HomeMy WebLinkAbout10-30-2025 IOC Agenda Packet
Investment Oversight Committee
AGENDA
Thursday, October 30, 2025, 10:30 a.m.
Conference Room 6 at City Hall, 990 Palm Street, San Luis Obispo
The Investment Oversight Commission holds in-person meetings. Zoom participation will not be
supported. Attendees of City Council or Advisory Body meetings are eligible to receive one hour of
complimentary parking; restrictions apply, visit Parking for Public Meetings for more details.
INSTRUCTIONS FOR PUBLIC COMMENT:
Public Comment prior to the meeting (must be received 3 hours in advance of the meeting):
Mail - Delivered by the U.S. Postal Service. Address letters to the City Clerk's Office at 990
Palm Street, San Luis Obispo, California, 93401.
Email - Submit Public Comments via email to advisorybodies@slocity.org. In the body of your
email, please include the date of the meeting and the item number (if applicable). Emails will not
be read aloud during the meeting.
Voicemail - Call (805) 781-7164 and leave a voicemail. Please state and spell your name, the
agenda item number you are calling about, and leave your comment. Verbal comments must be
limited to 3 minutes. Voicemails will not be played during the meeting.
*All correspondence will be archived and distributed to members, however, submissions received
after the deadline may not be processed until the following day.
Public Comment during the meeting:
Meetings are held in-person. To provide public comment during the meeting, you must be
present at the meeting location.
Electronic Visual Aid Presentation. To conform with the City's Network Access and Use Policy,
Chapter 1.3.8 of the Council Policies & Procedures Manual, members of the public who desire
to utilize electronic visual aids to supplement their oral presentation must provide display-ready
material to the City Clerk by 12:00 p.m. on the day of the meeting. Contact the City Clerk's
Office at cityclerk@slocity.org or (805) 781-7114.
Pages
1.CALL TO ORDER
Chair Emily Jackson will call the Regular Meeting of the Investment Oversight
Committee to order.
2.PUBLIC COMMENT FOR ITEMS NOT ON THE AGENDA
The public is encouraged to submit comments on any subject within the
jurisdiction of the Investment Oversight Committee that does not appear on this
agenda. Although the Committee will not take action on items presented during
the Public Comment Period, the Chair may direct staff to place an item on a
future agenda for discussion.
3.CONSENT
Matters appearing on the Consent Calendar are expected to be non-
controversial and will be acted upon at one time. A member of the public may
request the Revenue Enhancement Oversight Commission to pull an item for
discussion. The public may comment on any and all items on the Consent
Agenda within the three-minute time limit.
3.a CONSIDERATION OF MINUTES - MAY 29, 2025 INVESTMENT
OVERSIGHT COMMITTEE MINUTES
5
Recommendation:
To approve the Investment Oversight Committee Minutes of May 29,
2025.
4.BUSINESS ITEMS
4.a PRESENTATION OF THE QUARTERLY INVESTMENT REPORT ON
PORTFOLIO PERFORMANCE & ECONOMIC OUTLOOK
7
Receive and confirm investment policy compliance.
Recommendation:
Receive and confirm investment policy compliance.
4.b ANNUAL REVIEW OF CITY INVESTMENT POLICY AND
MANAGEMENT PLAN
31
Review and reaffirm the City's Investment Policy and Management Plan.
Recommendation:
Review and reaffirm the City's Investment Policy and Management Plan.
5.COMMENT AND DISCUSSION
5.a STAFF UPDATES AND AGENDA FORECAST
Chair Jackson will provide a brief agenda forecast and updates.
6.ADJOURNMENT
The next Regular Meeting of the Investment Oversight Committee will be
scheduled in late November in the Council Hearing Room at City Hall, 990 Palm
Street, San Luis Obispo.
LISTENING ASSISTIVE DEVICES are available -- see the Clerk
The City of San Luis Obispo wishes to make all of its public meetings accessible
to the public. Upon request, this agenda will be made available in appropriate
alternative formats to persons with disabilities. Any person with a disability who
requires a modification or accommodation in order to participate in a meeting
should direct such request to the City Clerk’s Office at (805) 781-7114 at least
48 hours before the meeting, if possible. Telecommunications Device for the
Deaf (805) 781-7410.
Agenda related writings or documents provided to the Investment Oversight
Committee are available for public inspection on the City’s website, under the
Public Meeting Agendas web page: https://www.slocity.org/government/mayor-
and-city-council/agendas-and-minutes. Meeting video recordings can be found
on the City’s website:
http://opengov.slocity.org/WebLink/Browse.aspx?id=61037&dbid=0&repo=CityCl
erk
Page 4 of 63
1
Investment Oversight Committee Minutes
May 29, 2025, 10:00 a.m.
Council Hearing Room, 990 Palm Street, San Luis Obispo
Investment Oversight
Committee Members
Present:
Committee Member Debbie Malicoat, Committee Member
Whitney McDonald, Committee Member Emily Francis,
Committee Member Riley Kuhn, Member Anni Wang, Chair
Emily Jackson
City Staff Present: Administrative Assistant Michelle Karpovich
_____________________________________________________________________
1. CALL TO ORDER
A Regular Meeting of the San Luis Obispo Investment Oversight Committee was
called to order on May 29, 2025 at 10:07 a.m. in the Council Hearing Room at
City Hall, 990 Palm Street, San Luis Obispo, by Chair Jackson.
2. PUBLIC COMMENT FOR ITEMS NOT ON THE AGENDA
Public Comment:
None.
--End of Public Comment--
3. CONSENT
3.a CONSIDERATION OF MINUTES - FEBRUARY 27, 2025 INVESTMENT
OVERSIGHT COMMITTEE MINUTES
Motion By Member Kuhn
Second By Member Malicoat
To approve the Investment Oversight Committee Minutes of February 27,
2025.
Ayes (4): Member Debbie Malicoat, Member Whitney McDonald, Member
Emily Francis, Member Riley Kuhn, Member Anni Wang, Chair Emily
Jackson
CARRIED (6 – 0)
Page 5 of 63
2
4. BUSINESS ITEMS
4.a PRESENTATION OF THE QUARTERLY INVESTMENT REPORT ON
PORTFOLIO PERFORMANCE & ECONOMIC OUTLOOK
Monique Spyke and Justin Resuello, with PFM Asset Management LLC,
provided an update via PowerPoint presentation and responded to
Committee inquiries.
Public Comment:
None
--End of Public Comment--
Motion By Member Wang
Second By Member Kuhn
Receive and confirm investment policy compliance.
Ayes (4): Member Debbie Malicoat, Member Whitney McDonald, Member
Emily Francis, Member Riley Kuhn, Member Anni Wang, Chair Emily
Jackson
CARRIED (6 to 0)
5. COMMENT AND DISCUSSION
5.a STAFF UPDATES AND AGENDA FORECAST
Chair Jackson provided the following update:
Announced the reappointment of Anne Wang to the Committee.
6. ADJOURNMENT
The meeting was adjourned at 10:49 a.m. The next Regular Meeting of the
Investment Oversight Committee is scheduled for August 28, 2025 at 10:00 a.m.
in the Council Hearing Room at City Hall, 990 Palm Street, San Luis Obispo.
APPROVED BY INVESTMENT OVERSIGHT COMMITTEE: XX/XX/202X
Page 6 of 63
Quarterly Investment Report
AS OF JUNE 30, 2025
Page 7 of 63
This report presents the City’s investment portfolio for
the quarter ending June 30,2025.It has been prepared
to comply with regulations contained in California
Government Code Section 53646.The report includes
all investments managed by the City on its own behalf
as well as for other third-party agencies on a fiduciary
basis such as the Whale Rock Commission.It also
includes all City related investments held by trustees for
bond debt service obligations.As required,the report
provides information on the investment type,issuer,
maturity date,cost,and current market value for each
security.
Page 8 of 63
Market Considerations
U.S. economy is resilient but
showing signs of cooling
•Headline employment data belies
underlying weakening
•Inflation remained rangebound
but does not yet reflect the full
impact of tariffs
•Fiscal policy uncertainty and
volatile tariff rollouts weigh on
consumer sentiment
The Fed’s June “dot plot” implies 50
bps of cuts in the back half of 2025
but members are split between 0 and
2 cuts this year. Fed Chair Powell
stated the effect, size, and duration
of tariffs are all highly uncertain
making staying on hold the
appropriate thing to do as they wait
to learn more.
The yield curve continued to steepen
between 2 years and 10 years while
Credit spreads widened sharply
following tariff fears but tightened to
levels near historic tights by quarter
end.
Source: Bloomberg Financial L.P. and ICE BofA Indices. ABS indices are 0-5 year, based on weighted
average life. As of June 30, 2025.
4.29%
3.72%3.80%
3.99%
4.23%
4.77%
3.00%
3.50%
4.00%
4.50%
5.00%
Yi
e
l
d
Maturity
U.S. Treasury Yield Curve
June 30, 2025
March 31, 2025
3mo 2yr 5yr 7yr 10yr 20yr 30yr
1.18%1.12%
1.23%
1.40%
1.56%
0.0%
0.5%
1.0%
1.5%
2.0%
U.
S
.
T
r
e
a
s
u
r
y
Ag
e
n
c
y
AB
S
Co
r
p
A
-
A
A
A
Co
r
p
B
B
B
Second Quarter 2025 Returns
Page 9 of 63
What we are watching…
U.S. growth turned negative in early
2025, driven by a historically high
trade deficit and weaker consumer
spending. Strong inventory build and
fixed investment helped offset this
weakness.
Financial conditions swung sharply
during the quarter as the tariff rollout
caused equities to sell off, credit
spreads to widen, and heightened
Treasury volatility.
The labor market remains healthy,
though early signs of cooling are
emerging, particularly in rising jobless
claims.
Inflation has moved closer to the Fed’s
2% target, but tariff-driven price
pressures may emerge as businesses
deplete pre-tariff inventories.
Fed Chair Powell said that he does
expect tariffs to impact inflation but
that the size, duration, and time of
tariff effects are highly uncertain.
Source: Federal Reserve, latest economic projections as of June 2025.
1.4%1.6%1.8%1.8%
0%
1%
2%
3%
4%
2025 2026 2027 Longer
Run
Change in Real GDP
Mar Projections Jun Projections 4.5%4.5%4.4%4.2%
0%
1%
2%
3%
4%
5%
6%
2025 2026 2027 Longer
Run
Unemployment Rate
Mar Projections Jun Projections
3.0%
2.4%2.1%2.0%
0%
1%
2%
3%
4%
2025 2026 2027 Longer
Run
PCE Inflation
Mar Projections Jun Projections
3.9%3.6%3.4%3.0%
0%
1%
2%
3%
4%
5%
6%
2025 2026 2027 Longer
Run
Federal Funds Rate
Mar Projections Jun Projections
Page 10 of 63
Current Cash and Investment Summary
The following is a summary of the City’s cash
and investments based on market value, as of
June 30, 2025, compared to the prior quarter.
