HomeMy WebLinkAbout18-169RESOLUTION NO. 18-169
A RESOLUTION AMENDING THE INVESTMENT POLICY
FOR ST. LUCIE COUNTY, FLORIDA; BY FURTHER
AMENDING THE INVESTMENT POLICY
WHEREAS, the Board of County Commissioners of St. Lucie County, Florida, has made the
following determinations:
1. Pursuant to Section 218.415, Florida Statutes, on or before October 1, 1995, counties
that have custody of public funds in excess of the amounts needed to meet current expenses who elect
to conduct investment activity themselves rather than depositing these funds in the Local Government
Surplus Funds Trust Fund for investment by the State Board of Administration, are required to conduct
such investment activity in accordance with a written investment plan and an investment policy adopted
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 adopted an
investment policy as recommended by the Investment Subcommittee of the St. Lucie County Citizens
Budget Review Committee.
3. On December 6, 1995, the Investment Committee recommended that the Board adopt
certain amendments to the investment policy; and on January 2, 1996, the Board adopted Resolution
No. 95-275 which amended the investment policy and incorporated the recommended changes of the
Investment Committee.
4. The Board has previously amended the policy and plans to further amend the policy in
the future.
NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of St. Lucie County,
Florida:
1. This Board does hereby adopt the amendments to the investment policy attached
hereto and made a part hereof as Exhibit "A," pursuant to Section 218.415, Florida Statutes.
2. Except as amended herein, the remaining terms and conditions of the Investment
Policy, 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:
Chair Frannie Hutchinson AYE
Vice Chair Linda Bartz AYE
Commissioner Chris Dzadovsky AYE
Commissioner Anthony Bonna AYE
Commissioner Cathy Townsend AYE
PASSED AND DULY ADOPTED this 18th day of September 2018.
ATTEST:
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BOARD OF COUNTY COMMISSIONERS
ST. LUCIE COUNTY, FLORIDA
CHAIR
APPROVED S TO LEGA RM AND
CORRECTNE W.
COUNTY AYTORIiEY
WWI
SCOPE..................................................................................................................................2
II.
INVESTMENT OBJECTIVES...................................................................................................
2
COUNTY
DELEGATION OF AUTHORITY..............................................................................................
2
IV.
INVESTMENT PERFORMANCE AND REPORTING .................................................. I.............
f
1
a.
R
I Q A
ST. LUCIE COUNTY BOARD OF COUNTY COMMISSIONERS
INVESTMENT POLICY
TABLE OF CONTENTS
I.
SCOPE..................................................................................................................................2
II.
INVESTMENT OBJECTIVES...................................................................................................
2
III.
DELEGATION OF AUTHORITY..............................................................................................
2
IV.
INVESTMENT PERFORMANCE AND REPORTING .................................................. I.............
3
V.
PERFORMANCE MEASUREMENT....................................................................................
3-4
VI.
PRUDENCE AND ETHICAL STANDARDS..............................................................................
4
VII.
AUTHORIZED INVESTMENTS...........................................................................................4-6
VIII.
MATURITY AND LIQUIDITY REQUIREMENTS...................................................................... 7
IX.
PORTFOLIO COMPOSITION........................................................................................... 7-11
X.
RISK AND DIVERSIFICATION............................................................................................. 11
XI.
AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS .........................................
11-12
XII.
THIRD PARTY CUSTODIAL AGREEMENTS.........................................................................
12
XIII.
MASTER REPURCHASE AGREEMENT...........................................................................
12-13
XIV.
BID REQUIREMENT......................................................................................................
13-14
XV.
INTERNAL CONTROLS..................................................................................................14-15
Investment Policy to be Approved September 18, 2018
SCOPE
This investment policy applies to all surplus funds held by or for the benefit of the St. Lucie
County Board of County Commissioners, hereinafter referred to as the County.
These policies were adopted using Sections 125.31 and 218.415, Florida Statutes. Bond
proceeds may be further limited or expanded by their respective bond resolutions or
covenants and shall not be considered to be in conflict with the Investment Policy.
