HomeMy WebLinkAboutRES 17-109RESOLUTION NO. 17-109
BE IT RESOLVED BY THE CITY COUNCIL
OF THE CITY OF BEAUMONT:
THAT the City of Beaumont Investment Policy, substantially in the form attached hereto
as Exhibit 'A" has been reviewed and is hereby in all things adopted.
PASSED BY THE CITY COUNCIL of the City of Beaumont this the 30th day of
May, 2017.
0
-
Mabl Becky Ames -
a
a] :EIIjvAr*I
TEXAS
a a
uI I
m
mummmim
Adopted by
City Council
May 10, 2016
RE
•
City of Beaumont - Investment Policy
Table of Contents
I. Introduction................................................................................................................ I
II. Scope............................................................................................................................1
III. Prudence.....................................................................................................................1
IV. Objectives.................................................................................................................... I
A. Safety of Principal..........................................................................................2
B. Liquidity..........................................................................................................2
C. Public Trust....................................................................................................2
D. Yield................................................................................................................2
V. Delegation of Authority.........................................................:....................................2
VI. Ethics and Conflicts of Interest................................................................................3
VII. Training......................................................................................................................3
VIII. Selection of Financial Dealers, Institutions and Investments Pools .....................3
A. Broker/Dealers...............................................................................................4
B. Public Depositories.........................................................................................4
C. Investment Pools............................................................................................5
IX. Authorized and Suitable Investments......................................................................5
X. Competitive Environment.........................................................................................7
XI. Collateralization.........................................................................................................7
XII. Safekeeping and Custody..........................................................................................8
XIII. Diversification............................................................................................................9
XIV. Investment Strategies................................................................................................9
A. Pooled Fund Groups.....................................................................................10
B. Debt Service Funds.......................................................................................11
C. Debt Service Reserve Funds.........................................................................12
XV. Internal Control ......................
...12
XVI. Performance Standards.........................................................................................13
XVII. Reporting.................................................................................................................13
XVIII. Investment Policy Adoption...................................................................................13
Exhibits
Exhibit A - Approved List Broker/Dealers...........................................................................15
Exhibit B - Certification by Business Organization............................................................16
City of Beaumont
Investment Policy
I. Introduction
It is the policy of the City of Beaumont to invest public funds in a manner that will ensure
that the investments are duly authorized, properly managed, adequately protected and
fully collateralized. The City shall seek the optimum investment return with the
maximum security while meeting daily cash needs and conforming to the City Charter,
the Public Funds Investment Act (Chapter 2256, Government Code as amended) and all
other state and local statutes governing the investment of public funds.
II. Scope
This Investment Policy applies to all financial assets of the City as accounted for in the
City's Comprehensive Annual Financial Report. These include General, Special
Revenue, Debt Service, Capital Projects, Enterprise, Internal Service, and Permanent
Funds. All are pooled for investment purposes except debt service and debt service
reserve funds, and the natural gas account. Interest is allocated monthly to each fund
based on its individual cash balance.
III. Prudence
Investments shall be made with judgment and care, under prevailing circumstances, that
a person of prudence, discretion, and intelligence would exercise in the management of
the person's own affairs, not for speculation, but for investment, considering the probable
safety of capital and the probable income to be derived. The "prudent person" standard
shall be applied in the context of managing the total portfolio rather than a single
investment providing that the decision was consistent with this Investment Policy.
Investment Officers acting in accordance with written procedures and the Investment
Policy and exercising due diligence shall be relieved of responsibility for an individual
investment's credit risk or market price changes provided that deviations from exceptions
are reported in a timely fashion and appropriate action is taken to control adverse
developments.
IV. Objectives
The primary objectives, in priority order, of the City's investment activities shall be safety
of principal, liquidity, public trust, and yield.