Investment Entity June 30, 2025 Percent of Total**March 31, 2025
City Held Cash & Investments $64,050,985.87 23.3%$51,913,323.29
JPMorgan Money Market Account $50,000,000.00 18.2%$50,000,000.00
LAIF Held Investments $49,175,806.49 17.9%$48,639,801.25
PFMAM Managed Investments*$111,147,388.38 40.5%$109,639,050.83
TOTAL**$274,374,180.74 100%$260,192,175.37
*Figures shown exclude accrued interest. **Details may not add up to total due to rounding.
Page 11 of 63
Current Cash and Investment Summary
There are several factors
which result in changes in
cash and investment
balances from month-to-
month and quarter-to-
quarter, dependent on the
receipt of revenues or a
large disbursement.
•Some major City revenues are received on a
periodic rather than a monthly basis. Property Tax
is received in December, January, April, and May
of each year. Transient Occupancy Tax is
received monthly but varies considerably due to
seasonality.
•Payments for bonded indebtedness or large
capital projects can reduce the portfolio
substantially in the quarter in which they occur.
•The City pays its CalPERS obligation in a lump
sum at the beginning of the fiscal year to achieve
interest savings.
Factors
Page 12 of 63
Securities
Securities in the City’s
portfolio are priced by
Refinitiv, an independent
pricing service, at the end
of every month. In some
cases, the City may have
investments with a current
market value that is greater
or less than the recorded
value. These changes in
market value are due to
fluctuations in the
marketplace, having no
effect on yield, as the City
does not intend to sell
securities prior to maturity.
Nevertheless, these
market changes can
impact the total value of
the portfolio.
Security Type Market Value
% of
Portfolio
% Change
vs. 3/31/25
Permitted by
Policy
U.S. Treasury 70,706,736 63.2%-1.3%100%
Federal Agency 4,960,922 4.4%-49.4%100%
Municipal Obligations 211,680 0.2%-53.4%30%
Negotiable CDs 1,013,896 0.9%-0.3%30%
Corporate Notes 23,580,087 21.1%33.3%30%
Asset-Backed
Securities 10,622,789 9.5%20.9%15%
Securities Sub-Total 111,096,111 1.5%
Money Market Fund 51,278 0.0%-77.5%20%
Accrued Interest 653,596 0.6%
Securities Total 111,800,985 100.0%2.0%
Page 13 of 63
PFMAM Managed 6/30/2025 3/31/2025
Average Maturity
(Years)2.49 2.35
Effective Duration1 2.07 1.95
Average Market Yield 4.06%4.18%
Total Return
Total return is calculated
based on interest and both
realized and unrealized
changes in market value;
this is expressed as a rate
of return over a specified
period of time based on
cost and is backward-
looking.
•Focused on long-term
performance and
growth
•Affected by both yield
and market value
fluctuations
•Reflects “true value” of
the portfolio
•Recommended
approach by the
Government Finance
Officers Association
Total Rate
of Return 3 Months 1 Year 3 Years Since
Inception
City of SLO 1.39%6.02%3.78%1.90%
0-5 Treasury
Index 1.28%5.80%3.53%1.70%
Variance +0.11% +0.22% +0.25% +0.20%
1Effective duration is the approximate percentage change in price for each 1% change in interest rates.
Page 14 of 63
Investment Objectives
The investment objectives of the City of San Luis Obispo are first, to
provide safety of principal to ensure the preservation of capital in the
overall portfolio; second, to provide sufficient liquidity to meet all
operating requirements; and third, to earn a commensurate rate of
return consistent with the constraints imposed by the safety and
liquidity objectives. The City follows the practice of pooling cash and
investments for all funds under its direct control. Funds held by outside
fiscal agents under provisions of bond indentures are maintained
separately. Interest earned on pooled cash and investments is
allocated quarterly to the various Quarterly Investment Report funds
based on the respective fund’s average quarterly cash balance.
Interest earned from cash and investments with fiscal agents is
credited directly to the related accounts.
It is common for governments to pool the cash and investments of
various funds to improve investment performance. By pooling funds,
the City can benefit from economies of scale, diversification, liquidity,
and ease of administration. The City uses the services of an
investment advisor, PFM Asset Management, to manage a portion of
the City’s portfolio. The City’s strategy is to retain approximately 25%
of the portfolio to manage its day-to-day cash flow needs, while PFM’s
focus is on longer-term investment management. In addition, the City
has retained direct control of several investments that had been
acquired before the City began to use investment advisors. All
investments are held by the City in a safekeeping account with Bank of
New York Mellon, except for investments held by trustees related to
bond financings, which are held by either US Bank or Bank of New
York Mellon.
Page 15 of 63
Environmental, Social, and Governance (ESG) Investment Objectives
ESG investing is the process of incorporating the
analysis of non-financial environmental, social, and
governance factors into investment decisions
alongside traditional financial criteria. As set forth in
the City’s Investment Management Plan dated
August 18, 2020, it is City’s objective to integrate
environmental, social, and governance (“ESG”)
factors into investment decisions for its investment
portfolio to the extent practical and possible.
In order to achieve this objective, the City will apply
the ESG Investment Criteria to the following
Investments: Asset-Backed Securities, Bankers’
Acceptances, Commercial Paper, Corporate,
Medium-Term & Bank Notes, and Negotiable Bank
Deposit Obligations.
The ESG investment criteria is based on ESG Risk
Ratings, industry and subindustry definitions, and
subindustry rankings as provided by Sustainalytics.
Page 16 of 63
Market Value includes accrued interest as of June 30, 2025. Average ESG Risk Rating is weighted by market value.
Please see important disclosures at the end of this presentation.
* U.S. Treasury and municipal obligations are not included in the analysis.
ESG Risk Composition Overview
The ESG Risk Rating measures
economic value at risk based on
ESG factors.
A company’s ESG Risk Rating is
comprised of a quantitative score
and a risk category. The score
indicates unmanaged ESG risk.
Risk categories are absolute and
comparable across industries.
Lower scores represent less
unmanaged risk. Ratings are
scored on a scale of 1-100 and are
assigned to one of the following
ESG risk categories:
•Negligible Risk (overall score
of 0-9.99 points)
•Low Risk (10-19.99 points)
•Medium Risk (20-29.99 points)
•High Risk (30-39.99 points)
•Severe Risk (40 and higher
points)
34/36 of portfolio issuers are rated with a total rated market value of $40.5 million (36%)
Negligible Low Medium High Severe
Portfolio Average
ESG Risk Rating
20.5
Allocation by ESG Risk Rating
Low
17%
Medium
19%
High
<1%
Not Rated
64%
Page 17 of 63
Industry Diversification
Portfolio holdings and Sustainalytics data as of June 30, 2025. Average ESG Risk Rating represents the market
value-weighted average ESG risk rating for each industry.
26.8
20.5 20.8
19.7
25.2
23.4 22.4
19.5
15.0
16.6
13.1
0%
20%
40%
60%
0
10
20
30
Po
r
t
f
o
l
i
o
W
e
i
g
h
t
(
%
)
ES
G
R
i
s
k
R
a
t
i
n
g
Industry Exposure and Weighted Average Risk Score
Page 18 of 63
S&P Credit Rating Distribution
ESG Risk Rating Key
Negligible Low Medium High Severe
0-9.99 10-19.99 20-29.99 30-39.99 40-100
Portfolio holdings and Sustainalytics data as of June 30, 2025. If a security is not rated by S&P, the equivalent
Moody’s rating is used. NR stands for ‘no rating’ and implies that the issuer is not rated by S&P or Moody’s but is
rated by Fitch.
$0 $5 $10 $15 $20
A
AA
AAA
Market Value Allocation (Millions $)
Credit Rating Grouped by ESG Risk Rating Category
22.6
17.4
21.3
0
10
20
30
AAA AA A
Average ESG Risk Rating by S&P Credit Rating
Page 19 of 63
Holdings as of June 30, 2025
Sorted By ESG Risk Rating
Source: Sustainalytics. Holdings as of June 30, 2025.
Issuer % Weight Subindustry Subindustry
Percentile
ESG Risk
Rating
6/30/2025
Coöperatieve Rabobank UA 0.9%Diversified Banks 5 12.3
The Home Depot, Inc.0.9%Home Improvement
Retail 15 12.6
Federal National Mortgage
Association 2.6%Thrifts and Mortgages 6 12.7
Cisco Systems, Inc.1.6%Communications
Equipment 4 13.1
Mastercard, Inc.0.5%Data Processing 9 14.3
Novartis AG 1.4%Pharmaceuticals 2 15.9
Deere & Co.0.7%Agricultural Machinery 8 16.1
Microsoft Corp.1.5%Enterprise and
Infrastructure Software 17 17.4
Bristol Myers Squibb Co.0.3%Biotechnology 3 17.9
Fifth Third Bancorp 0.6%Regional Banks 14 18.0
Target Corp.0.7%Department Stores 18 18.2
BlackRock Finance, Inc.1.1%Asset Management and
Custody Services 11 18.6
American Express Co.1.3%Consumer Finance 15 18.9
Kubota Corp.0.6%Agricultural Machinery 47 19.6
PepsiCo, Inc.0.7%Packaged Foods 3 19.7
The Bank of New York
Mellon Corp.1.4%Asset Management and
Custody Services 13 19.9
Freddie Mac 1.8%Thrifts and Mortgages 23 20.8
Citigroup, Inc.2.6%Diversified Banks 29 21.0
State Street Corp.0.5%Asset Management and
Custody Services 16 21.2
AstraZeneca PLC 0.8%Pharmaceuticals 9 23.1
Eli Lilly & Co.0.7%Pharmaceuticals 9 23.4
Kenvue, Inc.0.6%Personal Products 18 23.4
Page 20 of 63
Holdings as of June 30, 2025
Sorted By ESG Risk Rating
Source: Sustainalytics. Holdings as of June 30, 2025.
(continued)
Issuer % Weight Subindustry Subindustry
Percentile
ESG Risk
Rating
6/30/2025
The PNC Financial Services
Group, Inc.0.7%Regional Banks 31 23.7
Bank of America Corp.3.2%Diversified Banks 37 23.8
Hyundai Motor Co., Ltd.1.2%Automobiles 23 24.7
Morgan Stanley 0.8%Investment Banking and
Brokerage 20 24.8
Walmart, Inc.0.3%Food Retail 47 25.2
The Goldman Sachs Group,
Inc.0.7%Investment Banking and
Brokerage 22 25.2
Nissan Motor Co., Ltd.0.2%Automobiles 33 26.0
JPMorgan Chase & Co.2.2%Diversified Banks 51 27.3
General Motors Co.0.2%Automobiles 50 27.6
Honda Motor Co., Ltd.1.4%Automobiles 46 27.6
Toyota Motor Corp.1.0%Automobiles 53 28.2
PACCAR, Inc.0.7%Heavy Machinery and
Trucks 50 31.2
Page 21 of 63
Socially Responsible Investment Policy
In addition to the ESG
criteria, the City’s Socially
Responsible Investment
(SRI) Policy restricts portfolio
issuers who generate
revenue from casinos,
gambling, racetracks,
brewery, wine/spirits,
tobacco, electronic cigarette,
or tobacco-related products,
or who support the direct
production or drilling of fossil
fuels. The tables to the right
show the Bloomberg Industry
Classifications (“BICS”) for all
the portfolio’s holdings.