II. INVESTMENT OBJECTIVES
The County shall strive to achieve with each investment opportunity, the following
objectives, in ORDER OF PRIORITY.,
1. SAFETY -The primary objective of the County's investment activities is the protection
of investment capital.
2. LIQUIDITY -The County's investment strategy will provide sufficient liquidity such that
cash flow requirements are met through the utilization of marketable securities with
structured maturities.
3. INVESTMENT INCOME - In investing public funds, the County will strive to maximize
the return on the portfolio but will minimize investment risk.
III. DELEGATION OF AUTHORITY
The responsibility for providing oversight and direction in regard to the management of
the investment program resides with the Clerk of the Circuit Court. The Board of County
Commissioners will appoint an Investment Committee that will serve in an advisory
capacity and report to the Board of County Commissioners. Each Commissioner will select
one of the five Investment Committee members who will possess relevant financial
experience. The Investment Committee shall meet quarterly to review the Clerk's
investment strategy and results. The Investment Committee will rely on the Clerk of the
Circuit Court, the Finance Director and their staff for support. The management
responsibility for all Board's funds in the investment program and investment
transactions is delegated to the Clerk of Circuit Court or designee. The Clerk of the Circuit
Court or designee shall establish written procedures for the operation of the investment
portfolio and a system of internal accounting and administrative controls to regulate the
investment activities. The Clerk may employ investment manager(s) to assist in managing
some of the Board's investment portfolio. Such investment manager must be registered
under the Investment Advisors Act of 1940.
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IV. INVESTMENT PERFORMANCE AND REPORTING
A portfolio report shall be prepared each quarter by the Finance Director or designated
staff member, and be provided to the Clerk of the Circuit Court and appropriate
management staff. The report will also be made available 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 Investment Committee on a
quarterly basis. The report shall include information relating to transactions, market
values, performance and adherence to policy. The Clerk of the Circuit Court is authorized
to utilize an investment accounting service to obtain necessary information. The Board of
County Commissioners will conduct an annual review of the investment portfolio and the
investment policy.
The Board of County Commissioners will appoint an Investment Committee that will serve
in an advisory capacity and report to the Board of County Commissioners. Each
Commissioner will select one of the five Investment Committee members who will
possess relevant financial experience. The Investment Committee and the Board of
County Commissioners shall receive a copy of the portfolio pricing analysis.
The Clerk of the Circuit Court shall be notified immediately upon exceptions from
currently approved investment policies by the Finance Director.
In the event of an emergency situation requiring noncompliance with policy guidelines,
the Finance Director shall attempt to schedule a special committee meetingto discussthe
proposed action. if a special committee meeting is not possible due to time constraints
or scheduling problems, the Finance Director shall individually notify a minimum of three
committee members to obtain approval of the proposed action.
V. PERFORMANCE MEASUREMENT
In order to assist in the evaluation of the portfolio's performance, the Finance Director
will use performance benchmarks. The use of benchmarks will allow the Finance Director
to measure its returns against other investors in the same markets.
A. Investment performance of funds designated as short-term funds and other funds
that must maintain a high degree of liquidity will be compared to the return of the
S&P Rated GIP Index Government 30 -Day Gross of Fees Yield. Investments of current
operating funds shall have maturities of no longer than twenty-four (24) months.
B. Investment performance of funds designated as core funds and other non-operating
funds that have a longer-term investment horizon will be compared to the following
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indexes:
1. ICE Bank of America Merrill Lynch 1-3 Year U.S. Treasury/Agency Index
2. ICE Bank of America Merrill Lynch 1-5 Year U.S. Treasury/Agency Index
3. ICE Bank of America Merrill Lynch 1-5 Year Government/Corporate "A" rated or
better index
The appropriate index will have a duration and asset mix that approximates the
portfolio and will be utilized as a benchmark to be compared to the portfolio's total
rate of return. Investments of bond reserves, construction funds, and other non-
operating funds ("core funds") shall have a term appropriate to the need for funds
and in accordance with debt covenants, but in no event shall exceed five and one-
half (5.5) years.