A. Safety of principal
The City has as its foremost objective to ensure the safety of principal. Investments
of the City shall be undertaken in a manner that seeks to ensure the preservation of
principal in the overall portfolio. To attain this objective, diversification is required
in order to eliminate an over -concentration of assets in one institution, maturity or
type of investment, where appropriate.
B. Liquid
The City's investment portfolio will remain sufficiently liquid to enable the City to
meet all operating requirements that might be reasonably anticipated. The portfolio
shall be constructed so that investment maturities are matched with forecasted cash
flow requirements and limited by investments with an active secondary market or
convertible to cash with little or no penalty.
C. Public Trust
Investment Officers shall seek to act responsibly as custodians of the public trust.
Investment Officers shall avoid any transaction that might impair public confidence
in the City's ability to govern effectively.
D. Yield
The City's investment portfolio shall be designed with the objective of attaining a
rate of return that is consistent with risk limitations and cash flow characteristics of
the City's investments.
V. Delegation of Authority
Authority to manage the City's investment program is derived from the City Charter
(article VII, section 1-2). The Charter designates the City Manager as Director of Finance
who shall have custody of all public funds, investments, bonds and notes of the City and
be responsible for their safekeeping. The City Manager shall establish written
procedures for the operation of the investment program consistent with this Investment
Policy that include explicit delegation of authority to persons responsible for investment
transactions. The City Manager shall be responsible for all transactions undertaken and
shall establish a system of controls to regulate the activities of subordinate officials.
The City Manager, the Chief Financial Officer, and the City Controller are approved as
Investment Officers of the City. Such approval of specific persons shall remain in effect
until rescinded by the City Council or until termination of the person's employment by
the City. Investment Officers shall not deposit, withdraw, transfer or manage the funds
of the City in a manner that is not consistent with the "prudent person" standard as
described in section III of this Policy.
The City Council maintains the right to hire Investment Advisers to assist City staff in
the investment of funds. Investment Advisers shall adhere to the spirit, philosophy and
specific terms of this Policy and shall invest within the same objectives. The City
Manager shall establish criteria to evaluate Investment Advisers, including:
1. Adherence to the City's policies and strategies;
2. Investment strategy recommendations within accepted risk constraints;
3. Responsiveness to the City's request for services and information;
4. Understanding of the inherent fiduciary responsibility of investing public
funds; and
5. Similarity in philosophy and strategy with the City's objectives.
Selected Investment Advisers must be registered under the Investment Advisers Act of
1940 or with the State Securities Board. A contract with an Investment Adviser may
not be for a term longer than two years and any contract, renewal or extension must be
approved by the City Council.
VI. Ethics and Conflicts of Interest
Investment Officers and employees involved in the investment process shall refrain from
personal business activity that could conflict with proper execution of the investment
program, or which could impair their ability to make impartial investment decisions.
Investment Officers shall disclose any personal business relationships with business
organizations approved to conduct investment transactions with the City. They shall also
disclose any specific individuals who seek to sell investments to the City and are related
to the Investment Officer within the second degree by affinity or consanguinity, as
determined under Chapter 573. Disclosure shall be filed with the Texas Ethics
Commission and the City Council.
VII. Training
In order to ensure qualified and capable investment management, each Investment
Officer shall attend at least ten (10) hours of training relating to investment
responsibilities within 12 months after assuming such duties and shall continue to attend
an investment training session consisting of at least eight (8) hours of instruction not less
than once every two years thereafter. The two-year period shall begin on the first day of
the City's fiscal year and consist of the two consecutive fiscal years after that date.
Training shall be in accordance with the Public Funds Investment Act and include
education in investment controls, security risks, strategy risks, market risks, and
compliance with State statutes governing the investment of public funds. All training
shall be conducted by an independent source that has been approved by City Council.
The approved "independent sources" to provide such training are: the Government
Treasurers Organization of Texas, the Government Finance Officers Association, the
Government Finance Officers Association of Texas, the Texas Municipal League, and
the University of North Texas.