Issuer Sector (BICS)
American Express Co Credit Card ABS
AstraZeneca PLC Pharmaceuticals
BA Credit Card Trust Credit Card ABS
Bank of America Corp Diversified Banks
Bank of New York Mellon Corp Banks
BlackRock Inc Financial Services
Bristol-Myers Squibb Co Pharmaceuticals
Cisco Systems Inc Communications Equipment
Citigroup Inc Banks
Cooperatieve Rabobank UA Banks
Deere & Co Machinery Manufacturing
Eli Lilly & Co Pharmaceuticals
Federal Home Loan Mortgage Corp Government Agencies
Federal National Mortgage Association Government Agencies
Fifth Third Auto Trust Automobile ABS
GM Financial Consumer Automobile Receiv Automobile ABS
Goldman Sachs Group Inc Banks
Home Depot Inc Retail - Consumer Discretionary
Honda Auto Receivables Owner Trust Automobile ABS
Issuer Sector (BICS)
Hyundai Auto Receivables Trust Automobile ABS
JPMorgan Chase & Co Diversified Banks
Kenvue Inc Consumer Products
Kubota Credit Owner Trust Other ABS
Mastercard Inc Consumer Finance
Microsoft Corp Software & Services
Morgan Stanley Banks
New Jersey Turnpike Authority Transportation
Nissan Auto Receivables Owner Trust Automobile ABS
Novartis AG Pharmaceuticals
PACCAR Inc Transportation & Logistics
PepsiCo Inc Food & Beverage
PNC Financial Services Group Inc Banks
State Street Corp Financial Services
Target Corp Mass Merchants
Toyota Auto Receivables Owner Trust Automobile ABS
Toyota Motor Corp Automobiles
United States Treasury Sovereigns
Walmart Inc Mass Merchants
Source: Bloomberg Finance L.P. BICs is an industry classification system developed and utilized by Bloomberg that classifies securities
based on business, economic function, and other characteristics.Page 22 of 63
Distribution List
City Council
Erica A. Stewart
Mayor
Michelle Shoresman
Vice Mayor
Michael R. Boswell
Council Member
Emily Francis
Council Member
Jan Marx
Council Member
Investment Oversight
Committee
Emily Francis
Council Liaison
Anni Wang
Public Member
Whitney McDonald
City Manager
Emily Jackson
Director of Finance
Debbie Malicoat
Deputy Director of Finance/City
Controller
Riley Kuhn
Principal Financial Analyst—Budget
Independent Auditor
Badawi & Associates
PFM Asset
Management
Monique Spyke
Managing Director
Justin Resuello
Institutional Sales & Relationship
Manager
Page 23 of 63
Appendix
•Additional ESG Information
•ESG Themes Information
Page 24 of 63
0 5 10 15 20 25 30 35 40
Federal Agency & MBS
Certificates of Deposit
Corporate Notes
ABS
ESG Risk Rating
ESG Risk Rating Range and Average by Sector
Source: Sustainalytics. Data as of June 30, 2025. Bars represent the range of held issuers’ ESG risk rating that fall
under each sector, and lines indicate the sectors market value-weighted average ESG risk rating. Please see
important disclosures at the end of this presentation.
Sector Analysis
23.4
20.6
12.3
16.0
Page 25 of 63
ESG Themes Glossary
ESG Theme Theme Description Key Indicators
Environment
Carbon Output &
Energy Use
Refers to a company’s management of risks
related to its energy efficiency and
greenhouse gas emissions in its operation
as well as its products and services in the
production phase and during the product
use phase
•Carbon intensity
•Renewable energy use
•Env. Mgt. System certification
•GHG reporting / risk management
•Hazardous products
•Sustainable products & services
Waste & Pollution
Evaluates the management of emissions
and releases from a company’s own
operations to air, water, and land, excluding
greenhouse gas emissions
•Emergency response program
•Solid waste management
•Effluent management
•Radioactive waste management
•Hazardous waste management
•Non-GHG air emissions programs
•Oil spill disclosure & performance
•Recycled material use
Resource Use &
Biodiversity
Analyzes how efficiently and effectively a
company uses its raw material inputs and
water in production. It also encompasses
how a company manages the impact of its
operations on land, ecosystems, and wildlife
•Biodiversity programs
•Deforestation programs / polices
•Site closure & rehabilitation
•Water intensity & risk management
•Forest certifications
•Supplier environmental programs / certifications
•Sustainable agriculture programs
Community
Impact
(Environmental)
Evaluates the community impact from an
environmental risk perspective based on an
assessment of Community Relations,
Products & Services, Occupational Health
and Safety, and Product Governance
•Env Impact – Community Relations
•Env Impact – Products & Services
•Env Impact – Occupational Health and Safety
•Env Impact – Product Governance
Page 26 of 63
ESG Theme Theme Description Key Indicators
Social
Human Capital
Management
Evaluates the management of risks
related to human rights, labor rights,
equality, talent development,
employee retention, and labor health
and safety
•Discrimination policy
•Diversity programs
•Gender pay equality / disclosures
•Employee development
•Supply chain management / standards
•Human rights policies & programs
•Employee health & safety
Product
Governance
Focuses on the management of
risks related to product quality,
safety, wellness, and nutrition, as
well as customer data privacy &
cybersecurity
•Product & service safety programs /
c certifications
•Data privacy management
•Media & advertising ethics policy
•Organic products / GMO policy
•Product health statement
Community
Impact (Social)
Assesses how companies engage
with local communities and their
management of access to essential
products or services to
disadvantaged communities or
groups
•Equitable pricing and availability
•Access to health care
•Price transparency
•Human rights / indigenous policy
•Community involvement programs
•Noise management
ESG Financial Integration
& Resilience
Analyzes financial stability and
issues that pose systemic risks and
potential external costs to society in
the financial services industry. Also
measures ESG activities by financial
institutions
•Systemic risk management / reporting
•Tier 1 capital
•Leverage ratio
•Responsible investment / asset management
•Underwriting standards
•Financial inclusion
•Credit & loan standards
•Green buildings investments
ESG Themes Glossary
Page 27 of 63
ESG Themes Glossary
ESG Theme Theme Description Key Indicators
Governance Corporate
Governance
Evaluates a company’s rules, policies, and
practices with a focus on how a company's
board of directors manages and oversees
the operations of a company. Also assesses
the management of general professional
ethics and lobbying activities
•Board / management quality & integrity
•Board structure
•Ownership & shareholder rights
•Remuneration
•Audit & financial reporting
•Stakeholder governance
•Bribery & corruption policies / programs
•Money laundering policy
•Whistleblower programs
•Business ethics programs
•Political involvement policy
•Lobbying and political expenses
Page 28 of 63
Disclosures
This report contains information developed by Sustainalytics. Such information and data are proprietary of Sustainalytics
and/or its third-party suppliers (Third Party Data) and are provided for informational purposes only. The use of the data does
not constitute an endorsement of any product or project, nor investment advice and are not warranted to be complete, timely,
accurate or suitable for a particular purpose. The use of their data is subject to their conditions. For more information vis it
http://www.sustainalytics.com/legal-disclaimer.
Although PFM Asset Management’s information providers, including without limitation, Sustainalytics, Inc. and its affiliates
(the “ESG Parties”), obtain information from sources they consider reliable, none of the ESG Parties warrants or guarantees
the originality, accurate and/or completeness of any data herein. None of the ESG Parties make any express or implied
warranties of any kind, and the ESG Parties hereby expressly disclaim all warranties of merchantability and fitness for a
particular purpose, with respect to any data herein. None of the ESG Parties shall have any liability for any errors or
omissions in connect with any data herein. Further, without limiting any of the foregoing, in no event shall any of the ESG
Parties have any liability for any direct, indirect, special, punitive, consequential or any other damages (including lost pr ofits)
even if notified of the possibility of such damages.
There is a risk that the issuers selected to support client sustainable objectives may not perform as expected in addressing
sustainability considerations or such performance may change over time, which could cause a client account to temporarily
hold securities that are not in alignment with the account’s sustainable objectives. Further, there is a risk that informatio n used
to evaluate ESG criteria may not be readily available, complete or accurate, which could negatively impact an account’s
ability to apply its sustainable objectives. In managing client's sustainability objectives, PFM Asset Management may rely on
analysis and ratings provided by third parties in determining whether an issuer meets an account’s sustainability objectives. A
client’s perception may differ from PFM Asset Management’s or a third party’s on how to judge an issuer’s adherence to
client's guidelines.
PFM Asset Management serves clients in the public sector and is a division of U.S. Bancorp Asset Management, Inc., which
is the legal entity providing investment advisory services. U.S. Bancorp Asset Management, Inc. is a registered investment
adviser, a direct subsidiary of U.S. Bank N.A. and an indirect subsidiary of U.S. Bancorp. U.S. Bank N.A. is not responsible
for and does not guarantee the products, services, or performance of U.S. Bancorp Asset Management, Inc.
For more information regarding PFMAM’s services or entities, please visit www.pfmam.com.
Page 29 of 63
Disclosures (cont.)
The views expressed within this material constitute the perspective and judgment of U.S. Bancorp Asset Management, Inc. at
the time of distribution and are subject to change. Any forecast, projection, or prediction of the market, the economy,
economic trends, and equity or fixed-income markets are based upon current opinion as of the date of issue and are also
subject to change. Opinions and data presented are not necessarily indicative of future events or expected performance.
Information contained herein is based on data obtained from recognized statistical services, issuer reports or
communications, or other sources, believed to be reliable. No representation is made as to its accuracy or completeness.
PFM Asset Management serves clients in the public sector and is a division of U.S. Bancorp Asset Management, Inc., which
is the legal entity providing investment advisory services. U.S. Bancorp Asset Management, Inc. is a registered investment
adviser, a direct subsidiary of U.S. Bank N.A. and an indirect subsidiary of U.S. Bancorp. U.S. Bank N.A. is not responsible
for and does not guarantee the products, services, or performance of U.S. Bancorp Asset Management, Inc.
NOT FDIC INSURED : NO BANK GUARANTEE : MAY LOSE VALUE
For Institutional Investor or Investment Professional Use Only – This material is not for inspection by, distribution to, or
quotation to the general public.
Page 30 of 63
Agenda Report
Investment Oversight Committee
FROM: Emily Jackson, Finance Director
DATE: 10/30/2025
SUBJECT: ANNUAL REVIEW OF CITY INVESTMENT POLICY AND MANAGEMENT PLAN
RECOMMENDATION
Review and reaffirm the City’s Investment Policy and Management Plan.
POLICY CONTEXT
As set forth in the Statement of Investment Policy, the City Treasurer is responsible for developing
and monitoring the Investment Policy & Management Plan.