C. The Equities, Mutual Funds and/or exchange -traded funds (ETFs) performance shall
be compared on a quarterly basis to appropriate peer universe benchmarks, as well
as market indices in the equity markets. Examples of benchmarks and indexes that
will be used include the Russell 3000 Index for broad U.S. equity strategies; S&P 500
Index for large cap U.S. equities, Russell 2000 Index for small cap U.S. equities, MSCI
ACWI ex -U.S. Index for broad based non -U.S. equity strategies. The Russell 3000
Index will be used to benchmark the U.S. equities portfolio; the MSCI ACWI ex -U.S.
Index will be used to benchmark the non -U.S. equities portfolio.
VI. PRUDENCE AND ETHICAL STANDARDS
The "prudent person" standard shall be used in the management of the overall
investment portfolio.
The Finance Director, and other persons performing the investment function, shall act as
a "prudent person" in accordance with these written policies and procedures, exercising
due diligence and investing in investments authorized by law.
The "prudent person" standard is herewith understood to mean the following:
Investments shall be made with judgment and care, under circumstances then prevailing,
which persons of prudence, discretion, and intelligence exercise in the management of
their own affairs, not for speculation, but for investment, considering the probable safety
of their capital as well as the probable income to be derived.
VII. AUTHORIZED INVESTMENTS
The Clerk of the Circuit 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. The Intergovernmental Investment Pool rated "AAAm" by Standard & Poor's or the
equivalent by another nationally recognized self-regulatory organization (NRSRO) for
a stable Net Asset Value (NAV) fund. If the stable NAV fund has no rating then the
underlying securities must be either FDIC insured; collateralized under the Florida
Security for Public Deposits Act, Chapter 280, Florida Statutes; or have a long term
rating of "A" or better by a nationally recognized rating agency. For a floating NAV
fund, the minimum rating will be AAf/S1 or the equivalent by a nationally recognized
rating agency.
B. Negotiable direct obligations of, or obligations the principal and interest of which are
unconditionally guaranteed by the United States Government. Such securities will
include, but not be limited to, the following:
1. Treasury Bills
2. Treasury Notes
3. Treasury Bonds
C. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by
United States agencies provided such obligations are backed by the full faith and
credit of the United States Government. Such securities will include, but not be
limited to, the following:
1. Farmers Home Administration
2. Government National Mortgage Association (GNMA)
D. Bonds, debentures, notes of or other evidence of indebtedness issued or guaranteed
by United States Government agencies (Federal Instrumentalities) which are not
backed by the full faith and credit of the United States Government. Such securities
will include, but not be limited to, the following:
1. Federal Farm Credit Bank (FFCB)
2. Federal Home Loan Bank or its district banks (FHLB)
3. Federal National Mortgage Association (FNMA)
4. Federal Home Loan Mortgage Corporation (Freddie -Mac)
E. Non-negotiable interest-bearing time certificates of deposit, money market accounts
or savings accounts in financial institutions organized under the laws of the United
States, doing business and situated in this state, provided that any such deposits are
secured by the Florida Security for Public Deposits Act, Chapter 280, Florida Statutes.
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F. Repurchase agreements collateralized by Treasury Bills or Notes having a maturity of
two (2) years or less.
G. Securities and Exchange Commission registered money market funds with the highest
credit quality rating from a nationally recognized rating agency.
H. Corporate Obligations or Corporate Notes of U.S. Corporations with at least two of
the following three minimum ratings: A- by Standard & Poor s, A3 by Moody's, or A -
by Fitch.
Commercial Paper denominated in United States dollars that is rated, at the time of
purchase, Prime -1 by Moody's and A-1 by Standard & Poor's (Prime Commercial
Paper). If the Commercial Paper is backed by a letter of credit (LOC), the long-term
debt of the LOC provider must be rated A or better by at least two nationally
recognized rating agencies.
Supranational Agencies — Debt obligations issued by multilateral organization of
governments of which the U.S. is a shareholder and voting member, and are
denominated in U.S. dollars, with highest Short -Term or Long -Term rating (A -1+/P-1,
AAA/Aaa, or equivalent). Purchase authorization includes, but is not limited to,
obligations of the following multilateral organizations:
1. International Bank for Reconstruction and Development (IBRD)
2. International Finance Corporation (IFC)
3. European Bank for Reconstruction and Development (EBRD)
4. Inter -American Development Bank (IADB)
5. Asian Development Bank (ADB)
5. African Development Bank (AFDB)
K. Asset -Backed Securities (ABS) — Approved Securitization Types are Auto Loans, Auto
Leases, Credit Cards, Rate Reduction Bonds, Equipment Trusts, and Cell Phone
Receivables. Deal size at issue must be at least $300 million. ABS must be AAA rated
by at least two nationally recognized rating agencies.