VIII. Selection of Broker/ Dealers, Financial Institutions and Investment Pools
Authorized investments shall only be purchased from those institutions selected and
approved in accordance with this Policy.
Any business organization which seeks to execute investment transactions with the City
shall provide a written instrument certifying that they have received and thoroughly
reviewed the City's Investment Policy and have implemented reasonable procedures and
controls in an effort to preclude investment transactions that are not authorized by this
Policy. The certification, as shown by example in Exhibit B, must be signed by a
qualified representative of the business organization. Investment Officers shall not buy
any securities from a firm or make deposits with a fund, pool or financial institution that
has not filed this instrument or a similar statement that is acceptable to the City. Each
time City Council approves a material revision to the Investment Policy, tl:e
certification should be sent to the approved business organizations along with the
newly revised Investment Policy.
A. Broker/Dealers
The City shall select broker/dealers by their ability to provide effective market
access and may include "Primary Government Securities Dealers" or regional
dealers that qualify under Securities and Exchange Commission (SEC) Rule 15C3-
1 (uniform net capital rule). Broker/dealers selected must be members in good
standing of the Financial Industry Regulatory Authority ("FINRA"), and be
licensed by the State of Texas. Each broker/dealer will be reviewed by the
Investment Officers and a recommendation will be made for approval by the City
Council.
An "approved broker/dealer list", as shown in ExhibitA, shall be maintained by the
Investment Officers at all times and approved by the City Council on an annual
basis.
The City shall not enter into transactions with a broker/dealer until official City
Council approval.
B. Public Depositories/Financial Institutions
The City Council shall select a primary depository as required by law. The primary
depository as authorized by the City Council shall meet all requirements of the state
law concerning depositories for municipal funds (Chapter 105, Government Code).
The primary depository shall be selected through the City's banking services
procurement process, including a formal Request for Application (RFA) issued in
compliance with applicable State law, and offers the most favorable terms and
conditions for the handling of City funds.
The City may also establish agreements with other financial institutions under
separate contract for additional services that are necessary in the administration,
collection, investment, and transfer of municipal funds. Such deposits will only be
made after the financial institution has completed and returned the required written
instruments and depository pledge agreements. No deposit shall be made except in
a qualified public depository as established by State Law.
C. Investment Pools
Investment Officers may invest funds of the City through an eligible investment
pool with specific approval by resolution of City Council and execution of a written
agreement. To become eligible, investment pools must first meet all requirements
of State Law. They shall provide the City with an offering circular that contains
specific and detailed information, investment transaction confirmations, and
detailed monthly transaction and performance reports. Pools shall have advisory
boards composed of qualified members representing participants and non-
participants who do not have a business relationship with the pool. Before
selection, pools shall be thoroughly reviewed and evaluated by the Investment
Officers.
IX. Authorized and Suitable Investments
Authorized investments for municipal governments in the state of Texas are set forth in
the Public Funds Investment Act, as amended. Suitable investments for the City are
limited to the following:
♦ Direct Obligations of the United States or its agencies and instrumentalities that
have a maximum stated maturity date of 5 years or less.
♦ Financial institution deposits placed with approved financial institutions as
described above (section VIII -B) which have a maximum stated maturity date of 5
years or less and are insured by the Federal Deposit Insurance Corporation, or their
successors; or secured as described in section XI Collateralization. Additionally,
the City may execute certificates of deposit, and other forms of deposit, in any
manner authorized by the Public Funds Investment Act.
♦ Fully collateralized direct repurchase agreements with a defined termination date
of 90 days or less which are secured by cash or obligations of the United States or
its agencies and instrumentalities and pledged with a third party'other than an agent
for the pledgor. Investment Officers may invest in repurchase agreements through
an approved primary government securities dealer or an approved depository bank
as described above (section VIII -A, B). Each issuer of repurchase agreements shall
be required to sign a master repurchase agreement. For flexible repurchase
agreements executed with bond proceeds, the defined termination date of 90 days
or less may be waived to allow the term of the flexible .repurchase agreement to
more closely match the expected term of the bond project.