As recommended by Government Code Section 53646, the Investment Oversight Committee
(IOC) will review the Investment Policy & Management Plan annually. The Council will review the
Investment Policy & Management Plan at a public meeting when changes in strategies, practices
or procedures are proposed by the Investment Oversight Committee. In the interim, the City
Treasurer is responsible for keeping the Investment Policy & Management Plan up to date to
reflect changes in legislation, organizational structure , and other policies and administrative
procedures approved by the Council.
DISCUSSION
Background
The City’s Investment Policy and Management Plan provides that the City “shall invest public
funds in such a manner as to comply with state and local laws; ensure prudent money
management; provide for daily cash flow requirements; and meet the objectives of the Investment
Policy & Management Plan in priority order of Safety, Liquidity, and Return on Investment.”
The City’s Investment Policy and Management Plan was developed in 2015 and was most
recently updated in 2018, 2020, and 2024. A summary of the changes is as follows:
• On February 20, 2018 the policy was revised to increase flexibility of investment
mechanisms by:
o Requiring that all medium-term notes are rated “A” or equivalent or better by one
or more National Recognized Statistical Rating Organizations (NRSROs) rather
than two NRSROs;
o Changing the credit rating from “AA” to “A” or “A-1” or equivalent or better for
negotiable certificates of deposit;
o Allowing investments in asset backed securities.
The 2018 update also updated IOC membership to replace the Assistant City Manager
with the Budget Manager (now Principal Budget Analyst).
• On August 18, 2020 the policy was revised to incorporate an Environmental, Social,
Governance (ESG) investing approach which focuses on investing in companies that have
Page 31 of 63
City of San Luis Obispo, Title, Subtitle
Annual Review of City Investment Policy 2
a focus on environmental issues, are socially engaged and govern their business in a
sustainable and conscientious manner.
• In February 2024, the policy was revised to address inconsistencies created by the 2020
policy update, when the ESG investing approach was incorporated into the policy. As part
of the FY 2022-23 Audit, the City’s independent auditor (Badawi and Associates) identified
that the City was making investments in asset backed securities, despite the policy they
had been provided as part of the FY 2022-23 Audit not allowing for this type of investment.
The Deputy Director of Finance immediately contacted PFM Asset Management Inc.
(PFMAM), the City’s contracted investment manager, to determine why investments were
being made in asset backed securities. PFMAM staff reviewed this issue and determined
that when the 2020 policy updates were made to incorporate an ESG investing approach,
the updates had been made to the 2015 version of the policy, rather than the 2018 policy
which enabled investments in asset backed securities. Finance Department staff worked
with PFMAM to update the policy consistent with the City Council’s intent, based upon
approval of incremental changes to the policy, as outlined above. The correction of this
inconsistency was not formally approved by the City Council because the changes were
non-substantive and intended to clean up the policy to incorporate changes adopted by
the Council in 2018 and 2020. Council was informed of the clean-up via a Council
Memorandum in February 2024.
Recommended Changes - 2025:
Finance staff have worked with PFM Asset Management (PFMAM) to identify necessary changes
to the Investment Policy and Management Plan. Notable recommended changes for the IOC’s
consideration are summarized in Attachment A (Memo from PFMAM). In addition to those
changes, City and PFMAM staff recommend minor, non-substantive editorial clean ups. All
recommended changes are reflected in Attachment B (Draft Investment Policy and Management
Plan- October 2025 markup).
ATTACHMENTS
A- Memo from PFM Asset Management
B- Draft Investment Policy and Management Plan- October 2025 markup
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1 of 1
September 5, 2025
Memorandum
To: Emily Jackson, Finance Director
City of San Luis Obispo
From: Monique Spyke, Managing Director
Justin Resuello, Institutional Sales and Relationship Manager
PFM Asset Management a division of U.S. Bancorp Asset Management, Inc.
RE: 2025 Investment Policy Review
PFM Asset Management, a division of U.S. Bancorp Asset Management, Inc. has completed its review
of the Investment Policy (the “Policy”) for the City of San Luis Obispo (the “City”). This year, we are
recommending changes to (1) provide futher clarity on policy and (2) include Sustainability and ESG
Criteria within the Policy itself. All changes have been tracked within the shared file.
Specifically, with regard to policy clarity, we recommend removing the contrarian mention of
“collateralized mortgage obligations” in the Prohibited Investment Vehicles and Practies section of
the Policy. In January 2024, Senate Bill 882 made several changes to Code, including one change to
Code Section 53601(o). The bill clarified that mortgage-backed securities issued by federal agencies
are exempt from the Code’s requirements described in Section 53601(o) for privately issued asset-
and mortgage- backed securities. The Code update codifies the common understanding of how
agency mortgage-backed securities are treated under Code. We are recommending including the
following language:
“For investments that are not issued or guaranteed by federal agencies and GSEs …”
Separately, we also recommend updating the name for “S&P” to “S&P Global” to align with formal credit rating
agency recognition.
In accordance with the City’s request, we have also integrated the ESG parameters into the main Policy
document rather than maintaining a separate Addendum. All pertinent updates can be found in Section VII:
Sustainability & ESG Investing.
Most notably, we changed the title from “ESG” to “Sustainability & ESG” to be more inclusive and align better
with current industry terminology. References to Morningstar’s Sustainalytics were expanded to “Morningstar,
Bloomberg, or another reputable rating agency.” Additionally, the company-specific exclusions for private
prisons were replaced with the exclusion of the specific industry name (“Private Corrections” under Criteria #1);
the reason for this change is that this industry-level exclusion was not available for Bloomberg coding when the
Addendum was first adopted in 2020, but it can now be included. Lastly, it was clarified that the rules apply only
at the time of purchase, which had been implied but not clearly stated before.
Please let me know if you’d like to schedule a call to discuss our recommendations or to answer any questions
you may have. Thank you.
Page 33 of 63
Page 34 of 63
INVESTMENT POLICY
& MANAGEMENT PLAN
February 2024AugustOctober 2025
Page 35 of 63
INVESTMENT MANAGEMENT PLAN
Table of Contents
I. INTRODUCTION 1
Policy Statement
Primary Investment Objective
Scope of Investment Management Plan
Use of State Guidelines
Preparation and Administration of the Plan
Ethics and Conflict of Interest
II. INVESTMENT AUTHORITY AND RESPONSIBILITIES 5
Authorized Investment Officers
Internal Controls
Investment Management Resources
Evaluation of Investment Officer Actions
Responsibilities of an Investment Advisor
III. CAPITAL PRESERVATION AND RISK 9
Overview
Portfolio Diversification Practices
IV. ELIGIBLE FINANCIAL INSTITUTION 10
Portfolio Diversification and Credit-Worthiness Standards
Certification and Reporting Requirements
Individual Placement of Investments
Individual Placement of Deposits
V. INVESTMENT VEHICLES 12
State of California Limitations
Suitable and Authorized Investments
Review of Investment Portfolio
City Policies
Authorized Investments Summary
VI. INVESTMENT MATURITY 18
VII. SUSTAINABILITY & ESG INVESTING 19
VIII. CASH MANAGEMENT PRACTICES 20
IX. EVALUATION OF INVESTMENT PERFORMANCE 21
X. INVESTMENT REPORTING 22
XI. INVESTMENT POLICY AND MANAGEMENT PLAN REVIEW 24
XII. GLOSSARY 25
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1
I. INTRODUCTION
POLICY STATEMENT
The City of San Luis Obispo shall invest public funds in such a manner as to comply with state and
local laws; ensure prudent money management; provide for daily cash flow requirements; and meet the
objectives of the Investment Policy & Management Plan in priority order of Safety, Liquidity, and
Return on Investment.
The purpose of the investment management plan is to establish strategies, practices and procedures to
be used in administering the City's portfolio in accordance with the City's Statement of Investment
Policy. Included in the Appendix is a copy of the City’s most recently adopted Investment Policy.
PRIMARY INVESTMENT OBJECTIVE
The City's primary investment objective is to achieve a reasonable rate of return on public funds while
minimizing the potential for capital losses arising from market changes or issuer default. Although
the generation of revenues through interest earnings on investments is an appropriate City goal, the
primary consideration in the investment of City funds is capital preservation in the overall portfolio.
As such, the City's yield objective is to achieve a reasonable rate of return on City investments rather
than the maximum generation of income, which could expose the City to unacceptable levels of risk.
In determining individual investment placements, the following factors shall be considered in priority
order:
1. Safety
2. Liquidity
3. Yield – (Return on Investment)
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. To
attain this objective, the City will diversify its investments so that the impact of potential losses from
any one type of security or from any one individual issuer will be minimized. The objective is to
mitigate credit risk and interest rate risk summarized as follows:
Credit Risk. Credit risk is the risk that a security or a portfolio will lose some or all its value due to
a real or perceived change in the ability of the issuer to repay its debt. The City shall mitigate credit
risk by adopting the following strategies:
1. Limiting investments to the safest types of securities.
2. Pre-qualifying the financial institutions, broker/dealers, intermediaries, and advisors with which
the City will do business. If the City has an investment advisor, the investment advisor may use its
own list of authorized broker/dealers to conduct transactions on behalf of the City.
3. It is the intent of the City to diversify the investments within the portfolio to avoid incurring
unreasonable risks inherent in over-investing in specific instruments, individual financial
institutions or maturities. The asset allocation in the portfolio should, however, be flexible
Page 37 of 63
2
depending upon the outlook for the economy, the securities market, and the City’s anticipated
cash flow needs.
4. No more than 5% of the total portfolio may be invested in securities of any single issuer, other
than the United States Government, its agencies and instrumentalities, approved local agency
investment pools, LAIF, money market funds, and the City’s main financial institution.
5. The City may elect to sell a security prior to its maturity and record a capital gain or loss in order
to improve the quality, liquidity or yield of the portfolio in response to market conditions or the
City’s risk preferences.
6. If securities owned by the City are downgraded by either Moody’s or S&P Global to a level
below the quality required by this Investment Management Plan, it shall be the City’s policy to
review the credit situation and make a determination as to whether to sell or retain such securities
in the portfolio.
a. If a security is downgraded below the level required by this policy, the City Treasurer will
determine whether to sell or hold the security based on its current maturity, the economic
outlook for the issuer, and other relevant factors.
b. If a decision is made to retain a downgraded security in the portfolio, it will be monitored
and reported monthly to the City Council.
Interest Rate Risk. Interest rate risk is the risk that the portfolio will decline in value (or will not
optimize its value) due to changes in the general level of interest rates. The City recognizes that, over
time, longer-term portfolios achieve higher returns. On the other hand, longer-term portfolios have
higher volatility of return.
The City will mitigate interest rate risk by providing adequate liquidity for short-term cash needs,
and by making some longer-term investments only with funds that are not needed for current cash
flow purposes. The City further recognizes that certain types of securities, including variable rate
securities, securities with principal pay downs prior to maturity, and securities with embedded
options, will affect the market risk profile of the portfolio differently in different interest rate
environments. The City, therefore, adopts the following strategies to control and mitigate its exposure
to interest rate risk:
1. The maximum stated final maturity of individual securities in the portfolio shall be five years,
except that up to 10% of the portfolio can be invested in Treasury and GSE securities maturing
over 5 years.
