CCPD Resolution No. 76 RESOLUTION NO. 76
A RESOLUTION OF THE BOARD OF DIRECTORS OF THE BAYTOWN CRIME
CONTROL AND PREVENTION DISTRICT ADOPTING THE BAYTOWN CRIME
CONTROL AND PREVENTION DISTRICT'S INVESTMENT POLICY AND
STRATEGY STATEMENT; AND PROVIDING FOR THE EFFECTIVE DATE
THEREOF.
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BE IT RESOLVED BY THE BOARD OF DIRECTORS OF THE BAYTOWN CRIME CONTROL
AND PREVENTION DISTRICT:
Section 1: That the Board of Directors of the Baytown Crime Control and Prevention District
hereby acknowledges that it has reviewed the investment policy and strategy statement and that the written
instrument adopted in Section 2 hereof records any changes made to either the investment policy or strategy
statement.
Section 2: That the Board of Directors of the Baytown Crime Control and Prevention District
hereby adopts its investment policy, including the strategy statement therein, which is attached hereto as
Exhibit "A" and incorporated herein for all intents and purposes.
Section 3: This resolution shall take effect immediately from and after its passage by the Board
of Directors of the Baytown Crime Control and Prevention District.
INTRODUCED, READ and PASSED by the affirmative vote of the Board of Directors of the
Baytown Crime Control and Prevention District this the 12th day of October, 2021.
cg uji�
RIKKI WHEELER, President
ATTEST: ,
�s
ANGELA ACKSON, Secretary
APPROVED AS TO FORM:
KAREVE WRNER, General Counsel
RAKaren Anderson\RESOLUTIONS CCPD\2021.I0.12\Resolution-Adopt Investment Policy.docx
BAYTOWN CRIME .
CONTROL &
PREVENTION
DISTRICT
Investment Policy
Baytown Crime Control Prevention District
Investment Policy
Baytown Crime Control & Prevention District
Investment Policy
Table of Contents
I. Policy 1
II. Scope 1
III. General Objectives 1
A. Safety 1
B. Liquidity 2
C. Yield 2
IV. Standards of Care
A. Prudence 2
B. Ethics and Conflicts of Interest 3
C. Delegation of Authority 3
D. Training 3
V. Safekeeping and Custody
A. Authorized Financial Dealers and Institutions 4
B. Internal Controls 4
C. Delivery vs. Payment 5
VI. Suitable and Authorized Investments
A. Eligible Investments 5-13
B. Collateralization 13
C. Existing Investments 13
VII. Investment Parameters
A. Diversification 14
B. Maximum Maturities 14
VIII. Investment Strategies 14
IX. Reporting
A. Methods 14
B. Performance Standards 15
C. Marking to Market 15
EXHIBITS
A-Authorized Investment Officers 16
B - Statement of Ethics and Conflicts of Interest 17
C—Approved Broker/Dealers, Financial Institutions and Investment Pools 18
D—Certification by Business Organization 19
E—Investment Strategy 20-21
Baytown Crime Control Prevention District
Investment Policy
Baytown Crime Control & Prevention District
Investment Policy
I. Policy
It is the policy of the Baytown Crime Control & Prevention District (the "CCPD") to
administer and invest its funds in a manner that will preserve principal and maintain liquidity
while meeting the daily cash flow requirements of the CCPD. The CCPD will conform to all
federal, state and local statutes rules and regulations governing the investment of the CCPD's
funds.
The CCPD's policy is to hold investments to maturity, however, securities may be sold in
order to minimize the potential loss of principal on a security whose credit quality has
declined; to swap into another security which would improve the quality, yield or target
duration of the portfolio; or to meet unanticipated liquidity needs of the portfolio.
Not less than annually, the CCPD Board shall adopt a written instrument by resolution
stating that it has reviewed the Investment Policy and Investment Strategies and that the
written instrument so adopted shall record any changes made to the Investment Policy or
Investment Strategies.
II. Scope
This Investment Policy applies to all the investment activities of the CCPD. These funds are
accounted for in the CCPD's Annual Financial Report and include all financial assets of all
funds managed for CCPD by the City of Baytown, including but not limited to tax revenues,
charges for services, bond proceeds, and interest income.
III. General Objectives
The primary objectives, in priority order, of the CCPD's investment activities shall be safety,
liquidity, and yield:
A. Safety— 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 minimize credit risk
and interest rate risk.
