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HomeMy WebLinkAboutRES 24-269RESOLUTION NO.24-269 BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF BEAUMON`I": WHEREAS, State law mandates the City Council to review the Investment Policy and improve modifications, if any, on an annual basis; and, WHEREAS, this year the following changes were made: 1. Page 2 -- Confirni/change titles of Investment Officers since former CFOs resignation; and, 2. Page 5 — Addition of national Credit Union Share Investment language; and, 3. Page 6 - $1.000 per share for MMMF; and, 4. Page 7 -- Collateralization language update to include NCUSIF and clarity; and, 5. Page S — FIRREA language "must" consistency and safekeeping language clarification; and, 6. Exhibit A Broker/Deal list --- removal of one broker/Dealer 7. A few minor changes numbering and granunatical updates; NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF BEAUMONT: THAT the Council be and they are hereby authorized to approve the City of Beaumont Investment Policy as amended. The meeting at which this resolution was approved was in all things conducted in strict compliance with the Texas Open Meetings Act, Texas Goveriu- ent Code, Chapter 551. PASSED BY THE CITY COUNCIL of the City of Beaumont this the 29th day of October, 2024. No Text �[�7:ki TEXAS Investment Policy Adopted by City Council October 29, 2024 City of Beaumont - Investment Policy Table of Conteitts 1. Introduction ................................................................................................................ it. Scope ..................... .......................................................................................................I III. Prudence.....................................................................................................................1 IV. Objectives....................................................................................................................1 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 VILTraining......................................................................................................................3 VIII. Selection of Financial Dealers, Institutions altd Investments Pools .....................A A. Broker/Dealers.H.Hf..F..N......................................................................H.........4 B. Public Depositories.........................................................................................4 C. Investincict Pools............................................................................................5 IX. Authorized and Suitable Investments......................................................................5 X. Competitive Environment.........................................................................................7 XI. Collate)'alizRtion......................................................................... 4........................H..a 11 7 XII. Safekeeping and Custody..........................................................................................8 XIII, Diversification............................................................................................................8 XIV, Investment Strategies ......................................................................................I.........9 A. Pooled Ferrol Groups.......................................................................................9 B. Debt Service Funds .......................................................................................10 C. Debt Service Reserve Funds.........................................................................10 D. Natural Gas Account................................................................11 XV. Internal Control......................................................................................................12 XVT. Performance Standards.........................................................................................12 XVII. Reporting.................................................................................................................12 XVIII. Investment Policy Adoption...................................................................................13 Exhibit Exhibit A - Approved List Bross.er/Deaiers...........................................................................1.5 City of Beallmont Investment Policy I. Introduction It is the policy of the City of Beaumont to invest public Rinds in a manner that will ensure that the investments are duly authorized, properly managed, adequately protected and fully collateralized. The City shall seek the optimunx investment return with the maximum security while meeting daily Cash needs and Conforming to the City Charter, the Public Funds hivestntent ,Act (Chapter 2256, Govenunent Code as amended) and all other state and local statutes governing the investment of public fiends, If. Scope This Investment Policy applies to all financial assets of the City as accounted for in the City's Annual Comprehensive (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, tinder 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 (fiat 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 at#ain 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. Liguidily The City's investment portfolio will remain sufficiently liquid to eatable the City to meet all operating requirements that might be reasonably anticipated. Tlie 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, boards 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 parsons 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 Deputy Controller are approved as Investment Officers of the City. Such approval of specific personas 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 maiuier 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 Adviser's to assist City staff in the investment of fluids. Investment Advisees shall adhere to the spirit, philosophy and specific terms of this policy and shall invest within the same objectives. The City Manager sliall establish criteria to evaluate Investment Advisers, including; A. Adherence to the City's policies and strategies; B. Investment strategy recommendations within accepted risk constraints; C. Responsiveness to the City's request for services and information; D. Understanding of the inherent fiduciary responsibility of investing public finds; and E. 