2. The City shall maintain a minimum of three months of budgeted operating expenditures in short-
term investments. The level of operating expenses shall be measured once per year and shall be
based on the most recently adopted budget.
3. The duration of that part of the portfolio that is not needed for liquidity purposes shall typically
be approximately equal to the duration of an index of US Treasury and Federal Agency Securities
with maturities which meet the City’s needs for cash flow and level of risk tolerance (the
Benchmark Index) plus or minus 10%.
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3
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 (static liquidity).
Alternatively, a portion of the portfolio may be placed in money market mutual funds or local
government investment pools which offer same-day liquidity for short-term funds. Furthermore,
since all possible cash demands cannot be anticipated, the portfolio should consist largely of
securities with active secondary or resale markets (dynamic liquidity).
Yield: Return on Investments. The City’s investment portfolio shall be designed with the
objective of attaining a market benchmark rate of return throughout budgetary and economic cycles,
commensurate with the City’s investment risk constraints and the cash flow characteristics of the
portfolio. Return on investment is of least 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 reasonable return relative to the risk being assumed.
SCOPE OF INVESTMENT MANAGEMENT PLAN
Included in the scope of the City's Investment Policy & Management Plan are the following major
guidelines and practices to be used in achieving the City's primary investment objective:
1. Investment authority and responsibilities
2. Capital preservation and risk
3. Eligible financial institutions
4. Allowable investment vehicles
5. Investment maturity
6. Cash management
7. Evaluation of investment performance
8. Investment reporting
9. Investment management plan review
10. Environmental, social, and governance (“ESG”) Socially responsible investment guidelines
These guidelines apply to all cash-related assets included within the City’s audited financial
statements and held either directly by the City or held and invested by trustees or fiscal agents.
The only exception is funds invested in the City's deferred compensation plan, which are controlled
by federal law, specific provisions of the City's adopted plan and individual employee decisions.
USE OF STATE GUIDELINES
The California Government Code (including sections 16429.1, 16481.2, 53600-53609, 53630-
53634, 53635, 53635.2, 53635.3, 53635.8, 53637-53638 and 53684) regulates public agency
investment and investment reporting practices. It is the policy of the City of San Luis Obispo to use
the State's provisions for local government investments in developing and implementing the City's
investment policies and practices.
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4
PREPARATION AND ADMINISTRATION OF THE PLAN
As set forth in the Statement of Investment Policy, the City Treasurer is responsible for developing and
monitoring the Investment Policy & Management Plan.
As recommended by Government Code Section and 53646, the Investment Oversight Committee will
review the Investment Policy & Management Plan annually. The Council will review the Investment
Policy & Management Plan at a public meeting when changes in strategies, practices or procedures
are proposed by the Investment Oversight Committee. In the interim, the City Treasurer is responsible
for keeping the Investment Policy & Management Plan up to date to reflect changes in legislation,
organizational structure, and other policies and administrative procedures approved by the Council.
ETHICS AND CONFLICT OF INTEREST
Investment Officials shall refrain from personal business activity that could conflict with proper
execution and management of the policy and the investment management plan, or which could impair
their ability to make impartial decisions. Investment Officials must provide a public disclosure
document by April 1st of each year or when material interest in financial institutions or personal
investment positions require it. Furthermore, Investment Officials must refrain from undertaking
personal investment transactions with the same individuals(s) employed by the financial institution
with which business is conducted on behalf of the City.
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5
II. INVESTMENT AUTHORITY AND RESPONSIBILITIES
AUTHORIZED INVESTMENT OFFICERS
Authority to manage the investment portfolio is granted to the Finance Director/City Treasurer
pursuant to Resolution No. 8477. Responsibility for the day-to-day operation of the investment
program may be delegated to the Deputy Director of Finance/Controller, who is responsible for
carrying -out established written procedures and internal controls for the operation of the investment
program consistent with this plan. These procedures should include references to safekeeping,
delivery vs payment, investment accounting, repurchase agreements, wire transfer agreements,
collateral/depository agreements and banking services contracts.
Transactions Directed by City Staff. No person may engage in an investment transaction except as
provided under the terms of this plan and the procedures established by the F i n an ce Finance
Director/City Treasurer. Although the Finance Director/City Treasurer may delegate these duties to
another official in the Department of Finance, every investment transaction must be reviewed and
approved by the Finance Director/City Treasurer. Additionally, the Finance Director/City Treasurer
shall be responsible for all transactions undertaken and shall establish a system of controls to
regulate the activities of subordinate officials.
Transaction Directed by an Investment Advisor. The City may engage the services of an external
investment adviser to assist in the management of the City’s investment portfolio in a manner
consistent with the City’s objectives. The external investment adviser may be granted discretion to
purchase and sell investment securities in accordance with the City’s Investment Policy and this
Investment Management Plan. The investment adviser must be registered under the Investment
Advisers Act of 1940. The investment advisor shall be required to provide a certification that theyit
haves read and understands the applicable sections of the California Government Code relating to
municipal investments, this Investment Management Plan and the City’s Investment Policy.
INTERNAL CONTROLS
The Finance Director/City Treasurer is responsible for ensuring compliance with the City's
Investment Policy as well as for establishing systems of internal control designed to prevent losses due
to fraud, employee error, misrepresentation by third parties, unanticipated changes in financial
markets, or imprudent actions by City officers and employees. Additionally, the Finance
Director/City Treasurer is responsible for the physical security of City investments and shall use
custodial safekeeping for negotiable and bearer instruments whenever possible.
INVESTMENT MANAGEMENT RESOURCES
The concept of reasonable assurance recognizes that the:
1. Cost of a control procedure should not exceed the benefits likely to be derived.
2. Valuation of costs and benefits requires estimates and judgments by management. Accordingly,
the Finance Director/City Treasurer shall establish a process for annual independent review
by an external auditor to assure compliance with policies and procedures.
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6
Internal controls shall address the following points:
1. Separating transaction authority from accounting and record keeping. By separating the
person who authorizes or performs the transaction from the people who record or otherwise
account for the transaction, a separation of duties is achieved.
2. Custodial safekeeping. Securities purchased from any bank or dealer including appropriate
collateral (as defined by State Law) shall be placed with an independent third party for custodial
safekeeping as evidenced by safekeeping receipts in the City of San Luis Obispo’s name.
3. Avoiding physical delivery securities. Book entry securities are much easier to transfer and
account for since actual delivery of a document never takes place. Delivered securities must be
properly safeguarded against loss or destruction. The potential for fraud and loss increases with
physically delivered securities.
4. Delivery versus payment. All trades where applicable will be executed by delivery vs payment
(DVP). This ensures that securities are deposited in the eligible financial institution before the
release of funds. Securities will be held by a third-party custodian as evidenced by safekeeping
receipts.
5. Clearly delegating authority to subordinate staff members. Subordinate staff members must
have a clear understanding of their authority and responsibilities to avoid improper actions. Clear
delegation of authority also preserves the internal control structure that is contingent on the various
staff positions and their respective responsibilities.
6. Confirming telephone transactions for investments and wire transfers in writing. Due to the
potential for error and improprieties arising from telephone transactions, all telephone transactions
should be supported by written communications and approved by the appropriate person. Written
communications may be via fax if on letterhead or e-mail and the safekeeping institution has a list
of authorized signatures.
7. Developing wire transfer agreements with the lead bank or third-party custodian. This
agreement should outline the various controls, security provisions, and delineate responsibilities of
each party making and receiving wire transfers.
EVALUATION OF INVESTMENT OFFICER ACTIONS
The standard of prudence to be applied by the Finance Director of Finance/City Treasurer shall
be the "prudent investor" standard, as defined under Government Code Section 53600.3 which states:
When investing, reinvesting, purchasing, acquiring, exchanging, selling, or managing public
funds, a trustee shall act with care, skill, prudence, and diligence under the circumstances then
prevailing, including, but not limited to, the general economic conditions and the anticipated
needs of the agency, that a prudent person acting in a like capacity and familiarity with those
matters would use in the conduct of funds of a like character and with like aims, to safeguard
the principal and maintain the liquidity needs of the Agency. Within the limitations of this section
and considering individual investments as part of an overall strategy, investments may be
acquired as authorized by law.
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7
Investment officers acting in accordance with written procedures and this Investment Policy &
Management Plan, 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 plan.
Officers and employees involved in the investment process shall refrain from personal business
activity that could conflict with the proper execution and management of the investment program, or
that could impair their ability to make impartial decisions. Employees and investment officials shall
disclose any material interests in financial institutions with which they conduct business. They shall
further disclose any personal financial/investment positions that could be related to the performance
of the investment portfolio. Employees and officers shall refrain from undertaking personal
investment transactions with the same individual with whom business is conducted on behalf of the
City.
In accordance with Government Code Section 53607, the Finance Director/City in a n c e D i r
e c t o r /C it y Treasurer shall prepare a report of monthly investment transactions for the City
Council’s review. In addition, the City Council shall determine each year whether the delegation of
investment authority to the Treasurer shall be renewed.
RESPONSIBILITIES OF AN INVESTMENT ADVISOR
When the services of an investment advisor are contracted for by the City, the responsibilities and
obligations of the investment advisor shall be identified within the terms of the contract and shall, at a
minimum, include the following:
I. Investment Advisor will provide investment research and supervision of the managed assets and
conduct a continuous program of investment, evaluation and, when appropriate, sale and
reinvestment of the managed assets.
II. Investment Advisor shall continuously monitor investment opportunities and evaluate investments
of the managed assets. Investment Advisor shall furnish City with statistical information and
reports with respect to investments of the managed assets.
III. Investment Advisor shall place all orders for the purchase, sale, or exchange of portfolio securities
for City's account with brokers or dealers recommended by Investment Advisor and/or City, and
to that end Investment Advisor is authorized as agent of City to give instructions to the custodian
designated by City (the “Custodian”) as to deliveries of securities and payments of cash for the
account of City.
IV. In connection with the selection of such brokers and dealers and the placing of such orders,
Investment Advisor is directed to seek for City the most favorable execution and price, the
determination of which may take into account, subject to any applicable laws, rules and
regulations, whether statistical, research and other information or services have been or will be
furnished to Investment Advisor by such brokers and dealers.
V. Investment Advisor shall not take possession of or act as custodian for the cash, securities or other
assets of City and shall have no responsibility in connection therewith.
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VI. Authorized investments shall include only those investments which are currently authorized by
the state investment statutes, and City’s investment policy, and as supplemented by such other
written instructions as may from time to time be provided by City to Investment Advisor.
VII. Investment Advisor shall be entitled to rely upon City's written advice with respect to anticipated
drawdowns of managed assets.
VIII. Investment Advisor will observe the instructions of City with respect to broker/dealers who are
approved to execute transactions involving the managed assets and in the absence of such
instructions will engage broker/dealers who Investment Advisor reasonably believes to be
reputable, qualified and financially sound.