1. Credit Risk—The CCPD will minimize credit risk, the risk of loss due to the
failure of the security issuer or backer, by:
(a) limiting investments to the safest types of securities;
(b) pre-qualifying the fmancial institutions, broker/dealers, intermediaries,
and advisers with which the CCPD will do business; and
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(c) diversifying the investment portfolio so that potential losses on
individual securities will be minimized
2. Interest Rate Risk—The CCPD will minimize the risk that the market value
of securities in the portfolio will fail due to changes in general interest rates,
by:
(a) Structuring the investment portfolio so that securities mature to meet
cash requirements for ongoing operations,thereby avoiding the need to
sell securities on the open market prior to maturity; and
(b) Investing operating funds primarily in shorter-term securities,money
market mutual funds, or similar investment pools
B. Liquidity —The investment portfolio shall remain sufficiently liquid to meet all
operating requirements that may be reasonably anticipated. This is accomplished
by structuring the portfolio so that securities mature concurrent with cash needs to
meet anticipated demands. Furthermore, since all possible cash demands cannot
be anticipated, the portfolio shall consist largely of securities with active
secondary or resale markets. A portion of the portfolio also may be placed in
money market mutual funds or local government investment pools that offer
same-day liquidity for short-term funds.
C. Yield —The investment portfolio shall be designed with the objective of attaining
a market rate of return throughout budgetary and economic cycles, taking into
account the investment risk constraints and liquidity needs. Return on investment
is of secondary importance compared to the safety and liquidity objectives
described above. The core of investments is limited to relatively low risk
securities in anticipation of earning a fair return relative to the risk being assumed.
Securities shall not be sold prior to maturity with the following exceptions:
1. A security with declining credit may be sold early to minimize loss of
principal; and
2. To swap into another security which would improve the quality, yield or
target duration of the portfolio; and
3. Liquidity needs of the portfolio require that the security be sold
IV. Standards of Care
A. Prudence — The standard of care to be used by investment officers shall be the
"prudent person" standard and shall be applied in the context of managing an
overall portfolio. Investment officers acting in accordance with written
procedures and the Investment Policy 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.
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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.
B. Ethics and Conflicts of Interest — Officers and employees involved in the
investment process shall refrain from personal business activity that could conflict
with proper execution and management of the investment program, or that could
impair their ability to make impartial investment decisions. Employees and
investment officers shall disclose to the CCPD and the Texas Ethics Commission
any material financial interests in financial institutions that conduct business with
the CCPD. They shall further file a disclosure statement with the Texas Ethics
Commission and the CCPD that includes any large personal financial/investment
positions that could be related to the performance of the investment portfolio. See
Exhibit B.
C. Delegation of Authority — City employees authorized to engage in investment
transactions and authorized as Investment Officers are the Director of Finance and
the Treasurer. Management responsibility for CCPD's investment program is
assigned to the Director of Finance. This authority is derived from the Local
Government Code Chapter 363. Responsibility for the operation of the
investment program is hereby delegated to the Director of Finance, who shall act
in accordance with established written procedures and internal controls for the
operation of the investment program consistent with this Investment Policy.
Procedures should include reference to: safekeeping, delivery vs. payment,
investment accounting, repurchase agreements, wire transfer agreements, and
collateral/depository agreements. Such procedures shall include explicit
delegation of authority to persons responsible for investment transactions. (See
Exhibit A) No person may engage in an investment transaction except as
provided under the terms of this policy and the procedures established by the
Director of Finance. The Director of Finance shall be responsible for all
transactions undertaken and shall establish a system of controls to regulate
activities of subordinate officers.
D. Training — Investment Officers shall attend at least one investment training
session within 12 months after taking office or assuming investment duties, and
shall attend investment training not less than once annually, beginning on the first
day of the CCPD's fiscal year and consisting of one (1) consecutive fiscal year
after that date, and receive not less than 10 hours of instruction relating to
investment responsibilities. The CCPD shall provide the training through courses
and seminars offered by professional organizations and associations in order to
ensure the quality and capability of the CCPD's investment personnel making
investment decisions in compliance with Public Funds Investment Act (PFIA).
Professional organizations and associations that may provide investment training
include the Government Treasurer's Organization of Texas, the University of
North Texas, the Government Finance Officers Association of Texas, the
Association for Financial Professionals, or the Texas Municipal League.
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V. Financial Institutions,Broker/Dealers, Safekeeping and Custody
A. Authorized Financial Dealers and Institutions — Investment Officers will
maintain a list of financial institutions, securities broker/dealers and business
organizations authorized to provide investment services (Exhibit Q. These may
include "primary" dealers or regional dealers. No public deposit shall be made
except in a qualified public depository as established by state law.
All financial institutions, broker/dealers, or business organizations who desire to
become qualified bidders for investment transactions must supply the Investment
Officer with the following as appropriate:
1. Audited financial statements
2. Proof of Financial Industry Regulatory Authority(FINRA) certification
3. Proof of state registration
4. Completed broker/dealer questionnaire(Exhibit D)
5. Certification by a qualified representative of the firm that the firm has a)
received and reviewed the CCPD's Investment Policy and b) has
implemented reasonable procedures and controls in an effort to preclude
investment transactions that are not authorized by the CCPD's Investment
Policy, except to the extent that this authorization is dependent on an
analysis of the makeup of the CCPD's entire portfolio or requires an
interpretation of subjective investment standards.