♦ No load money market mutual funds registered with and regulated by the Securities
and Exchange Commission whose investment objectives include the maintenance
of a stable net asset value of $1 per share. Money market mutual funds must
maintain a AAAm, or equivalent rating from at least one nationally recognized
rating agency; and provide the City with a prospectus and other information
required by the Securities and Exchange Act of 1934 and be specifically approved
by City Council or purchased through the City's primary depository as an overnight
investment tool. The City may not own more than 10% of tl:e money market
mutual fund's total assets.
♦ Approved investment pools as described above (section VIII -C) which are
continuously rated no lower than AAA, AAA -m or an equivalent rating by at least
one nationally recognized rating agency.
Investments Not Authorized - The following investments are not authorized under this
section:
a. Obligations whose payment represents the coupon payments on the outstanding
principal balance of the underlying mortgage-backed security collateral and pay no
principal;
b. Obligations whose payment represents the principal stream of cash flow from the
underlying mortgage-backed security collateral and bears no interest;
c. Collateralized mortgage obligations that have a stated final maturity date of greater
than ten years; and
d. Collateralized mortgage obligations the interest rate of which is determined by an index
that adjusts opposite to the changes in a market index.
Not less than quarterly, the Investment Officers will monitor the credit rating for each
held investment that has a Public Fund Investment Act required minimum rating. Any
Authorized Investment that requires a minimum rating does not qualify during the period
the investment does not have the minimum rating. Prudent measures will be taken to
liquidate an investment that is downgraded to less than the required minimum rating.
The City is not required to liquidate investments that were authorized investments at the
time of purchase.
The purchase of stock is not an authorized investment for municipal governments.
However, stock may be accepted as a donation, provided that it is held in accordance with
the terms of the donation and sold as soon as it is advantageous to do so. Reinvestment
of proceeds must be in accordance with authorized and suitable investments for the City
as listed above.
X. Competitive Environment
It is the policy of the City to provide a competitive environment for all individual security
purchases and sales, financial institution deposits, and money market mutual fund and
local government investment pool selections. The Investment Officers shall develop and
maintain procedures for ensuring competition in the investment of the City's funds.
X1. Collateralization
Collateralization will be required on all financial institution deposits and repurchase
agreements. With the exception of deposits secured with irrevocable letters of credit at
100% of amount, the collateralization level shall be equal to at least one hundred two
percent (102%) of the aggregate market value of the deposit or investment including
accrued interest less an amount insured by the Federal Deposit Insurance Corporation.
Evidence of the pledged collateral shall be documented by a custodial or a master
repurchase agreement with the eligible collateral clearly listed in the agreement.
Collateral shall be reviewed at least monthly to assure that the market value of the
securities pledged equals or exceeds the related deposit or investment requirement.
Collateral requirements shall be in accordance with both the Public Funds Investment
Act and the Public Funds Collateral Act. Collateral underlying repurchase agreements is
limited to direct obligations of the United States or its agencies and instrumentalities.
The City shall accept a surety bond or the following investment securities as collateral
on deposits and certificates of deposit:
♦ Direct obligations of the United States or its agencies and instrumentalities. Direct
obligations of this state or its agencies and instrumentalities.
♦ Collateralized mortgage obligations directly issued by a federal agency or
instrumentality of the United States and excluding those mortgage backed securities
considered a high-risk mortgage security as described by Section 2257.0025 of the
Government Code.
♦ Other obligations that are guaranteed or backed by the full faith and credit of this
state or the United States or their respective agencies and instrumentalities.
♦ Obligations of states, agencies, counties, cities and other political subdivisions
rated not less than A or its equivalent.
♦ Letters of credit issued by the United States or its agencies and instrumentalities.