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9
III. CAPITAL PRESERVATION AND RISK
OVERVIEW
Some level of risk is inherent in any investment transaction. Losses may be incurred due to issuer
default, market price changes or technical cash flow complications such as investments in non-
marketable certificates of deposit. Diversification of the City's portfolio by institution, investment
vehicle and maturity term is the primary tool available to the City in minimizing investment risk and
capital losses by safeguarding the overall portfolio from any individual loss.
PORTFOLIO DIVERSIFICATION PRACTICES
The following sections summarize the City's major portfolio diversification practices and guidelines in
determining:
1. Eligible financial institutions
2. Investment vehicles
3. Investment maturity
Portfolio limitations included in these guidelines are to be based on the portfolio composition and
Investment Management Plan policies in effect at the time of placement; the actual composition of the
City's investments may vary over time from plan limitations due to overall portfolio changes from
when the individual placement was made as well as changes in the City's Investment Management
Plan.
Credit criteria listed in these guidelines refer to the credit rating at the time the security is purchased. If
an investment’s credit rating falls below the minimum rating required at the time of purchase, the
Finance Director/City Treasurer will consult with the Investment Advisor and perform a timely
review to decide whether to sell or hold the investment.
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IV. ELIGIBLE FINANCIAL INSTITUTION
PORTFOLIO DIVERSIFICATION AND CREDIT-WORTHINESS STANDARDS
The following general criteria relating to portfolio diversification and creditworthiness will be used in
selecting depositories and broker/dealers (financial institutions) in the placement of City investments:
1. The financial capacity and creditworthiness of the financial institution shall be considered before
the placement of City investments.
2. Current financial statements shall be maintained for each institution in which or through which cash
is invested.
3. No more than 5% of the City's portfolio (exclusive of the US Government, its agencies and
instrumentalities, approved local agency investment pools and money market funds government
agency issues, or LAIF and money market funds, and the City’s main financial institution) shall be
placed with any financial institution.
4. No more than 25% of the City's portfolio shall be invested in collateralized certificates of deposit
issued by savings and loan institutions.
5. Certificates of deposit placed by the City shall not constitute more than 15% of the total assets of
the institution; and the institution must have total assets in excess of $200 million.
CERTIFICATION AND REPORTING REQUIREMENTS
Unless the City has engaged an investment advisor, the City shall establish a list of qualified
securities dealers based on a certification submitted by all financial institutions with which the City
has an investment relationship. The certification shall state that the institution has reviewed the City's
Investment Policy & Management Plan and that it will:
1. Exercise due diligence in monitoring the activities of its officers and employees engaged in
transactions with the City.
2. Ensure that all of its officers and employees offering investments to the City are trained in the
precautions appropriate to public sector investments.
3. Submit audited financial statements prepared by an independent certified public accountant to the
City on an annual basis within 180 days after the end of the institution's fiscal year.
INDIVIDUAL PLACEMENT OF INVESTMENTS
A list will be maintained of financial institutions and depositories authorized to provide investment
services. In addition, a list will be maintained of approved security broker/dealers selected by
creditworthiness (e.g., a minimum capital requirement of $10,000,000 and at least five years of
operation). These may include "primary" dealers or regional dealers that qualify under Securities
and Exchange Commission (SEC) Rule 15C3-1 (uniform net capital rule).
All financial institutions and broker/dealers who desire to become qualified for investment
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transactions must supply the following as appropriate:
1. Audited financial statements demonstrating compliance with state and federal capital adequacy
guidelines
2. Proof of National Association of Securities Dealers (NASD) certification (not applicable to
Certificate of Deposit counterparties)
3. Proof of state registration
4. Certification of having read and understood and agreeing to comply with the applicable sections
of the California Government Code and the City’s Investment Policy and that all securities
recommended shall be suitable for the City of San Luis Obispo.
The investment advisor (or City staff if applicable) will strive to obtain competitive bids from at
least three brokers or financial institutions on all purchases and sales of investment instruments
whenever possible.
INDIVIDUAL PLACEMENT OF DEPOSITS
Individual placement of collateralized certificates of deposit with eligible financial institutions shall be
based on the following practices and procedures:
1. Deposits shall only be placed with financial institutions maintaining offices within the City of
San Luis Obispo.
2. Unless collateralized by eligible securities as provided in Sections 53651 and 53652 of the
Government Code, the maximum number of Certificates of Deposit to be placed with any single
institution is the amount up to the Federal Deposit Insurance Corporation (FDIC) limit.
3. Reasonable efforts will be made to place deposits of less than the FDIC limit with each eligible
institution. Any deposits in excess of this amount shall be awarded based on competitive bids.
Documentation relating to rate quotes shall be maintained by Finance for six months.
4. Within the context of the City's policies regarding competitive bidding and portfolio limitations,
deposits shall be distributed as evenly as possible between financial institutions.
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V. INVESTMENT VEHICLES
STATE OF CALIFORNIA LIMITATIONS
As provided in the applicable sections of the Government Code (53601 + 53601.6), the State of
California limits the investment vehicles available to local agencies.
SUITABLE AND AUTHORIZED INVESTMENTS
City funds may be invested to diversify the investments by security type and institutions subject to the
following restrictions:
1. No more than 5% of the total portfolio may be invested in securities of any single issuer,
other than the US Government, its agencies and instrumentalities, approved local agency
investment pools, LAIF, money market funds, and the City’s main financial institution.
2. The maximum stated final maturity of individual securities in the portfolio shall be five years,
except that up to 10% of the portfolio can be invested in Treasury, municipal, and GSE securities
maturing over 5 years.
3. The City shall maintain a minimum of three months of budgeted operating expenditures in short
term investments. The level of operating expenses shall be measured once per year and shall be
based on the most recently adopted budget.
4. The duration of that part of the portfolio that is not needed for liquidity purposes shall typically
be approximately equal to the duration of an index of US Treasury and Federal Agency Securities
with maturities which meet the Authority’s needs for cash flow and level of risk tolerance (the
Benchmark Index) plus or minus 10%.
5. Treasury Obligations: Treasury bills, Treasury notes, Treasury bonds and Treasury STRIPS with
maturities not exceeding five years from the date of purchase.
6. Federal Agency or Government Sponsored Enterprise (GSE) Securities: Federal agency or United
States government-sponsored enterprise obligations, participations, or other instruments,
including those issued by or fully guaranteed as to principal and interest by federal agencies or
United States government-sponsored enterprises with maturities not exceeding five years from
the date of purchase.
7. Municipal Securities: include obligations of the City, the State of California, any of the other 49
states, and any local agency within the State of California, provided that the securities are rated
in a rating category of “A” or its equivalent or higher by at least one nationally recognized
statistical rating organization (NSRO). No more than 30% of the portfolio may be invested in
these securities and no more than 5% of the portfolio may be invested in any issuer.
8. Commercial Paper: With “prime” quality of the highest ranking or of the highest letter and
number rating as provided for by a nationally recognized statistical-rating organizations
(NRSRO). The entity that issues the commercial paper must meet all of the following conditions
in either paragraph a or paragraph b:
a. The entity meets the following criteria: (i) is organized and operating in the United
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States as a general corporation, (ii) has total assets in excess of five hundred
million dollars ($500,000,000), and (iii) has debt other than commercial paper, if
any, that is rated in a rating category of “A” or its equivalent or higher by a
NRSRO.
b. The entity meets the following criteria: (i) is organized within the United States as
a special purpose corporation, trust, or limited liability company, (ii) has program-
wide credit enhancements including, but not limited to, over collateralization,
letters of credit, or surety bond, and (iii) has commercial paper that is rated in a
rating category of “A-1” or higher, or the equivalent, by a NRSRO.
c. Eligible commercial paper will have a maximum maturity of 270 days or less. No
more than 40% of the City’s portfolio may be invested in commercial paper. The
City may purchase no more than 10% of the outstanding commercial paper of any
single issuer.
9. Medium Term Notes: Issued by corporations organized and operating in the U.S. or by depository
institutions licensed by the U.S. or any state and operating within the U.S., except financial
institutions shall not be considered. At the time of purchase, the notes must mature within five
years and must be rated in a rating category of “A” or its equivalent or better by one or more
NRSRO. At the time of purchase, no more than 30% of the City’s portfolio may be invested in
medium term notes and no more than 5% of the City’s portfolio may be invested in any one issuer.
10. Bankers’ Acceptances: Not exceeding 180 days to maturity. At the time of purchase, no more
than 40% of the City’s surplus funds may be invested in bankers’ acceptances and no more than
5% of the City’s surplus funds may be invested in bankers’ acceptances from any one bank.
11. Repurchase Agreements: With a term of the agreement not exceeding one year, collateralized by
U.S. Treasury and agency securities listed in items 1 and 2 above. The value of the collateral
underlying the agreement shall be 102%. The market value of the collateral shall be marked-to-
the-market at least weekly based on the bid price and adjustments made when the value falls
below 102%. Collateral shall be held in the City’s custodial bank as safekeeping agent.
Repurchase Agreements shall be entered into only with dealers who have executed a Master
Repurchase Agreement with the City and who are recognized as Primary Dealers with the Market
Reports Division of the Federal Reserve Bank of New York. There are no limitations on the
amount that can be invested in repurchase agreements. No more than 25% of the portfolio can be
invested with any one financial institution.
12. Asset-Backed Securities (ABS). A mortgage passthrough security, collateralized mortgage
obligation, mortgage-backed or other pay-through bond, equipment lease-backed certificate,
consumer receivable passthrough certificate, or consumer receivable-backed bond. At the time of
purchase, asset-backed securities must be issued by an issuer rated in a rating category of “A” or
its equivalent or better by an NRSRO unless issued or guaranteed by federal agencies and GSEs.
for the issuer’s debt as provided by an NRSRO and rated in a rating category of “AAA” or its
equivalent or better by an NRSRO. At the time of purchase, no more than 15% of the City’s
portfolio may be invested in asset-backed securities and no more than 2.5% of the City’s
portfolio may be invested in any one issuer.
13. Local Agency Investment Fund (LAIF): A local government investment pool established by the
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State Treasurer of California for the benefit of California local agencies. City funds can be
invested in LAIF up to the maximum permitted by State Law.
14. Negotiable Certificates of Deposit: Issued by a nationally or state-chartered bank, a savings
association or a federal association (as defined by Section 5102 of the Financial Code), a state or
federal credit union, or by a federally or state-licensed branch of a foreign bank. At the time of
purchase, the maturity of the certificate may not exceed five years, must be rated in a rating
category of “A” or “A-1” or its equivalent or better by one or more NRSRO, no more than 30%
of the City’s surplus funds may be invested in certificates of deposit and no more than 5% of the
City’s surplus funds may be invested in certificates from any one bank.
15. Collateralized Bank Deposits: Shall be evaluated in terms of Federal Deposit Insurance
Corporation (FDIC) coverage. For deposits in excess of the FDIC insured limit, approved
collateral at the percentage above market value as specified by California Government Code,
Sections 53651 et seq. and Sections 53652 et seq. shall be required. No more than 25% of the
portfolio can be placed with any one financial institution. This limit may be exceeded if necessary,
to allow the City to meet its short-term operational needs.