The CCPD Board shall at least annually review and/or revise and adopt a list of
qualified brokers that are authorized to engage in investment transactions with the
CCPD.
B. Internal Controls — The Director of Finance is responsible for establishing and
maintaining an internal control structure designed to ensure that the assets of the
CCPD 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.
Accordingly, the Director of Finance shall establish a process for an annual
independent review by an external auditor to assure compliance with policies and
procedures. The internal controls shall address the following points:
1. Control of collusion
2. Separation of transaction authority from accounting and record keeping
3. Custodial safekeeping
4. Avoidance of physical delivery securities
5. Clear delegation of authority to subordinate staff members
6. Written confirmation of transactions for investments and wire transfers
7. Development of a wire transfer agreement with the lead bank and third
party custodian
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C. Delivery vs. Payment—All trades where applicable will be executed by delivery
vs. payment (DVP) to ensure that securities are deposited in an eligible financial
institution prior to the release of funds. Securities and collateral will be held in
the CCPD's name by a third-party custodian as evidenced by safekeeping
receipts.
VI. Suitable and Authorized Investments
A. Eligible Investments — Assets of the CCPD may be invested in the following
instruments described below. All of these investments are authorized by Chapter
2256 of the Government Code(Public Funds Investment Act).
An investment that requires a minimum rating under this section does not qualify
as an authorized investment during the period the investment does not have the
minimum rating.
In order to monitor rating changes in investments acquired with public funds,
Investment Officers shall, on at least a monthly basis, verify the ratings of
investments currently held by the CCPD with either the authorized broker/dealer
from which the investment was purchased, or a broker/dealer currently authorized
to engage in investment transactions with the CCPD. As a condition of engaging
in investment transactions with the CCPD, brokers/dealers shall, when requested
by the CCPD's Investment Officer(s), provide said Investment Officer(s) with
written verification of the ratings of investments currently owned by the CCPD.
The CCPD shall take all prudent measures consistent with this Investment Policy
to liquidate an investment that does not have the minimum rating.
1. Obligations of, or Guaranteed by Governmental Entities
(a) Except as provided by Subsection (b), the following are authorized
investments under this subchapter:
(i) obligations, including letters of credit, of the United States or its
agencies and instrumentalities;
(ii) direct obligations of this state or its agencies and instrumentalities;
(iii)collateralized mortgage obligations directly issued by a federal
agency or instrumentality of the United States, the underlying
security for which is guaranteed by an agency or instrumentality of
the United States;
(iv) other obligations, the principal and interest of which are
unconditionally guaranteed or insured by, or backed by the full
faith and credit of this state or the United States or their respective
agencies and instrumentalities, including obligations that are fully
guaranteed or insured by the Federal Deposit Insurance
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Corporation or by the explicit full faith and credit of the United
States;
(v) obligations of states, agencies, counties, cities, and other political
subdivisions of any state rated as to investment quality by a
nationally recognized investment rating firm not less than A or its
equivalent; and
(b)The following are not authorized investments under this section:
(i) obligations whose payment represents the coupon payments on the
outstanding principal balance of the underlying mortgage-backed
security collateral and pays no principal;
(ii) obligations whose payment represents the principal stream of cash
flow from the underlying mortgage-backed security collateral and
bears no interest;
(iii) collateralized mortgage obligations that have a stated final maturity
date of greater than 10 years; and
(iv) collateralized mortgage obligations the interest rate of which is
determined by an index that adjusts opposite to the changes in a
market index.
2. Certificates of Deposit and Share Certificates
A certificate of deposit is an authorized investment under this subchapter if
the certificate is issued by a state or national bank domiciled in this state, a
savings bank domiciled in this state, or a state or federal credit union
domiciled in this state and is:
(i) guaranteed or insured by the Federal Deposit Insurance Corporation
or its successor or the National Credit Union Share Insurance Fund or
its successor;
(ii) secured by obligations that are described by Section l(a), including
mortgage backed securities directly issued by a federal agency or
instrumentality that have a market value of not less than the principal
amount of the certificates, but excluding those mortgage backed
securities of the nature described by Section 1(b); or
(iii) secured in any other manner and amount provided by law for
deposits of the CCPD.
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3. Repurchase Agreements
A fully collateralized repurchase agreement is an authorized investment under
this subchapter if the repurchase agreement:
(i)has a defined termination date;
(ii) is secured by a combination of cash and obligations described by
Section 1(a)(i); and
(iii) requires the securities being purchased by the CCPD or cash held by
the CCPD to be pledged to the CCPD, held in the CCPD's name,
and deposited at the time the investment is made with the CCPD or
with a third party selected and approved by the CCPD; and
(iv) is placed through a primary government securities dealer, as defined
by the Federal Reserve, or a financial institution doing business in
this state.