L. Equities, Mutual Funds and/or exchange -traded funds (ETFs) — Equities, shares in
open-end and no-load equity and/or fixed-income mutual funds, and/or ETFs.
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 underlying 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
ceiling contracts, and linked index investments.
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VIII. MATURITY AND LIQUIDITY REQUIREMENTS
To the extent possible, an attempt will be made to match investment maturities with
known cash needs and anticipated cash flow requirements. Investments, including
investment pools, of current operating funds shall have maturities of up to five and one-
half (5.5) years except the Corporate Obligations. The maximum length to maturity for
Corporate Obligations or Corporate Notes shall be five (5) years from the date of
purchase. The Finance Director and other persons performing the investment function
will provide an appropriate mix of maturities to maximize the return on the portfolio while
minimizing investment risk. Investment of bond reserves, construction funds, and other
non-operating funds shall have a term appropriate to the need for funds, and in
accordance with debt covenants, but shall not exceed five and one-half (5.5) years, unless
permitted by the terms of the bond documents.
Equities, Mutual Funds and/or exchange -traded funds (ETFs) are excluded from the
maximum maturity limitations due to the nature of these types of investments.
A liquidity amount of approximately three (3) months of anticipated disbursements,
excluding bond construction payments or other bond payments made from escrow or
trust accounts, will be kept in relatively short-term investments. These would include the
State Investment Pool (SBA), "Florida Trust", money market accounts and Repurchase
Agreements.
IX. PORTFOLIO COMPOSITION
The following are the guidelines for investments and limits on security issues, issuers, and
maturities as established by the County. The Finance Director, or their_ appropriate
designee, after consulting with the Clerk of Circuit Court, shall have the option to further
restrict or increase investment percentages from time to time based on market
conditions. Purchases of investments based on bond covenant requirements shall not be
included in the portfolio composition calculation. The allowable maximum percentage
requirements should be based on the prior month portfolio ending balance. If the
maximum percentage is exceeded for any reason, corrective action should be taken
within 30 days of any notice of violation to conform the portfolio to the allowable
percentages.
The following maximum limits are guidelines established for diversification by instrument:
Authorized Investment- Sector Type
Maximum
Allocation
Individual
Issuer
Limit
Maximum
Length to
Maturity_
Intergovernmental Investment Pool
40%
25%
N/A
Certificates of Deposit
40%
10%
2 years
Treasuries
75%
N/A
5.5 years
United States Government Agencies
50%
25%
5.5 years
Federal Instrumentalities (United States
Government Sponsored Agencies)
50%
25%
5.5 years
Repurchase Agreement
10%
10%
1 ear
Money Market Funds
80%
25%
N/A
Corporate Obligations or Corporate Notes
25%
5%
5 years
Commercial Paper
25%
5%
270 days
5u ranational Agencies
25%
10%
5.5 years
Asset Backed Securities
10%
3%
5.5 years
Equities, Mutual Funds and/or ETFs
X10%
N/A
N/A
A. The Intergovernmental Investment Pool
1. A maximum of 40% of the portfolio may be invested in Intergovernmental
Investment Pool.
2. A maximum of 25% of the portfolio maybe invested in anyone pool.
B. Non-negotiable Interest -Bearing Time Certificates of Deposit
1. A maximum of 40% of the portfolio may be invested in non-negotiable interest
bearing time certificates of deposit or savings accounts.
2. The maximum maturity on any certificates shall be no greater than two (2) years
from the time of purchase.
3. A maximum of 10% of the portfolio may be deposited in the instruments of any
one issuer.
C. United States Government Securities
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1. A maximum of 75% of the portfolio maybe invested in United States 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.
2. The maximum length of maturity of any direct investment in government
securities is five (5) years.
