G.I.T.)
1. A maximum of 35to of th¡-; portfolio may b¡-; inv¡-;st¡-;d in (F.L.G.I.T~.
C. Non-n¡-;gotiabl¡-; Interest-B¡-;aring Tim¡-; C¡-;rtificat¡-;s of D¡-;posit
1. A maximum of4Qto pfth¡-;portfolio may b¡-; inv¡-;st¡-;d in non-n¡-;gotiabl¡-;
int¡-;r¡-;st b¡-;aring tim¡-; c¡-;rtificat¡-;s of d¡-;posit or savings accounts.
2. Th¡-; maximum maturity on any ærtificates shall be no greater than
on¡-; (1) year from the time of purchase.
3. A maximum of ~ lO'Yo of the portfolio may be d¡-;posit¡-;d in the
instruments of anyone issuer.
D. United States Government Securities
1. A maximum of 75'Yo of the portfolio may b¡-; invested in United Stat¡-;s
Government Securities which are defined as negotiable direct obligations, or obligations
the principal and interest of which are unconditionally guaranteed, by the United States
Government,(e)(sl\'\¡¡le: TresstJPy Bills, ÞJates).
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2. The maximum length of maturity of any direct investment in
government securities is five (5) years.
E. United States Federal Agencies
1. A maxim!Jm of 5O'YoofthE;po.rtfo!i0 may be invested il'1\.Jt1ited states
Federal~~ency securities which are backed by the full faith and credit of the United
States Government,(e¡(al'!'\f3le: GN,',I,A, f-arl'!'\eps Hal'!'\C Aal'!'\il'listratisA).
2. .\'.aturit'f will I>e. limitea ta tRere< \;IiPÐments ef UAitea States
G(¡,(eri'll'r\el'ltsecl;lrities. The maximum length of maturity of any direct investment in
Federal Agencies Securities is five (5) years.
3. A maximum of 25'ì'o of the portfolio may be invested in the
instruments of anyone issuer.
F. Federal Instrumentalities
1. A maximum of 40'ì'o of the portfolio may be invested in Federal
InStrumentalities which are not full-faith and credit United States Government
Agencies,(e¡(al'!'\f3le: fFCB, fÞJMA).
2. Matupit'f will. aelil'!\itea te tRere< l;Iiremei'lts ef tRe. United States
GeverRl\îentsecl:lritics. Themaximumlenqth of maturity of any direct investment in
Federal Instrumentalities is five (5) years.
3. A maximum of 25'ì'o of the portfolio may be invested in the
instruments of anyone issuer.
G. Repurchase Agreements
1. A maximum of lO'ì'o of the portfolio may be invested in repurchase
agreements with the exception of one (1) business day agreements and overnight sweep
agreements which may go as high as 25'ì'o.
2. The maximum term of a repurchase agreement will be one (1) year.
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3, A maximum of 10'Y. 9fth~ portfolio may be invested in the
instrumentsiof anyon~issuer with the exceptianof one (1) business day agreements and
overnight sweep agreements which may go as high as 25'Yo.
VIII. RISK AND DIVERSIFICATION
Assets held shall be div~rsified to contr91the risk of IQss resultingfrQm the Qver
concentratiQnof assets in a specific maturity, issuer, instrument, dealer, Qr bank through
which th~se instrµments are bQughtam:l sold. Diversification strategies within the
establishedgµidelines shall be reviewed and revised periodically as necessary by the
appropriate management staff,
IX. AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS
The CQunty shall only purchase securities from financial institutions which have
Qffices IQc;qted within the State of FIQl'idaand(ll'e quglified as public d~positQries by the
TreQsurer of the State of Florida, fromprimQrys~curities brokers/deQlers designated by
th~ Federal Reserve Bank of New YQrkorfrom. secondary brokers/d~QI~rs, specified
def3leps,v¡jt~.ßReffice lecatediR St,LuciøceuRty, withQn Qffice 10cQtedin the State of
FIQrida. Sychspecified brokers/deal~rSrnµstber¡;cel'!'\fI\ei'lded reviewed~ndapproved by
the Investment Committee and QPprQved . ii'ldi','iduall'f by the BOQrd Qf County
CQmmissioners, Documented lists of the aythorized financial institutions and
brokers/deQlers will be developed and maintained by the Finance Director and approved by
the Clerk of the Court.
If Qt anytime the Clerk 9f the CQyrt is QPpropriately notified of any threat to the
integrity of the investment portfoJio, proper security measures maY beSygg.ested and
implemented, and the Clerk of the Coyrtsh.all have the option to further restrict
investment in selected instruments, to conform to the then-present market conditions.
Repurchase Agreements will be conducted through, and negotiated with primary
securities brokers/dealers, or sec;ondary brokers/dealers, or Qualified Public; Dep9sitory
financ;iaLinstitutions. A written Master Repurchase Agreement will benegotiated with any
institutiQns with which the County through the Clerk of the Court enters into a specific
repurchase agreement.
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X. THIRD PARTY CUSTODIAL AGREEMENTS
The Clerk of the Court will exeçute a Third Party Custodial safekeeping Agreement
with a cpmt¡\ercial bank's trust department which is separately chartered by the United
StCites L?pvernment or the State of Florida. ¡ð,lIsecurities purchased and/or collateral
obtCiinedbythe Clerk of the Court ShCiIl bepr9perlydesignCited as an asset 9fthe County
and held in <safekeeping by the trust department and no withdrawal of such seçurities, in
whole or itlpCirt, shall be made from safekeeping except by an authorizedstCiffmember.