In this section, "repurchase agreement" means a simultaneous agreement to
buy, hold for a specified time, and sell back at a future date obligations
described by Section l(a)(i), at a market value at the time the funds are
disbursed of not less than the principal amount of the funds disbursed. The
term includes a direct security repurchase agreement and a reverse security
repurchase agreement.
Notwithstanding any other law, the term of any reverse security repurchase
agreement may not exceed 90 days after the date the reverse security
repurchase agreement is delivered.
Money received by CCPD under the terms of a reverse security repurchase
agreement shall be used to acquire additional authorized investments, but the
term of the authorized investments acquired must mature not later than the
expiration date stated in the reverse security repurchase agreement.
4. Banker's Acceptances
A bankers' acceptance is an authorized investment under this policy if the
bankers' acceptance:
(i) has a stated maturity of 270 days or fewer from the date of its
issuance;
(ii) will be, in accordance with its terms, liquidated in full at maturity;
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(iii) is eligible for collateral for borrowing from a Federal Reserve Bank;
and
(iv) is accepted by a bank organized and existing under the laws of the
United States or any state, if the short-term obligations of the bank,
or of a bank holding company of which the bank is the largest
subsidiary, are rated not less than A-1 or P-1 or an equivalent rating
by at least one nationally recognized credit rating agency.
5. Commercial Paper
Commercial paper is an authorized investment under this policy if the
commercial paper:
(i) has a stated maturity of 365 days or fewer from the date of its
issuance; and
(ii) is rated not less than A-1 or P-1 or an equivalent rating by at least:
(a) two nationally recognized credit rating agencies; or
(b) one nationally recognized credit rating agency and is
fully secured by an irrevocable letter of credit issued by a
bank organized and existing under the laws of the United
States or any state.
6. Mutual Funds
A no-load money market mutual fund is an authorized investment under
this subchapter if the mutual fund:
(i) is registered with and regulated by the Securities and Exchange
Commission;
(ii) provides the CCPD with a prospectus and other information
required by the Securities Exchange Act of 1934 (15 U.S.C.
Section 78a et seq.) or the Investment Company Act of 1940 (15
U.S.C. Section 80a-1 et seq.); and
(iii) complies with federal Securities and Exchange Commission Rule
2a-7 (17 C.F.R. Section 270.2a-7), promulgated under the
Investment Company Act of 1940 (15 U.S.C. Section 80a-1 et
seq.)
In addition to a no-load money market mutual fund permitted as an
authorized investment in Subsection (a), a no-load mutual fund is an
authorized investment under this subchapter if the mutual fund:
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(i) is registered with the Securities and Exchange Commission;
(ii) has an average weighted maturity of less than two years; and
(iii) either has a duration of one year or more and is invested
exclusively in obligations approved by this subchapter; or
(iv) has a duration of less than one year and the investment portfolio is
limited to investment grade securities, excluding asset-backed
securities
The CCPD is not authorized by this section to:
(i) invest in the aggregate more than 15 percent of its monthly average
fund balance, excluding bond proceeds and reserves and other
funds held for debt service, in mutual funds described in
Subsection(b);
(ii) invest any portion of bond proceeds, reserves and funds held for
debt service, in mutual funds described in Subsection(b); or
(iii) invest its funds or funds under its control, including bond proceeds
and reserves and other funds held for debt service, in any one
mutual fund described in Subsection (a) or (b) in an amount that
exceeds 10 percent of the total assets of the mutual fund.
7. Guaranteed Investment Contracts
A collateralized guaranteed investment contract is an authorized investment
for bond proceeds under this policy if the guaranteed investment contract:
(i) has a defined termination date;
(ii) is secured by direct and unsubordinated obligations described by
Section 2256.009(a)(1) of the Act, excluding those obligations
described by Section 2256.009(b) of the Act, in an amount at least
equal to the amount of bond proceeds invested under the contract;
and
(iii) is pledged to the CCPD and deposited with the CCPD or with a
third party selected and approved by the CCPD.
Bond proceeds, other than bond proceeds representing reserves and funds
maintained for debt service purposes, may not be invested under this policy in
a guaranteed investment contract with a term of longer than five years from
the date of issuance of the bonds.
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To be eligible as an authorized investment:
(i) the CCPD Board must specifically authorize guaranteed investment
contracts as an eligible investment in the order, ordinance, or
resolution authorizing the issuance of bonds;
(ii) the CCPD must receive bids from at least three separate providers
with no material financial interest in the bonds from which proceeds
were received;
(iii)the CCPD must purchase the highest yielding guaranteed investment
contract for which a qualifying bid is received;
(iv)the price of the guaranteed investment contract must take into
account the reasonably expected drawdown schedule for the bond
proceeds to be invested; and
(v) the provider must certify the administrative costs reasonably
expected to be paid to third parties in connection with the
guaranteed investment contract.