D. United States Federal Agencies
1. A maximum of 50% of the portfolio may be invested in United States Federal
Agency securities which are backed by the full faith and credit of the United States
Government.
2. The maximum length of maturity of any direct investment in Federal Agencies
Securities is five (5) years.
3. A maximum of 25% of the portfolio maybe invested in the instruments of anyone
issuer.
E. Federal Instrumentalities
1. A maximum of 50% of the portfolio may be invested in Federal Instrumentalities
which are not full -faith and credit United States Government Agencies.
2. The maximum length of maturity of any direct investment in Federal
Instrumentalities is five (5) years.
3. A maximum of 25% of the portfolio maybe invested in the instruments of anyone
issuer.
F. Repurchase Agreements
1. A maximum of 10% 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%.
2. The maximum term of a repurchase agreement will be one (1) year.
4. A maximum of 10% of the portfolio maybe invested in the instruments of anyone
issuer with the exception of one (1) business day agreements and overnight sweep
agreements which may go as high as 25%.
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G. Money Market Funds
1. A maximum of 80% of the portfolio maybe invested in institutional money market
funds.
2. Money market funds must have an "AAA" rating from Moody's, Standard and
Poor's or Fitch.
3. A maximum of 25% of the portfolio may be invested in any one money market
fund.
H. Corporate Obligations or Corporate Notes
1. A maximum of 25% of available funds maybe invested incorporate obligations or
corporate notes.
2. A maximum of 5% of available funds maybe invested in with anyone issuer.
3. The maximum length of maturity of any Corporate Obligations or Corporate Notes
is five (5) years.
L Commercial Paper
1. A maximum of 25% of available funds may be directly invested in Prime
Commercial Paper.
2. A maximum of 5% of available funds maybe invested with anyone issuer.
3. The maximum length to maturity for Prime Commercial Paper shall be 270 days
from the date of purchase.
J. Supranational Agencies
1. A maximum of 25% of available funds may be directly invested in Supranational
Agencies.
2. A maximum of 10% of available funds may be invested with any one issuer.
3. The maximum length of maturity of any Supranational Agency is five (5) years.
K. Asset Backed Securities
1. A maximum of 10% of available funds maybe invested in Asset Backed Securities.
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X.
XI
L
2. A maximum of 3% of available funds maybe invested with anyone issuer.
3. The maximum length of maturity for Asset Backed Securities is 5.5 years from the
date of purchase —the weighted average maturity will be used instead of the final
maturity date for maturity guideline purposes.
Equities, Mutual Funds and/or ETFs
1. A maximum of "°b 10% of available funds may be directly invested in equities,
mutual funds and/or ETFs.
2. The County believes that to achieve the greatest likelihood of meeting the
investment objectives and the best balance between risk and return for
optimal diversification, assets will be invested in accordance with the targets
for each asset class as follows to achieve an average total annual rate of return
that is equal to or greater than the benchmark.
Asset Weightings
Asset Classes Range Tar et*
Domestic Equity +/-1.5% 3.3%
International (non -US) Equity +/-1.5% 1.7%
*The targets are based on a strategic allocation of 66% in Domestic Equity and 34% in
International Equity. This may be adjusted from time -to -time to reflect the prevailing
market.
RISK AND DIVERSIFICATION
Assets held shall be diversified to control the risk of loss resulting from the over
concentration of assets in a specific maturity, issuer, instrument, dealer, or bank through
which these instruments are bought and sold. Diversification strategies within the
established guidelines shall be reviewed and revised periodically as necessary by the
appropriate management staff.
AUTHORIZED INVESTMENT INSTITUTIONS AND DEALERS
The County shall only purchase securities from financial institutions which have offices
located within the State of Florida and are qualified as public depositories by the
Treasurer of the State of Florida, from primary securities brokers/dealers designated by
the Federal Reserve Bank of New York or from secondary brokers/dealers, with an office
located in the State of Florida. Such specified brokers/dealers must be reviewed and
approved by the Investment Committee and approved by the Board of County
Commissioners.
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Documented lists of the authorized financial institutions and brokers/dealers will be
developed and maintained by the Finance Director and approved by the Clerk of the
Circuit Court.