Financial institutions serving as depositories will be required to sign a depository
agreement with the City. The collateralized deposit portion of the agreement shall define
the City's rights to the collateral in case of default, bankruptcy or closing and shall
establish a perfected security interest in compliance with Federal and State regulations,
including:
1. The agreement must be in writing;
2. The agreement has to be executed by the Depository and the City
contemporaneously with the acquisition of the asset:
3. The agreement must be approved by the Board of Directors or designated
committee of the Depository and a copy of the meeting minutes must be
delivered to the City; and
4. The agreement must be part of the Depository's "Official Record"
continuously since its execution.
XII. Safekeeping and Custody
Collateral shall be placed for safekeeping in a custodial account at the Federal Reserve
Bank or at an institution not affiliated with a firm pledging collateral acceptable to the
City. All safekeeping arrangements shall clearly define the responsibilities of each parry
and outline the steps to be taken in order for the City to gain access to the collateral in
the event of a "failure". The custodial agreement shall be executed between the City, the
firm pledging the collateral and the custodial institution, as applicable. All safekeeping
receipts shall be delivered to the City and all collateral (whether a pledge or substitution)
shall be formally accepted and released by Investment Officers.
All security transactions, including collateral for repurchase agreements, entered into by
the City shall be conducted on a delivery -versus -payment (DVP) basis. That is, funds
shall not be wired or paid until verification has been made that the correct security was
received by the safekeeping institution. Financial institution deposits, pool funds, and
mutual funds are excluded from this requirement. The investment shall be held in the
name of the City or on behalf of the City.
XIII. Diversification
The City will diversify its investments to eliminate an over -concentration of assets in any
one security,type or institution.
♦ Up to ninety percent (90%) par of the portfolio may be invested in direct obligations
of the United States (U.S. Treasury Securities).
♦ Up to seventy percent (70%) par of the portfolio may be invested in U.S. Agency
or Instrumentalities.
♦ No more than thirty percent (30%) par of the portfolio may be invested with any
one U.S. Agency or Instrumentality.
♦ Up to one hundred percent (100%) par of the portfolio may be invested in
investment pools for liquidity purposes with no more than eighty percent (80%) par
of the portfolio invested in any one pool.
♦ No more than fifty percent (50%) par of the portfolio may be invested in money
market mutual funds.
XIV. Investment Strategies
The City shall maintain a separate investment strategy for each of the fund types
represented in the portfolio.
A. Pooled Fund Groups
Suitability — Any investment eligible in the Investment Policy is suitable for
Pooled Fund Groups.
Safety of Principal — All investments shall be of high quality with no
perceived default risk. Market price fluctuations will occur. However,
managing the weighted average days to maturity of each fund's portfolio to
less than 365 days and restricting the maximum allowable maturity to three
years using the final stated maturity dates of each investment will minimize
the price volatility of the portfolio.
Marketability — Investments with active and efficient secondary markets are
necessary in the event of an unanticipated cash flow requirement. Historical
market "spreads" between the bid and offer prices of a particular security -type
of less than a quarter of a percentage point will define an efficient secondary
market.
Li uidi — Pooled Fund Groups require the greatest short-term liquidity of
any of the fund -types. Short-term financial institution deposits, investment
pools and money market mutual funds will provide daily liquidity and may be
utilized as a competitive yield alternative to fixed maturity investments.
Diversification — Investment maturities should be staggered throughout the
budget cycle to provide cash flow based on the anticipated operating needs of
the City. Diversifying the appropriate maturity structure up to the three-year
maximum will reduce interest rate risk.
Yield — Attaining a competitive market yield for comparable investment -types
and portfolio restrictions is the desired objective. The yield of an equally
weighted, rolling three-month Treasury Bill portfolio will be the minimum
yield objective.
B. Debt Service Funds
Suitability — Any investment eligible in the Investment Policy is suitable for
Debt Service Funds.