8. Investment Pools
The CCPD may invest its funds and funds under its control through an
eligible investment pool if the CCPD Board by rule, order, ordinance, or
resolution, as appropriate, authorizes investment in the particular pool. An
investment pool shall invest the funds it receives from entities in
authorized investments permitted by this subchapter. An investment pool
may invest its funds in money market mutual funds to the extent permitted
by and consistent with Subchapter A of the Texas Government Code,
Chapter 2256 and the investment policies and objectives adopted by the
investment pool.
To be eligible to receive funds from and invest funds on behalf of the
CCPD under this section, an investment pool must furnish to the
Investment Officer or other authorized representative of the CCPD an
offering circular or other similar disclosure instrument that contains, at a
minimum,the following information:
(i) the types of investments in which money is allowed to be invested;
(ii) the maximum average dollar-weighted maturity allowed, based on
the stated maturity date, of the pool;
(iii) the maximum stated maturity date any investment security within
the portfolio has;
(iv) the objectives of the pool;
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(v) the size of the pool;
(vi) the names of the members of the advisory board of the pool and
the dates their terms expire;
(vii) the custodian bank that will safekeep the pool's assets;
(viii) whether the intent of the pool is to maintain a net asset value of
one dollar and the risk of market price fluctuation;
(ix) whether the only source of payment is the assets of the pool at
market value or whether there is a secondary source of payment,
such as insurance or guarantees, and a description of the secondary
source of payment;
(x) the name and address of the independent auditor of the pool;
(xi) the requirements to be satisfied for an entity to deposit funds in and
withdraw funds from the pool and any deadlines or other operating
policies required for the entity to invest funds in and withdraw
funds from the pool; and
(xii) the performance history of the pool, including yield, average
dollar-weighted maturities, and expense ratios; and
(xii) the pool's policy regarding holding deposits in cash.
To maintain eligibility to receive funds from and invest funds on behalf of
the CCPD under this section, an investment pool must furnish to the
Investment Officer or other authorized representative of the CCPD:
(i) investment transaction confirmations; and
(ii) a monthly report that contains, at a minimum, the following
information:
(a) the types and percentage breakdown of securities in which the
pool is invested;
(b) the current average dollar-weighted maturity, based on the
stated maturity date, of the pool;
(c) the current percentage of the pool's portfolio in investments that
have stated maturities of more than one year;
(d) the book value versus the market value of the pool's portfolio,
using amortized cost valuation;
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(e)the size of the pool;
(f)the number of participants in the pool;
(g)the custodian bank that is safekeeping the assets of the pool;
(h) a listing of daily transaction activity of the entity participating
in the pool;
(i) the yield and expense ratio of the pool, including a statement
regarding how yield is calculated;
(j)the portfolio managers of the pool; and
(k) any changes or addenda to the offering circular.
The CCPD by contract may delegate to an investment pool the authority to
hold legal title as custodian of investments purchased with its local funds.
In this section, for purposes of an investment pool for which a $1.00 net
asset value is maintained, "yield" shall be calculated in accordance with
regulations governing the registration of open-end management
investment companies under the Investment Company Act of 1940, as
promulgated from time to time by the federal Securities and Exchange
Commission.
To be eligible to receive funds from and invest funds on behalf of the
CCPD under this section, a public funds investment pool that uses
amortized cost or fair value accounting must mark its portfolio to market
daily, and, to the extent reasonably possible, stabilize at a $1.00 net asset
value, when rounded and expressed to two decimal places. If the ratio of
the market value of the portfolio divided by the book value of the portfolio
is less than 0.995 or greater than 1.005, the governing body of the
investment pool must take action as the body determines necessary to
eliminate or reduce to the extent reasonably practicable any dilution or
unfair result to existing participants, including a sale of portfolio holdings
to attempt to maintain the ratio between 0.995 and 1.005. The public
funds investment pool must, in addition to the requirements of its
Investment Policy and any other forms of reporting, report yield to its
investors in accordance with regulations of the federal Securities and
Exchange Commission applicable to reporting by money market funds.
To be eligible to receive funds from and invest funds on behalf of the
CCPD under this section, a public funds investment pool must have an
advisory board composed:
(i) equally of participants in the pool and other persons who do not
have a business relationship with the pool and are qualified to
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advise the pool, for a public funds investment pool created under
Chapter 791 and managed by a state agency; or
(ii) of participants in the pool and other persons who do not have a
business relationship with the pool and are qualified to advise the
pool, for other investment pools.
To maintain eligibility to receive funds from and invest funds on behalf of
the CCPD under this section, an investment pool must be continuously
rated no lower than AAA or AAA-m or at an equivalent rating by at least
one nationally recognized rating service.
If the investment pool operates an Internet website, the information in a
disclosure instrument or report described in Subsections (b), (c)(2), and(f)
of Texas Government Code Chapter 2256, Subchapter A, Section
2256.016 must be posted on the website.
To maintain eligibility to receive funds from and invest funds on behalf of
the CCPD, an investment pool must make available to the CCPD an
annual audited financial statement of the investment pool in which the
CCPD has funds invested.