Investments in equities, mutual funds and/or ETFs are excluded from the broker/dealer
requirements.
The restriction on the secondary brokers/dealers with an office located in the State of
Florida does not apply to the external investment managers. The purpose is to provide
greater flexibility in seeking better pricing and optimize interest income to the County
within the guidelines set forth in this policy.
If at any time the Clerk of the Circuit Court is appropriately notified of any threat to the
integrity of the investment portfolio, proper security measures may be suggested and
implemented, and the Clerk of the Circuit Court shall 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 secondary brokers/dealers, or Qualified Public Depository
financial institutions. A written Master Repurchase Agreement will be negotiated with
any institutions with which the County through the Clerk of the Circuit Court enters into
a specific repurchase agreement.
XII. THIRD PARTY CUSTODIAL AGREEMENTS
The Clerk of the Circuit Court will execute a Third Party Custodial safekeeping Agreement
with a commercial bank's trust department which is separately chartered by the United
States Government or the State of Florida. All securities purchased and/or collateral
obtained by the Clerk of the Circuit Court shall be properly designated as an asset of the
County and held in safekeeping by the trust department and no withdrawal of such
securities, in whole or in part, shall be made from safekeeping except by an authorized
staff member. The Third Party Custodial Safekeeping Agreement shall include letters of
authority from the Clerk of the Circuit Court, details as to responsibilities of each party,
notification of security purchases, sales, delivery, repurchase agreements, wire transfers,
safekeeping and transaction costs, procedures in case of wire failure or other unforeseen
mishaps including liability of, each party.
XIII. MASTER REPURCHASE AGREEMENT
The Clerk of the Circuit Court will require all approved institutions and dealers transacting
repurchase agreements to execute and perform as stated in the Master Repurchase
Agreement. All repurchase agreement transactions will adhere to requirements of the
Master Repurchase Agreement. The agreement shall specify that the underlying
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securities have a market value of at least 103% of the principal balance of the investment.
The market value is to be determined on a monthly basis.
XIV. BID REQUIREMENT
Although in most situations the competitive bid process shall be utilized, there is no
obligation to secure competitive bids from all financial institutions and dealer/brokers on
the approved list.
Rather a decision will be made by the Clerk of the Circuit 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.
After the Clerk of the Circuit Court, through the Finance Director, has determined the
approximate maturity date based on the cash flow needs and market conditions and has
analyzed 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.
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 in 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 circumstances where 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 Circuit Court will have final approval on these
particular transactions before they have been completed.
6. Investments in equities, mutual funds and/or ETFs are excluded from the minimum
three (3) bid requirement.
7. Notwithstanding the above, in order to afford financial institutions within St. Lucie
County opportunities to enhance the economy of the local area, certificates of deposit
may be purchased from an institution as described in Section VI.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.
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b. The institution has the highest and best bid of all bidding institutions as
described in Section VI.F.
c. The institution awarded the bid is subject to the portfolio limitation
requirements and may not exceed said limitations.
d. Financial institutions included on the approved list must be Qualified Public
Depositories, as determined by the State of Florida.
XV. INTERNAL CONTROLS
The Clerk of the Circuit Court shall exercise and monitor a set of internal controls to be
conducted through the Finance Director. Controls are designed to protect the County's funds 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 will be transferred only under the "delivery versus
payment" (D.V.P.) method to ensure that funds or securities are not released until all
criteria relating to the specific transaction are met.
B. The Clerk of the Circuit Court is authorized to accept, on behalf of and in the name of
St. Lucie 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. Lucie 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 clear 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.
I. 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 prohibition 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 established by the Board of County Commissioners
considering the recommendations of the Investment Committee. All daily investment
activity will be coordinated and reviewed by the Finance Director. In the absence of
the Finance Director and Clerk of the Circuit Court investment 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 Circuit Court as having the
authority to initiate all investment activities:
1. Clerk of the Circuit Court
2. Finance Director
3. All other designees will be at the discretion of the Clerk of the Circuit Court.
P. All officials responsible for making investment decisions, or the Finance Director, shall
complete 8 hours of continuing education 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 Circuit Court.
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