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 Intex-est 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 wlxo 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. VIL Ti-aining In order to ensure qualified and capable investment management, each Investment Officer shall attend at least tell (10) hours of training relating to investment fesponsibilitics 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 thefeafter, 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: (lie Governinent Treasurers Organization of Texas, the Government Finance Officers Association, the Goveniment Finance Officers Association of Texas, the Council of Governments, the Texas Municipal League, and the University of North Texas. VIII<. Selection of Broker/ Dealers, Financial Institutions and Investment ;fools Authorized investments shall only be purchased from those institutions selected and approved in accordance with this Policy, Any investment pool or discretionary investment management firm 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. Ewch file City C01mcil al),proves a material revision to the Investment Policy, the newly revised Investment Policy must be sent to the gliproved investment pool or discretionary invest)llent management firm and a business eertification should be oblaineel. 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 Conunission (SEC) Rule 1 SC3- 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 ExhillitA, shall be maintained by the Investment Officers at all times and approved by the City Council oil an annual basis. The City shall not enter into transactions with a broker/dealer until official City Council approval, B. Public Depositorics/Financial Institutions The City Council shall select a primary depository as required by law. The primary depository as authorized by (lie City Council shall meet all requirements of the state law concerning depositories for municipal finds (Chapter 105, Government Code), The primary depository shall be selected through the City's banking services procurement process, including a formal Request for Application (RI:A) 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 fools Investment Officers may invest hinds 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, hweshuent transaction confirinations, and detailed niontbly 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 folill 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 Vill-B) which have a maximum stated maturity date of 5 years or less and are insured by the Federal Deposit Insurance Corporation (FDIC), National Credit Union Share Insurance (NCUSIF), or their successors; or secured as described in section XI Collateral ization. Additionally, the City may execute certificates of deposit, and other forms of deposit, in any manner authorized by the Public Funds Investment Act. Dully 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 goverrunent securities dealer or an approved depository bank as described above (section VIII-A, B). Each issuer of repurchase agreements sliall 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 terns of the flexible repurchase agreement to more closely match the expected terns of the bond project. No load money ►narket mutual fiends registered with and regulated by the Securities and Exchange Commission whose investment objectives include the maintenance of a stable net asset value of $1.0000 per share. Money market mutual funds musk maintain a AAAm, or equivalent rating from at least one nationally recognized rating agency; have an average weighted maturity of less than two years; 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 Ynay not own more than 10% of the monel mat -fret inuffrrrl fitnrl'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 Author-iizeu - 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 Cho so. Itemvestment 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 governnnnent investment pool selections, The Investment Officers shall develop and maintain procedures for ensuring competition in the investment of the City's funds. XI. Collateralization Collateralizationn 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 principle plus anticipated accrued interest, the collateralization level shall be equal to at least one hundred two percent (102%) of (lie aggregate market value of the deposit or investment including accrued interest less an amount insured by the FDIC or NCUSIK 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 (lie 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 financial institution deposits: ■ 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 requi€ed to sign a depository agreement with the City. The collateralized deposit portion of the agreement shall defino 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; I . The agreement must be in writing; 2. The agreement must be executed by the Depository and the City contemporaneously with the acquisition of the asset; I 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 d. The agreement must be part of the Depository's "Official Record" continuously Since its execution. XIL Safekeeping and Custody Collateral shall be placed for safekeeping in a custodial account at the, Federal Reserve Bank or at all institution not affiliated with, a firth pledging collateral acceptable to the City. All safekeeping arrangements shall clearly define the responsibilities of each party and outline the steps to be taken in order for the City to gain access to the collateral ill 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 oil a delivery -versus -payment (DVP) basis. That is, finds 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 fiends, and mutual fonds are excluded from this requirement. The investment shall be held by a third -party safekeeping agent 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. Up to one hundred percent (100%) par of the portfolio ,may be invested ill 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, Investinerrt Strategies Tile City shall maintain a separate investment strategy for each of the fiend types represented in the portfolio, A, Pooled Fund Groups Suitability -- Any investment eligible in the Investment Policy is suitable for Tooled Fund Groups. Safe of Principal — All investments shall be of high duality with no porceived default risk. Market price fluctuations will occur. However, managing the weighted average days to maturity of each Rind's