If an investment pool offers fee breakpoints based on fund balances
invested, the investment pool in advertising investment rates must include
either all levels of return based on the breakpoints provided or state the
lowest possible level of return based on the smallest level of funds
invested.
B. Collateralization — Collateralization will be required on three types of
investments: certificates of deposit, repurchase (and reverse repurchase)
agreements and guaranteed investment contracts (GICs). In order to anticipate
market changes and provide a level of security for all funds, the Collateralization
level will be one hundred two percent (102%) of market value of principal and
accrued interest. Pledged collateral shall consist of eligible U.S. Treasury
securities, eligible securities issued by U.S. Government Sponsored Enterprises,
or Federal Home Loan Bank Letters of Credit, or a combination thereof, and shall
be marked to market on at least a monthly basis.
Likewise, all time and demand deposits in excess of FDIC or NCUA insurance
levels shall be collateralized to a minimum of 102% of principal and accrued
interest. The depository shall be responsible for maintaining collateralization
margins. Collateral will be held in the City of Baytown's name (for the CCPD)
by an independent third party with whom the City of Baytown(for the CCPD) has
a current custodial agreement approved by the Council and executed under the
terms of FIRREA (Financial Institutions Reform, Recovery, and Enforcement
Act) as amended. A clearly marked evidence of ownership (safekeeping receipt)
must be supplied to the CCPD and retained. The right of collateral substitution is
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granted, subsequent to the review and approval of an authorized City of Baytown
Investment Officer.
C. Existing Investments — Any investment currently held that does not meet the
guidelines of this policy, but were authorized investments at the time of purchase,
is not required to be liquidated.
VII. Investment Parameters
A. Diversification — The investments shall be diversified by security type and
institution. With the exception of U.S. Treasury securities and authorized pools,
the CCPD will diversify the entire portfolio to comply with the investment
B. strategy; however, in no case shall any single investment transaction be more than
ten-percent(10%) of the entire portfolio.
C. Maximum Maturities —To the extent possible, the CCPD shall attempt to match
its investments with anticipated cash flow requirements. Unless matched to a
specific cash flow, the CCPD will not directly invest in securities maturing more
than five(5)years from the date of purchase.
VIII. Investment Strategies
The CCPD maintains separate portfolios for individual funds or groups of funds that
are managed according to the terms of this Policy and the corresponding investment
strategies listed in Exhibit E. The investment strategy for portfolios established after
the annual Investment Policy review and adoption will be managed in accordance
with the terms of this Policy and applicable agreements until the next annual review
when a specific strategy will be adopted.
The CCPD maintains a pooled fund group that is an aggregation of the majority of
CCPD funds including tax receipts, as well as some grant dollars and investment
income. This portfolio is maintained to meet budgeted funding obligations of the
CCPD. In order to ensure the ability of the CCPD to meet obligations and to
minimize potential liquidation losses, the dollar-weighted average stated maturity of
the Investment Pool shall not exceed 2 years. The objectives of this portfolio are to
ensure safety of principal; ensure adequate investment liquidity; limit market and
credit risk through diversification; and attain the best feasible yield in accordance
with the objectives and restrictions set for in this Policy
IX. Reporting
A. Methods — Investment officers shall jointly prepare an investment report at least
quarterly, including a management summary that provides an analysis of the
status of the current investment portfolio and transactions made over the last
quarter. This management summary will be prepared in a manner consistent
with the requirements of Section 2256.023 (Internal Management Reports) of the
PFIA, and that will allow the CCPD to ascertain whether investment activities
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Baytown Crime Control Prevention District
Investment Policy
during the reporting period have conformed to the Investment Policy. The report
should be provided to the CCPD Board.
An independent auditor shall formally review the quarterly reports prepared under
this section at least annually, and that auditor shall report the results of the review
to the CCPD Board.
B. Performance Standards — The investment portfolio shall be managed in
accordance with the objectives specified in this policy (safety, liquidity, yield).
The portfolio should obtain a market average rate of return during a
market/economic environment of stable interest rates. The basis used by the
Investment Officer to determine whether market yields are being achieved shall
be the three(3)month U.S. Treasury Bill.
C. Marking to Market — The market value of the portfolio shall be calculated at
least monthly and a statement of the market value of the portfolio shall be issued
at least quarterly. The market value of each investment shall be obtained from a
source such as the Wall Street Journal, a reputable brokerage firm or security
pricing service and reported on the investment reports.
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Baytown Crime Control Prevention District
Investment Policy
EXHIBIT A
Baytown Crime Control & Prevention District
Authorized Investment Officers
W. Victor Brownlees, City of Baytown Director of Finance
Monio Mark, City of Baytown Controller
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Baytown Crime Control Prevention District
Investment Policy
EXHIBIT B
Baytown Crime Control &Prevention District
Statement of Ethics and Conflicts of Interest
Investment Officers for the Baytown Crime Control & Prevention District shall refrain from personal
business relationships with business organizations that could conflict with the proper execution of the
investment program, or which could impair their ability to make impartial investment decisions. This
would only apply to personal business relationships with business organizations that have been approved
by the Board of Directors to conduct investment transactions with the Baytown Crime Control Prevention
District.