Safety of Principal — All investments shall be of high quality with no
perceived default risk. Market price fluctuations will occur. However, by
managing Debt Service Funds to not exceed the debt service payment schedule
the market risk of the overall portfolio will be minimized. The stated final
maturity date on investments purchased shall not exceed the debt service
payment date unless excess funds are available. In that case, maximum
maturities shall not exceed two (2) years from the date of purchase.
Marketability — Investments with active and efficient secondary markets are
not necessary as the event of an unanticipated cash flow requirement is not
probable.
Liquid — Debt Service Funds have predictable payment schedules.
Therefore investment maturities should not exceed the anticipated cash flow
requirements. Financial institution deposits, investments pools, and money
market mutual funds may provide a competitive yield alternative for short-
term fixed maturity investments. A singular repurchase agreement may be
utilized if disbursements are allowed in the amount necessary to satisfy any
10
debt sei vice payment. This investment structure is commonly referred to as a
flexible repurchase agreement.
Diversification — Market conditions influence the attractiveness of fully
extending maturity to the next "unfunded" payment date. Generally, if
investment rates are anticipated to decrease over time, the City is best served
by locking in most investments. If the interest rates are potentially rising, then
investing in shorter and larger amounts may provide advantage. At no time
shall the debt service schedule be exceeded in an attempt to bolster yield.
Yield — Attaining a competitive market yield for comparable investment -types
and portfolio restrictions is the desired objective. The yield of an equally
weighted, rolling three-month Treasury Bill portfolio shall be the minimum
yield objective.
C. Debt Service Reserve Funds
Suitability — Any investment eligible in the Investment Policy is suitable for
Debt Service Reserve Funds. Bond resolution and loan documentation
constraints and insurance company restrictions may create specific
considerations in addition to the Investment Policy.
Safety of Principal — All investments shall be of high quality with no
perceived default risk. Market price fluctuations will occur. However, by
managing Debt Service Reserve Fund maturities to generally not exceed the
call provisions of the borrowing will reduce the investment's market risk if the
City's debt is redeemed and the Reserve Fund liquidated. No stated final
investment maturity shall exceed the shorter of the final maturity of the
borrowing or five years. Annual mark -to -market requirements or specific
maturity and average life limitations within the borrowing's documentation
will influence the attractiveness of market risk and influence maturity
extension.
Marketability — Investments with less active and efficient secondary markets
are acceptable for Debt Service Reserve Funds.
Li uidi — Debt Service Reserve Funds have no anticipated expenditures.
The Funds are deposited to provide annual debt service payment protection to
the City's debt holders. The funds are "returned" to the City at the final debt
service payment. Market conditions and arbitrage regulation compliance
determine the advantage of investment diversification and liquidity.
Generally, if investment rates exceed the cost of borrowing, the City is best
seived by locking in investment maturities and reducing liquidity. If the
11
borrowing cost cannot be exceeded, then concurrent market conditions will
determine the attractiveness of locking in maturities or investing shorter and
anticipating future increased yields.
Diversification — Market conditions and the arbitrage regulations influence
the -attractiveness of staggering the maturity of fixed rate investments for Debt
Service Reserve Funds. At no time shall the final debt service payment date
of the bond issue be exceeded in an attempt to bolster yield.
Yield — Achieving a positive spread to the applicable borrowing cost is the
desired objective. Debt Service Reserve Fund portfolio management shall
operate within the limits of the Investment Policy's risk constraints.
D. Natural Gas Account
Suitability — Any investment eligible in the Investment Policy is suitable for
the Natural Gas Account.
Safety of Principal — All investments shall be of high quality with no
perceived default risk. Market price fluctuations will occur. However,
managing the weighted average days to maturity to less than 365 days and
restricting the maximum allowable maturity to three years using the final stated
maturity dates of each investment will minimize the price volatility of the
portfolio.
Marketability — Investments with active and efficient secondary markets are
necessary in the event of an unanticipated cash flow requirement. Historical
market "spreads" between the bid and offer prices of a particular security -type
of less than a quarter of a percentage point will define an efficient secondary
market.