The Third PCirty Custodial SCifekeeping ¡ð,greet¡\ent shCiIl include letters of authority from
the Clerk of the Court, details as to respon~ibilities of each party, notifiçCition of security
purchCiseS, sCiles, delivery, repurchase agreements, wire transfers, sCifekeeping and
trans9ction costs, procedures in case of wire failure or other unforeseen mishaps including
liability of, each party.
XI. MASTER REPURCHASE AGREEMENT
The Clerk of the Court will require CiIlClpproved institutions Cind dealers transacting
repurchCise Cigreements to execute andPerfort¡\ CiS stated in theMCister Repurchase
Agreement. All repurchase CigreementtrCinsCiçtions will Cidhere to requi.rements of the
MCister Repurchase Agreement. The c¡greemeOtsl)Ci1' specify that the underlying securities
have a mCirket VCilue of at leCist 1037. of the principal balance of the investment. The
market value is to be determined on a monthly basis.
XII. BID REQUIREMENT
Although in most situations the competitive bid process shCiIl be utilized, there is no
9bligCiti9n t9 secure competitive bids from all finCinciCiI institutions Cinddealer/brokers on
thec¡pproved list. Rather a decision will be mCide by the Clerk of the Court through the
finance Director as to the institutions that have been the most competitive over the
preceding weeks and these will be contacted for a bid.
A. After the Clerk of the Court, through the Finance Direçtor,hCis<petert¡\ined
the approximCite maturity date based on the cash flow needs and marketconditi90sand has
anCilyzed and selected one or more optimal types of investments, a minimum of three (3)
qualified banks and/or dealers will be contacted and asked to provide bids on the securities
in question.
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1. Bids will be held in confidence until the highest bid is determined and
awarded.
2. Documentation will be retained for all bids, with the winning bid
clearly identified.
3. If for any reason the highest interest rate bid was not selected, then
the reasons leading to that decision will be clearly indicated on the bid form.
4, If the maturing investment is funds to be invested are from a
certificate of deposit, the present holder of the funds issuer of the CD will be one of the
contacts made, subject to the portfolio diversification requirements in this policy.
5. In certain circumstonceswhere a dealer or bank informs the County
of a potential sale that must be completed within minutes of notification, the competitive
bidding policy will be waived, The Clerk of the Court will have final approval on these
particular transactions before they have been completed.
6. Notwithstanding the above, in order to afford financial institutions
(banks and/or savings and loan associations)within St. Lucie County opportunities to
enhc::¡nce the economy of the local Qrea, certificates of deposit may be purchQsed from an
institutionQs described in Section V.F provided that the following additional conditions
have been satisfied:
a. The institution, or a branch office, is located within the
boundaries of St. Lucie County.
b. The institution has the highest and best bid of all bidding
institutions as described in Section V.F.
c. The institution awarded the bid is subject to the portfolio
limitation requirements and may not exceed said limitations.
d. Banks/savings and loan associations included on the approved
list must be Qualified Public Depositories, as determined by the State of Florida.
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XIII. INTERNAL CONTROLS
The Clerk of the Court shall exercise and monitor a set of internal controls to be
conqucted through the Finance Director, which said controls are designed to protect the
County's funqs And ensure proper accounting and reporting of the securities trAnsactions.
The investment policy shall provide for review of such controls by independent auditors as
part of any financial audit periodically required of the unit of local government. Such
internal controls shall consist of the following:
A. All securities purchased or sold willÞe transferred only under the "delivery
versus payment" CD.V.P.) method to ensure that funds or securities are not released until
all criteria relating to the spedfic transaction are met.
B. The Clerk of the Court is authorized to accept, on behalf of and in the name
of St, Lude County, bank trust receipts or confirmAtions as evidence of actuAl delivery of
the obligation or securities in return for investment of funds.
C. Trust receipts or confirmAtions shAll fully describe the various obligAtions or
securities held. The receipt or confirmation shall stAte thAt the investment is held in the
name of St. Lude County.
D. Written documentAtion and/or confirmation of telephone trAnsactions And
wire transfers will be maintained.
E. There will be adequate separAtion of duties with dear delegation of
authority among investment personnel.
F. Custodial sAfekeeping shAll be properly utilized.
G. Operation review and performance evaluations and reporting, interim and
annual, shall be done by the Finance Director.
H. There will be an avoidance of no bearer-form securities.
1. There will be no physical delivery of securities.
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J. There will be specific limitations regarding securities losses and remedial
action shall be taken as soon as possible.
K. A development of a wire transfer agreement with the custodial bank
outlining the various controls and security provisions for making and receiving wire
transfers shall be made.
L. There is a prohibitic¡n of collusion between those making investment
decisions and those providing investment services,
M. Written dealer confirmation and monthly and/or quarterly custodial account
statements shall be maintained.
N. Investment policy shall be:establishl::~ by the Board of County Commissioners
conside:ring the: recomme:ndations of the Investment Committee. All daily investment
activity willbe coordinated and reviewed by the Finance Director. In the abSence of the
Financ.e Director and Clerk of the Court investlTlent activity must be approved by their
designee and later approved by the Finance Director or Clerk of the Court.
O. The following positions are designated by the Clerk of the Court as having
the authority to initiate all investment activities:
1. Clerk of the Court
2. Finance Director
3. All other designees will be at the discretion of the Clerk of the Court
P. All officials responsil;¡le for making. investment decisions, or the Finance
Director, shall complete 8 hours of continuing eciucation annually in subjects or courses of
study related to investment practices and products.
Q. Such additional internal controls as established by the Clerk of the Court.
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