An investment official is considered to have a personal business relationship with a business
organization if:
(1) The investment official owns 10 percent or more of the voting stock or shares of the
business organization or owns$5,000 or more of the fair market value of the business.
(2) Funds received by the investment official from the business organization exceed 10
percent of the investment official's gross income for the previous year.
(3) The investment official has acquired from the business organization during the previous
year investments with a book value of$2,500 or more for the personal account of the
investment official.
I do hereby certify that I do not have a personal business relationship with any business organization
approved to conduct investment transactions with the Baytown Crime Control & Prevention District, nor
am I related within the second degree by affinity or consanguinity, as determined under Chapter 573 of
the Texas Government Code,to an individual seeking to sell an investment to the Baytown Crime Control
&Prevention District as of the date of this statement.
City of Baytown
Investment Officers
W.Victor Brownlees, Date
City of Baytown Director of Finance
Brent Yowell, Date
City of Baytown Treasurer
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Baytown Crime Control Prevention District
Investment Policy
EXHIBIT C
Baytown Crime Control &Prevention District
Approved Broker/Dealers, Financial Institutions and Investment Pools
Broker/Dealers
Cantor Fitzgerald&Co.
Wells Fargo Brokerage Services, LLC
Hilltop Securities, Inc.
Duncan-Williams, Inc.
Multi-Bank Securities, Inc.
Vining Sparks IBG, L.P.
FTN Financial
Raymond James&Associates, Inc.
RBC Capital Markets, LLC
Public Depository
JP Morgan Chase,NA(Primary)
Local Government investment Pools
TexPool
TexSTAR
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Baytown Crime Control Prevention District
Investment Policy
EXHIBIT D
Baytown Crime Control & Prevention District
Certification by Business Organization
date
Baytown Crime Control&Prevention District
C/O City of Baytown,Texas
(Attn:Designated Investment official)
P O Box 424
Baytown,TX 77522-0424
Dear Mr/s. (investment official):
This certification is executed on behalf of the Baytown Crime Control &Prevention District(the
Investor)and , (the Business Organization)
pursuant to the Public Funds Investment Act,Chapter 2256,Texas Government Code, (the Act)in
connection with investment transactions conducted between the Investor and Business Organization.
The undersigned Qualified Representative of the Business Organization hereby certifies on behalf of the
Business Organization that:
1. The undersigned is a Qualified Representative of the Business Organization offering to enter an
investment transaction with the Investor(Note: as such terms are used in the Public Funds Investment
Act,chapter 2256,Texas Local Government Code)and;
2. The Qualified Representative of the Business Organization has received and reviewed the Investment
Policy furnished by the Investor and, agrees, on behalf of the Business Organization, to comply with
its requirements under the Investment Policy and;
3. The Qualified Representative of the Business Organization has implemented reasonable procedures
and controls in an effort to preclude investment transactions conducted between the Business
Organization and the Investor that are not authorized by the Investor's Investment Policy, except to
the extent that this authorization is dependent on an analysis of the makeup of the investor's entire
portfolio or requires an interpretation of the subjective investment standards.
Qualified Representative of the Business Organization
Signed By:
Name
Title
Date
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Baytown Crime Control Prevention District
Investment Policy
EXHIBIT E
INVESTMENT STRATEGY
It is the policy of the Baytown Crime Control and Prevention District (the "CCPD") that, giving due
regard to the safety and risk of investments, all funds shall be invested at all times in conformance with
State and Federal statutes, applicable trust agreements or related bond document requirements, the
CCPD's adopted Investment Policy and this Investment Strategy. The CCPD's portfolio shall be
designed and managed in a manner responsive to the public trust and consistent with the Investment
Policy.
In accordance with the Public Funds Investment Act, CCPD investment strategies establish
maximum maturities and maximum dollar-weighted average maturity limits for each portfolio and
address the priorities for those funds(in order of priority):
• Suitability of the investment to the financial requirements of the CCPD and the particular Fund
Type;
• Preservation and safety of principal;
• Liquidity;
• Marketability of the investment if the need arises to liquidate the investment prior to maturity;
• Diversification of the investment portfolio;and
• Yield.
Effective investment strategy development coordinates the primary objectives of the CCPD's Investment
Policy and cash management procedures with investment security risk/retum analysis to enhance interest
earnings and reduce investment risk. The CCPD intends to generally utilize a buy and hold strategy but
will evaluate more active strategies, such as swaps or outright sales of securities, for incremental income
when appropriate. The structure of the portfolio(s)will be primarily dependent upon the continuing cash
flow requirements of the funds represented. The portfolio(s) will reflect both the short and long term
needs of the funds. A limited liquidity buffer will be maintained to cover any unanticipated cash needs,
where appropriate.
