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Printable Acrobat PDF file (152KB)
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Chapter I |
Purpose
The purpose of this Investment Policy (hereinafter “Policy”) is to set forth the investment objectives and parameters for the management of public funds for the Town of Ponce Inlet, Florida (hereinafter “Town”). This policy is designed to ensure the prudent management of public funds, the availability of operating and capital funds when needed, and an investment return competitive with comparable funds and financial market indices.
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Chapter II |
Scope
In accordance with Section 218.415, Florida Statues, this Policy applies to all cash and investments held or controlled by the Town with the exception of Pension Funds and funds related to the issuance of debt where there are other existing policies or indentures in effect for such funds. Funds held by state agencies (e.g., Department of Revenue) are not subject to the provisions of this policy.
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Investment Objectives
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Chapter IV |
Delegation of Authority
In accordance with the Charter of the Town of Ponce Inlet, the responsibility for providing oversight and direction in regard to the management of the investment program resides with the Town Manager. The daily management responsibility for all Town funds in the investment program and investment transactions is delegated to the Town Manager. The Town Manager shall establish written procedures for the operation of the investment portfolio and a system of internal accounting and administrative controls to regulate the activities of employees. The Town may employ an Investment Manager to assist in managing some of the Town’s portfolios. Such Investment Manager must be registered under the Investment Advisors Act of 1940.
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Standards of Prudence
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Chapter VI |
Ethics and Conflicts of Interest
Employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. Also, employees involved in the investment process shall disclose to the Town Manager and the Mayor any material financial interests in financial institutions that conduct business with the Town, and they shall further disclose any material personal financial/investment positions that could be related to the performance of the Town’s investment program.
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Chapter VII |
Internal Controls and Investment Procedures
The Town Manager shall establish a system of internal controls and operational procedures that are in writing and made a part of the Town’s operational procedures. The internal controls should be designed to prevent losses of funds, which might arise from fraud, employee error and misrepresentation by third parties, or imprudent actions by employees. The written procedures should include reference to safekeeping, repurchase agreements, separation of transaction authority from accounting and recordkeeping, wire transfer agreements, banking service contracts and collateral/depository agreements. No person may engage in an investment transaction except as authorized under the terms of this policy.
Independent auditors as a normal part of the annual financial audit to the Town shall conduct a review of the system of internal controls to ensure compliance with policies and procedures.
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Chapter VIII |
Continuing Education
The Town Manager and other appropriate staff shall annually complete 8 hours of continuing education in subjects or courses of study related to investment practices and products.
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Chapter IX |
Authorized Investment Institutions and Dealers
Authorized Town staff and Investment Advisors shall only purchase securities from financial institutions, which are qualified as public depositories by the Treasurer of the State of Florida, institutions designated as “Primary Securities Dealers” by the Federal Reserve Bank of New York, or from direct issuers of commercial paper and bankers’ acceptances.
Authorized Town staff and Investment Advisors shall only enter into repurchase agreements with financial institutions that are state qualified public depositories and primary securities dealers as designated by the Federal Reserve Bank of New York.
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Chapter X |
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 of current operating funds shall have maturities of no longer than twenty-four (24) months.
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 (5) years.
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Competitive Selection of Investment Instruments
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Chapter XIII |
Derivatives and Reverse Repurchase Agreements
Investment in any derivative products or the use of reverse repurchase agreements are specifically prohibited by this investment policy. A “derivative” is defined as a financial instrument the value of which depends on, or is derived from, the value of one or more underlying assets or indices or asset values.
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Performance Measurements
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Reporting
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Third Party Custodial Agreements
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Investment Policy Adoption
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Glossary of Cash and Investment Management Terms
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