16. Money Market Mutual Funds: Shall be registered under the Investment Company Act of 1940.
To be eligible for investment pursuant to this subdivision, these companies will either:
i. attain the highest-ranking letter or numerical rating provided by at least two NRSROs or
ii. have retained an investment advisor registered or exempt from registration with the
Securities and Exchange Commission with not less than five years of experience managing
money market mutual funds and with assets under management in excess of $500,000,000.
At the time of purchase, no more than 20% of the City’s surplus funds may be invested in
money market mutual funds and no more than 10% of the City’s surplus funds may be
invested in any one fund.
17. Local Government Investment Pools: Shares of beneficial interest issued by a joint powers
authority (Local Government Investment Pools) organized pursuant to Government Code Section
6509.7 that invests in the securities and obligations authorized in subdivisions (a) to (o) of
California Government Code Section 53601, inclusive. Each share will represent an equal
proportional interest in the underlying pool of securities owned by the joint powers’ authority.
The Pool will be rated in a rating category “AAA” or its equivalent by a NRSRO. To be eligible
under this section, the shares will maintain a stable net asset value (NAV) and the joint powers
authority issuing the shares will have retained an investment adviser that meets all of the
following criteria:
a. The adviser is registered or exempt from registration with the Securities and
Exchange Commission.
b. The adviser has not less than five years of experience investing in the securities and
obligations authorized in subdivisions (a) to (o) Government Code Section 53601,
inclusive.
c. The adviser has assets under management in excess of five hundred million dollars
($500,000,000).
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18. Investments in Community Banks: Provided that the requirements of these guidelines and
California Code sections 53630-53653 are adhered to, funds may be invested in community banks
within the San Luis Obispo County service area under the following criteria:
a. The bank must be based and have its headquarters in San Luis Obispo County, with
at least one branch within the City of San Luis Obispo.
b. As indicated by Government Code Section 53635.2, the bank must receive an
overall rating of not less than “satisfactory” from the appropriate federal
supervisory agency for meeting the criteria specified in Section 2906 of Title 12 of
the U.S. Code (Community Reinvestment Act of 1977).
c. The bank must provide certification and supporting information that indicates at
least 25% in loans is invested within the City of San Luis Obispo.
d. To ensure the City obtains a competitive rate for investments in the program, any
potential investment or proposal must enjoy a rate of return equal to or greater than
the Local Agency Investment Fund (LAIF) average quarterly rate existing at the
time of the investment;
e. Participating banks shall make a presentation to the City of San Luis Obispo
Investment Oversight Committee about their community involvement at least once
per year.
f. Upon the Investment Oversight Committee’s review of community involvement,
the existing investment will be evaluated for renewal by City finance staff.
REVIEW OF INVESTMENT PORTFOLIO
The securities held by the City must be in compliance as outlined under “Suitable and Authorized
Investments” at the time of purchase. Because some securities may not comply with said section
subsequent to the date of purchase, the Finance Director/City Treasurer shall at least annually review
the portfolio to identify those securities that doe no longer comply. The Finance Director/City
Treasurer shall establish procedures to report to the Investment Oversight Committee any major
and/or critical incidences of noncompliance identified through the review of the portfolio.
CITY POLICIES
Debt Funds. Reserve funds from the proceeds of debt issues shall be invested by the Finance
Director/City Treasurer in accordance with bond covenants.
Deferred Compensation. These policies do not apply to deferred compensation plans. Individual
investment policies are adopted by each deferred compensation plan and approved independently by
Council. Furthermore, individual investments are directed solely by the employee.
Prohibited Investment Vehicles and Practices
1. State law notwithstanding, any investments not specifically described herein are prohibited,
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including, but not limited to, mutual funds (other than money market funds as described above in
No. 10), equity investments, unregulated and/or unrated investment pools or trusts,
collateralized mortgage obligations and futures and options.
2. In accordance with Government Code Section 53601.6, investment in inverse floaters, range
notes or mortgage derived interest-only strips is prohibited.
3. Investment in any security that could result in a zero-interest accrual if held to maturity is
prohibited.
4. Trading securities for the sole purpose of speculating on the future direction of interest rates is
prohibited.
5. Purchasing or selling securities on margin is prohibited.
6. The use of reverse repurchase agreements, securities lending or any other form of borrowing or
leverage is prohibited without Council approval.
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AUTHORIZED INVESTMENTS SUMMARY
Investment Type
Government Code
Maximum Maturity
Maximum % of Portfolio
Quality Requirements
San Luis Obispo
Maximum Maturity Maximum
% of Portfolio Quality
Requirements
1. Treasury Obligations 5 Years
None
None
5 Years a
None
None
2. GSE Securities 5 Years
None
None
5 Years a
None
None
3. Municipal Securitiesb 5 years
None
None
5 years a
30% per type; 5% per issuer “A”
or better
4. Commercial Paper 270 Days
25% per type; none per issuer
A-1/P-1/F-1; Long-term “A”
270 Days
25% per type; 10% per issuer A-
1/P-1/F-1; Long-term “A”
5. Medium Term Notes 5 Years
30% per type; none per issuer
“A”
5 Years
30% per type; 5% per issuer “A”
6. Bankers’ Acceptances 180 Days
40% per type; 30% per issuer
None
180 Days
40% per type; 5% per issuer None
7. Repurchase Agreement 1 Year
None
None
1 Year
None per type; 5% per
counterparty
Primary Dealers/ Collateralization
requirements
8. Asset Backed Securities 5 Years
20 % per type; none per issuer
“A” for issuer’s debt; “AA” for issue”
5 Years
15% per type; 2.5% per issuer
“A” for issuer’s debt; “AAA” for
issue
9. LAIF N/A
None
None
N/A
Limit per Gov’t Code
None
10. Negotiable CDs 5 Years
30% per type; none per issuer
None
5 Years
30% per type; 5% per issuer “AA”
or “A-1”
11. Collateralized Bank Deposits 5 Years
None
None
5 Years
None per type; 25% per institution
None
12. Money Market Mutual Funds N/A
20% per type; 10% per issuer
Highest rating of at least two
NRSRO
N/A
20% per type; 10% per issuer
Highest rating of at least two
NRSRO
13. Local Government Investment
Pools (LGIPs)
N/A
N/A
Advisor requirements
N/A
N/A
Advisor requirements/“AAA”
a. Up to 10% of the portfolio can be invested in Treasury and GSE securities maturing over 5 years. This includes
municipal obligations.
b. Includes State Obligations, City of San Luis Obispo obligations and California Local Agency obligations
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VI. INVESTMENT MATURITY
In addition to the risks associated with the creditworthiness of the financial institution and the
security of the investment vehicle, the maturity period of investments is also a significant
consideration in the management of the City's portfolio.
In order to minimize the impact of market risk, it is intended that all investments will be held until
maturity. In implementing this policy, the following guidelines will be used:
1. Projected cash flow requirements are the primary factor to be used in determining investment
maturity terms.
2. After cash flow needs have been met, investments may be structured in longer-term securities
within a disciplined investment program and process that is based on long-term expectations
and is not speculative.
3. Investments may be sold before maturity for cash flow purposes or to rebalance the risk profile
of the portfolio.
4. Council approval to make investments with terms in excess of five years is required at least three
months prior to the initial investment.
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VII. SUSTAINABILITY & ESG INVESTING
Environmental, social, and governance (“ESG”) investing is the process of incorporating the
analysis of non-financial environmental, social, and governance factors into investment decisions
alongside more traditional financial criteria. It is the City’s objective to integrate ESG and other
sustainability factors into investment decisions for its investment portfolio to the extent practical
and possible. In order to achieve this objective, the City will develop and apply ESG additional
screening investment criteria to authorized corporate obligations—, including asset-backed
securities, bankers’ acceptances, commercial paper, corporate/medium-term notes, bank notes, and
negotiable certificates of deposit —for purposes of determining investment eligibility.
The Sustainability & ESG iInvestment cCriteria will be based on the ESG risk ratings, industry and
sub-industry definitions, and sub-industry rankingsrules detailed below, which are provided by
Morningstar, Bloomberg, or another Sustainalyticsa reputable ranking rating agency. The ESG
investment criteria may include industry exclusions, ESG risk rating limitations, and eligibility
exceptions for issuers that are top performers within their subindustry. Thise cESG criteria will be
reviewed annually by City’s Investment Oversight Committee.
Sustainability & ESG Investment Criteria*
Criteria #1: Industry &
Subindustry Exclusions
Industry Exclusions:
(1) Energy Services
(2) Oil & Gas Producers
(3) Refiners & Pipelines
(4) Aerospace & Defense
(5) Paper & Forestry
(6) Private Corrections (based on Bloomberg BB Sector)
Subindustry Exclusions:
(7) Tobacco
Criteria #2: ESG Risk Rating
Limit
An eligible issuer’s ESG Risk Rating must be medium or lower (i.e.,
< 30 on a scale of 0-100, where lower scores indicate less ESG-
related risk)
Criteria #3: ESG Risk Rating
Limit Exception | Top ESG
Performers Within Peer Group
If Criteria #1 is satisfied, but #2 is not met, an issuer may still be
eligible if its ESG Risk Rating is in the high category (i.e., 30-39.99)
and its subindustry ranking is within the top 25th percentile
Acceptable Investments Subject
to the ESG Investment Criteria
Asset-Backed Securities
Bankers’ Acceptances
Commercial Paper
Corporate, Medium-Term & Bank Notes
Negotiable Bank Deposit Obligations
*The criteria outlined above will be based on issuer/parent corporation-level data as of the most recent
prior-month-end date.
The Sustainability & ESG Investment Parameters are in effect at time of purchase of the investment.
If a previously purchased investment no longer satisfies the City’s Sustainability & ESG iInvestment
cCriteria, the City will continue to hold that investment to maturity unless the City directs its
investment advisor to sell the investment.
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VIII. CASH MANAGEMENT PRACTICES
To achieve a reasonable return on public funds, the following cash management practices will be
followed:
1. Maintain maximum investment of all City funds not required to meet immediate cash flow needs
while maintaining adequate compensating balances as required under the City’s banking services
agreement.
2. Pool resources available for investment from all City-administered funds, with interest earnings
allocated to each of the funds in accordance with generally accepted accounting principles.
3. Maximize the City’s cash flow through the immediate deposit of all cash receipts, use of direct
deposits and wire transfers when available, and appropriate timing of payments to vendors.
4. Maximize the cash flow information available by using only one operating bank account.
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IX. EVALUATION OF INVESTMENT PERFORMANCE
As indicated in the Introduction section of this document, it is the City’s primary investment
objective to achieve a reasonable rate of return on public funds while minimizing risks and
preserving capital. In evaluating the performance of the City’s overall portfolio in achieving this
objective, it is expected that yields on City investments will regularly meet or exceed the returns of
a Treasury Index of similar duration.the average return on three-month U. S. Treasury Bills. It is
also expected that the portfolio managed by the investment advisor will meet or exceed the Bank of
America Merrill Lynch 0-to-5-year U.S. Treasury Bond Index.