With a more active position, maturity selections may be extended to gain incremental income or adjust
portfolios to economic and market conditions. It is recognized that more active management may
increase the overall weighted average maturity of the portfolios due to additional volatility.
The CCPD's Investment Officer(s) shall monitor and evaluate the ongoing economic environment and
incorporate market information from reliable sources as well as current and anticipated CCPD financial
conditions when prudently implementing these strategies. Anticipated changes in the CCPD's Investment
Strategy shall be reported to the Board as part of the quarterly investment reporting.
The CCPD expects, but is not required by law, to consolidate and commingle funds from similar type
funds or all funds in an attempt to maximize investment earnings. Investment income by fund will be
recognized and allocated on a monthly basis based on respective fund balances for the period in
accordance with generally accepted accounting principles.
FUND TYPE IDENTIFICATION
Each major fund type has varying cash flow requirements and liquidity needs. Therefore, specific
strategies shall be implemented considering the fund type's unique requirements. CCPD funds shall be
analyzed and invested according to the following major fund types:
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Baytown Crime Control Prevention District
Investment Policy
a. Operating Funds
Operating funds have ongoing cash needs in support of ongoing operations and required transfers. Funds
include: General Fund.
b. Liquidity Buffer Accounts
Liquidity funds are to assure the CCPD's liquidity for anticipated and unanticipated needs within one
month. A liquidity buffer is needed in all but debt service funds which have well-defined and unalterable
liabilities.
INVESTMENT STRATEGY BY TYPE
In order to minimize market risks or principal loss due to interest rate fluctuations, investment maturities
and portfolio structures will be limited by the anticipated cash flow requirements of the various fund
types. The general investment strategies are established by fund type. The use of liquidity buffers in fund
types is to provide for unanticipated liabilities.
a. Operating Funds
The short term (one to six months) needs of the operating funds will generally be addressed through a
laddered portfolio and the longer term (six to twelve months) needs of the operating funds will be
structured in a more loosely structured ladder. Core funds, not intended for use within one year may be
extended to two years.
Operating Funds are designed to meet ongoing demands. The portfolio(s) will utilize high credit quality
securities with no perceived credit risk to meet those demands and assure liquidity if needed. Securities
with active and efficient secondary markets are necessary in the event of an unanticipated cash
requirement. Investment maturities shall be laddered based on the anticipated operating needs of the
CCPD. Market cycle risk will be reduced by diversifying the appropriate maturity structure. Operating
Funds require the greatest short-term liquidity of any of the fund types, investment pools and money
market mutual funds can provide daily liquidity.
Price volatility of the overall portfolio(s) will be minimized by requiring a maximum dollar-weighted
average days to maturity(WAM) for the Operating portfolio(s) of 180 days and restricting the maximum
allowable maturity to two years.
Attaining a competitive market yield is a desired objective. The yields on the six-month and one-year
Treasury Bills shall be the minimum yield objective and benchmarks for these funds in accordance with
their anticipated WAM restrictions.
b. Liquidity Buffer Accounts
A liquidity buffer, dependent in size upon then—current economic conditions and CCPD cash flow needs,
shall be maintained in Operating Funds to meet immediate cash needs of at least one month and provide
for reasonable, unanticipated liabilities. The maximum maturity of these liquid invested funds should be
one day. These funds may be invested in money market mutual funds, local government pools, or in a
depository overnight sweep.
21
10/8/21,10:11 AM Print Agenda Item Request
IOWAN
BAYTOWN CRIME CONTROL AND 3. a.
PREVENTION DISTRICT
Meeting Date: 10/12/2021
Consider the Approval of the Baytown CCPD Investment Policy and Strategy Statement.
Prepared For: Victor Brownlees, Finance Prepared By. Elizabeth Donato, Finance
Information
ITEM
This proposed resolution approves the Baytown Crime Control and Prevention District's Investment Policy and
Strategy Statement in accordance with the Public Funds Investment Act, Section 2256.005(e) for the addition
of an investment officer.
PREFACE
This proposed resolution approves the Baytown Crime Control and Prevention District's Investment Policy and
Strategy Statement in accordance with the Public Funds Investment Act, Section 2256.005(e) for(i) the
addition of an investment officer and(ii) the addition and deletion of broker/dealers.
RECOMMENDATION
Staff recommends approval.
Fiscal Impact
Fiscal Year:
Acct Code:
Source of Funds(Operating/Capital/Bonds
Funds Budgeted Y/N:
Amount Needed:
Fiscal Impact(Additional Information)_
There is no fiscal impact associated with this item.
Attachments
Exhibit A - Investment Policy and Strategy_
https:Hagendas.baytown.org/live/publish/print_ag_Memo.cfm?seq=20959&rev_num=0&mode=External&reloaded=true&id=0 119