portfolio to less than 365 days and restricting the maximum allowable maturity to three years using file final stated maturity dates of each investment will minimize the price volatility of the portfolio. Li uidi — Pooled Fund Groups require the greatest short-term liquidity of any of the fiend -types, Short-term financial institution deposits, investment pools and money market Mutual fiinds will provide daily liquidity and may be utilized as a competitive yield alternative to fixed maturity investments. Marlretabilrty — 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 particular security -type of less than a quarter of a percentage point will define an efficient secondary market. Diversification Investment maturities should be staggered throughout the budget cycle to provide cash flow based oil the anticipated operating heeds of the City. Diversifying the appropriate maturity structure tip 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 air equally weighted, rolling three-month Treasury Bill portfolio will be the ininiinutu yield objective. B. Debt Service Funds Suitability Any itivestrnent eligible in the Investment Policy is suitable for Debt Service Funds. Safety of P0116VAl — 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. Tire stated filial maturity date oil investments purchased shall not exceed the debt service payment date unless excess Rinds are available. In that case, maximum maturities shall not exceed two (2) years from the date of purchase. Liquidity — Debt Service braids have predictable payment schedules. Therefore, investment maturities should not exceed the anticipated cash flow requirements. Financial institution deposits, investments pools, and money market mutual Rinds may provide a competitive yield alternative for short- terin fixed maturity investments. A singular repurchase agreement may be utilized if disbursements are allowed in the amount necessary to satisfy any debt service payment. This investment structure is commonly referred to as a flexible repurchase agreement. Marlcetability Investments with active and efficient secondary markets are not necessary as the event of an unanticipated cash flow requirement is not probable. Diversification Market conditions influence the attractiveness of frilly 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 all advantage. At no time shall the debt service schedule be exceeded in all attempt to bolster yield. Yield —Attaining a competitive market yield for comparable investnientwtypes and portfolio restrictions is the desired objective. The yield of an equally weighted, rolling three-month Treasury Bill portfolio sliall be the minitnutn yield objective. C. Debt Serwiee Reserve Funds Suitability — Any itrvesttnent 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. 10 Safety of Principal All investments shall be of High quality with aro 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 (lie investment's market risk if the City's debt is redeemed and (lie Reserve Fund liquidated. No stated filial 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. Li Midi -- Debt Service Reserve Funds have no anticipated expenditures. The Funds are deposited to provide annual debt service payment protection to the City's debt holder.-,. 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 served by locking in investment maturities and reducing liquidity. If the borrowing cost carinot be exceeded, then concurrent market conditions will determine the attractiveness of locking in maturities or investing shorter and anticipating fixture increased yields. Marketability — Investments with less active and efficient secondary markets are acceptable for Debt Service Reserve Funds. 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 sliall the filial debt service payment date of the bond issue be exceeded in all attempt to bolster yield. Yield -- Achieving a positive spread to the applicable borrowing cost is the desired objective. Debt Service Reserve Fluid portfolio management shall operate within the limits of the Investment Policy's risk constraints. D. Natural Gus Account Suitabili — 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 filial slated maturity dates of each investment will minimize the price volatility of the portfolio, Li midi — Natural Gas Account fiends require moderate short -terra liquidity. Short -terns financial institution deposits, investment fools and money market mutual fiends will provide daily liquidity and may be utilized as a competitive yield alternative to fixed maturity investments, Marketability — Investments with active and efficient secondary markets are necessary in the event of an unanticipated cash flow requitement, 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. )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. XV. 111ternal 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. XVL 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. Tire investment portfolio shall be designed with the objective of obtaining a rate ofreturn throughout budgetary and economic cycles that is consistent with risk limitations and cash flow creeds of the City. "Weighted avefage yield to maturity" shall be the portfolio performance measurement standard. XVIL 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 Execrative Officer, and the City Council detailing investment transactions and performance for the reporting period in accordance with State law. The report shall he jointly prepared and signed by all Investment Officers. It shall include a summary statement prepared for each hand 12 type and a detailed listing that states the beginnijig market value, ending Market value and fully accrued interest for the period, In addition, Investment Officers shall report Oil adherence to the City's investment strategies as expressed in this Policy. In conjunction with the annual audit, the quarterly reports sliall be formally reviewed by the City's independent auditor on an amival basis and the results of the review shall be reported to City Council. X'VI11. 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 selves to satisfy the statutory requirement to define and adopt a formal investment policy. 13 EXHIBIT 14 Exhibit A CITY OF BEAUMONT Approved List Broker/Dealers BR-olm-Mcalci•s: FUN Financial Capital Markets Oppenheimer & Co, RBC Capital Markets Wells Fargo Securities PNC Investments LLC Hilltop Securities Crews & Associates is