Liquidity -Natural Gas Account funds require moderate short-term liquidity.
Short-term financial institution deposits, investment pools and money market
mutual funds will provide daily liquidity and may be utilized as a competitive
yield alternative to fixed maturity investments.
Diversification — Investment maturities should be staggered throughout the
anticipated expenditure schedule. Diversifying the appropriate maturity
structure up to the three-year maximum will reduce interest rate risk.
Yield — Attaining a competitive market yield for comparable investment -types
and portfolio restrictions is the desired objective. The yield of an equally
weighted, rolling three-month Treasury Bill portfolio will be the minimum
yield objective.
12
XV. Internal Control
The City, in conjunction with its annual financial audit, shall perform a compliance
audit of management controls on investments and adherence to the City's
Investment Policy.
XVI. Performance Standards
The City intends to pursue an active versus a passive portfolio management
philosophy. That is, investments may be sold or redeemed before they mature if
market conditions present an opportunity for the City to benefit from the trade.
The investment portfolio shall be designed with the objective of obtaining a rate of
return throughout budgetary and economic cycles that is consistent with risk
limitations and cash flow needs of the City. "Weighted average yield to maturity"
shall be the portfolio performance measurement standard.
XVII. Reporting
Investment Officers shall submit a monthly report to City Council summarizing the
results of the City's investment activity. This report shall include the status of the
current portfolio position, performance, trading activity, interest earnings, and
collateral.
A quarterly report shall be submitted to the City Manager, as Chief Executive
Officer, and the City Council detailing investment transactions and performance
for the reporting period in accordance with State law. The report shall be jointly
prepared and signed by all Investment Officers. It shall include a summary
statement prepared for each fund type and a detailed listing that states the beginning
market value, ending market value and fully accrued interest for the period. In
addition, Investment Officers shall report on adherence to the City's investment
strategies as expressed in this Policy.
In conjunction with the annual audit, the quarterly reports shall be formally
reviewed by the City's independent auditor on an annual basis and the results of the
review shall be reported to City Council.
XVIII. Investment Policy Adoption
The City's Investment Policy is hereby adopted by resolution of the City Council.
The City Council shall review and approve the Policy on an annual basis. This
Policy serves to satisfy the statutory requirement to define and adopt a formal
investment policy.
13
EXHIBITS
14
Exhibit A
CITY OF BEAUMONT
Approved List
Broker/Dealers
Business/Orizanizations
Broker/Dealers:
Coastal Securities
Duncan -Williams, Inc.
JP Morgan Chase Securities
Mutual Securities, Inc.
Oppenheimer & Co.
Rice Financial Products Company
Raymond James
Wells Fargo Brokerage Services, LLC
Certificate of Deposit Purchase Program:
PFM Asset Management LLC
15
Exhibit B
City of Beaumont, Texas
Certification By Business Organization
This certification is executed on behalf of the City of Beaumont (the Investor) and
(the Business Organization) pursuant to the Public Funds
Investment Act, Chapter 2256, Texas Government Code (the Act) in connection with investment
transactions conducted between the Investor and the Business Organization.
The undersigned Qualified Representative of the Business Organization hereby certifies on behalf
of the Business Organization that:
1. The undersigned is a Qualified Representative of the Business Organization offering to
enter an investment transaction with the Investor as such terms are used in the Public Funds
Investment Act, Chapter 2256, Texas Government Code and
2. The Qualified Representative of the Business Organization has received and reviewed the
Investment Policy furnished by the Investor and
The Qualified Representative of the Business Organization has implemented reasonable
procedures and controls in ani effort to preclude investment transactions conducted between
the Business Organization and the Investor that are not authorized by the Investor's
Investment Policy, except to the extent that this authorization is dependent on an analysis
of the makeup of the Investor's entire portfolio or requires and interpretation of subjective
investment standards.
(Firm)
Qualified Representative of the Business Organization
(Signature)
(Name)
(Title)
(Date)
Ml