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X. INVESTMENT REPORTING
Consistent with the guidance provided by California Government Code Section 53646 and the City’s
practice of reviewing the Financial Policies each year, the Finance Director/City Treasurer may
submit the Investment Policy to the Council for consideration at a public meeting. This statement
will generally be reviewed by the Council in conjunction with the Financial Plan review and
approval process. In accordance with this Statement of Investment Policy, the City Treasurer is
responsible for developing and maintaining this Investment Management Plan.
Though optional, pursuant to California Government Code Section 53646 (b)(1), the Finance
Director/City Treasurer will provide the Council and Investment Oversight Committee with a
quarterly investment report providing the following information for each investment or security:
1. Issuer (financial institution)
2. Type of investment
3. Amount paid for the investment
4. The par amount of the investment, if applicable
5. Certificate or other reference number if applicable
6. Percentage yield on an annualized basis
7. Purchase date
8. Maturity date for each investment and the weighted average maturity of all the investments within
the portfolio
9. Current book value
10. Current market value
11. Total cost and market value, including source of this valuation, of the City's portfolio
12. A description of the compliance with the Statement of Investment Policy
13. Information demonstrating that the City's expenditure requirements can be met in the following six
months
14. Other information regarding the City's portfolio as appropriate
The Investment Report shall include all investments as of the end of the quarter from all funds held in
the City's portfolio, including funds held and invested by trustees exclusive of deferred compensation
plan funds; and shall be issued within 30 days after the end of the quarterly reporting period.
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1. Within 60 days from the start of each fiscal year, the City Treasurer shall provide the Investment
Oversight Committee (IOC) with the value that represents the City’s minimum liquidity
requirement which is equal to 3 months of operating costs based on the most recently adopted
annual budget. Any adjustments to this amount which the Treasurer feels are required to meet
cash demands from time to time shall be identified by the Treasurer at each meeting of the IOC as
these amounts become known.
2. At the regularly scheduled IOC meeting which next follows the e nd of a fiscal year, the Treasurer
shall file a report which identifies how the invested balances were adjusted to accommodate the
City’s liquidity requirement and the extent to which investment maturity limits were adjusted to
follow the City’s benchmark duration value.
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XI. INVESTMENT POLICY AND MANAGEMENT PLAN REVIEW
The Finance Director/City Treasurer shall review the City's Investment Policy & Management Plan
on an ongoing basis to ensure its continued effectiveness and value in administering the City's
portfolio. Additionally, the City shall maintain an Investment Oversight Committee whose
membership shall consist of the Mayor, the City Manager, the Finance Director/City Treasurer, the
Deputy Director of Finance/Controller, the Principal Budget Analyst, and a member of the public at
large. The Investment Oversight Committee is responsible for:
1. Reviewing the City's portfolio at least quarterly to determine compliance with the Investment
Policy & Management Plan; and
2. Reviewing and making recommendations as appropriate regarding the City's investment policies
and practices at least annually.
It is important to note the distinction between the committee's oversight responsibility in ensuring
compliance with the policies and overall framework established in this plan, and the responsibility of
the Finance Director/City Treasurer in managing the City's investment portfolio in accordance with
this plan.
This distinction between management and oversight is especially important as it applies to the role of
the City's independent auditors. The committee's oversight function is consistent with the scope of the
auditor's engagement duties, which includes reviewing for compliance with City financial policies
and procedures, and for making recommendations for improvements in the City's fiscal operations.
However, in this oversight context, the auditors retain their independence from responsibility for
managing any aspects of the City's operations; this responsibility lies solely with the City's elected
leadership and staff.
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XII. GLOSSARY
Asset Backed Security is a security in which its income payments and value is derived from and
collateralized of “backed” by a specified pool of underlying assets, such as receivables.
Bankers’ Acceptances (BAs) are short-term credit arrangements to enable businesses to obtain
funds to finance commercial transactions. They are time drafts drawn on a bank by an exporter
or importer to obtain funds to pay for specific merchandise. By its acceptance, the bank becomes
primarily liable for the payment of the draft at maturity. An acceptance is a high-grade negotiable
instrument.
Benchmark is a market index used as a comparative basis for measuring the performance of an
investment portfolio. A performance benchmark should represent a close correlation to investment
guidelines, risk tolerance and duration of the actual portfolio's investments.
Bond is a financial obligation for which the issuer promises to pay the bondholder (the purchaser or
owner of the bond) a specified stream of future cash flows, including periodic interest payments and
a principal repayment.
Broker-Dealer is a person or a firm who can act as a broker or a dealer depen ding on the transaction.
A broker brings buyers and sellers together for a commission. They do not take a position. A dealer
acts as a principal in all transactions, buying and selling for his own account.
Certificates of Deposit (CDs)
Negotiable Certificates of Deposit are large-denomination CDs. They are issued at face
value and typically pay interest at maturity, if maturing in less than 12 months. CDs that mature
beyond this range pay interest semi-annually. Negotiable CDs are issued by U.S. banks
(domestic CDs), U.S. branches of foreign banks (Yankee CDs), and thrifts. There is an active
secondary market for negotiable domestic and Yankee CDs. However, the negotiable thrift CD
secondary market is limited. Yields on CDs exceed those on U.S. treasuries and agencies of
similar maturities. This higher yield compensates the investor for accepting the risk of reduced
liquidity and the risk that the issuing bank might fail. State law does not require the
collateralization of negotiable CDs.
Non-negotiable Certificates of Deposit are time deposits with financial institutions that earn
interest at a specified rate for a specified term. Liquidation of the CD prior to maturity incurs a
penalty. There is no secondary market for those instruments, therefore, they are not liquid. They
are classified as public deposits and financial institutions are required to collateralize them.
Collateral may be waived for the portion of the deposits that are covered by FDIC insurance.
Collateral refers to securities, evidence of deposits, or other property that a borrower pledges to
secure repayment of a loan. It also refers to securities pledged by a bank to secure deposits. In
California, repurchase agreements, reverse repurchase agreements, and public deposits must be
collateralized.
Commercial Paper is a short-term, unsecured, promissory note issued by a corporation to raise
working capital.
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Corporate Note is a debt instrument issued by a corporation with a maturity of greater than one year
and less than ten years.
Delivery Versus Payment (“DVP”) is a settlement procedure in which securities are delivered
versus payment of cash, but only after cash has been received. Most security transactions,
including those through the Fed Securities Wire system and Depository Trust Company (“DTC”),
are done DVP as a protection for both the buyer and seller of securities.
Depository Trust Company (“DTC”) is a firm through which members can use a computer to
arrange for securities to be delivered to other members without physical delivery of certificates. A
member of the Federal Reserve System and owned mostly by the New York Stock Exchange, the
Depository Trust Company uses computerized debit and credit entries. Most corporate securities,
commercial paper, CDs, and BAs clear through DTC.
Federal Agency Obligations are issued by U.S. Government Agencies or Government Sponsored
Enterprises (“GSE”). Although they were created or sponsored by the U.S. Government, most
Agencies and GSEs are not guaranteed by the United States Government. Examples of these securities
are notes, bonds, bills and discount notes issued by the Federal National Mortgage Association
(“Fannie Mae” or (“FNMA”), the Federal Home Loan Mortgage Corporation (“Freddie Mac” or
(“FHLMC”), the Federal Home Loan Bank system (“FHLB”), and Federal Farm Credit Bank
(“FFCB”). The Agency market is a very large and liquid market, with billions traded every day.
Investment Advisor is a company that provides professional advice managing portfolios, investment
recommendations and/or research in exchange for a management fee.
Issuer means any corporation, governmental unit, or financial institution that borrows money through
the sale of securities.
Liquidity refers to the ease and speed with which an asset can be converted into cash without loss of
value. In the money market, a security is said to be liquid if the difference between the bid and asked
prices is narrow and reasonably sized trades can be done at those quotes.
Local Agency Investment Fund (“LAIF”) is a special fund in the State Treasury that local agencies
may use to deposit funds for investment. There is no minimum investment period and the minimum
transaction is $5,000, in multiples of $1,000 above that, with a maximum of $50 million for any
California public Agency. It offers high liquidity because deposits can be converted to cash in twenty-
four hours and no interest is lost. All interest is distributed to those agencies participating on a
proportionate share determined by the amounts deposited and the length of time they are deposited.
Interest is paid quarterly via direct deposit to the Agency’s LAIF account. The State keeps an amount
for reasonable costs of making the investments, not to exceed one-quarter of one percent of the
earnings.
Market Value is the price at which a security is trading and could presumably be purchased or sold.
Maturity is the date upon which the principal or stated value of an investment becomes due and
payable.
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Medium-Term Notes are debt obligations issued by corporations and banks, usually in the form of
unsecured promissory notes. These are negotiable instruments that can be bought and sold in a large
and active secondary market. For the purposes of California Government Code, the phrase
“Medium-Term” refers to a maximum remaining maturity of five years or less. They can be
issued with fixed or floating-rate coupons, and with or without early call features, although the vast
majority are fixed-rate and non-callable. Corporate notes have greater risk than Treasuries or
Agencies because they rely on the ability of the issuer to make payment of principal and interest.
Money Market Fund is a type of safe investment comprising a variety of short-term securities with
high quality and high liquidity. The fund provides interest to shareholders and must strive to
maintain a stable net asset value (“NAV”) of $1 per share.
NRSRO is a “Nationally Recognized Statistical Rating Organization.” A designated rating
organization that the SEC has deemed a strong national presence in the U.S. NRSROs provide credit
ratings on corporate and bank debt issues. Only ratings of a NRSRO may be used for the regulatory
purposes of rating. Includes Moody’s, S&P Global, Fitch, and Duff & Phelps among others.
Principal describes the original cost of a security. It represents the amount of capital or money that
the investor pays for the investment.
Repurchase Agreements are short-term investment transactions. Banks buy temporarily idle funds
from a customer by selling him them U.S. Government or other securities with a contractual
agreement to repurchase the same securities on a future date at an agreed upon interest rate.
Repurchase Agreements are typically for one to ten days in maturity. The customer receives interest
from the bank. The interest rate reflects both the prevailing demand for Federal Funds and the
maturity of the Repurchase Agreemento. Repurchase Agreements must be collateralized.
Supranational entities are formed by two or more central governments with the purpose of
promoting economic development for the member countries. Supranational institutions finance their
activities by issuing debt, such as supranational bonds. Examples of supranational institutions
include the European Investment Bank and the World Bank. Similarly, to the U.S. government
bonds, the bonds issued by these institutions are considered direct obligations of the issuing nations
and have a high credit rating.
U.S. Treasury Issues are direct obligations of the United States Government. They are highly liquid
and are considered the safest investment security. U.S. Treasury issues include:
1. Treasury Bills which are non-interest-bearing discount securities issued by the U.S.
Treasury to finance the national debt. Bills are currently issued in one, three, six, and twelve-
month maturities.
2. Treasury Notes that have original maturities of one to 10 years.
3. Treasury Bonds that have original maturities of greater than 10 years.
Yield to Maturity is the rate of income return on an investment, minus any premium above par or
plus any discount with the adjustment spread over the period from the date of the purchase to the
date of maturity of the bond
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