Reso 1641 06/2023RESOLUTION NO. 1641
RESOLUTION OF THE BOARD OF DIRECTORS OF THE
VALLECITOS WATER DISTRICT APPROVING THE STATEMENT
OF INVESTMENT POLICY FOR CALENDAR YEAR 2023 AND REPEALING
RESOLUTION 1628
WHEREAS, the Board of Directors shall annually approve a Statement of
Investment Policy; and
WHEREAS, the annual Statement of Investment Policy of the Vallecitos Water
District is as follows:
Contents
Section
Paqe
1
General Provisions and Objectives
1
2
Delegation of Authority
3
3
Ethics and Conflict of interest
4
4
Internal Controls
4
5
Authorized Financial Institutions, Depositories and Broker/Dealers
4
6
Authorized Investments
5
7
Prohibited Investment Vehicles and Transactions
10
8
Investment Pools/Mutual Funds
11
9
Collateralization
11
10
Delivery, Safekeeping, and Custody
12
11
Maximum Maturity
12
12
Risk Management and Diversification
12
13
Review and Reporting
14
14
Glossary of Terms
15
Section 1: General Provisions and Objectives
Section 1.1: Introduction
The purpose of this investment policy is to identify various policies and procedures that
will foster a prudent and systematic investment program designed to meet the Vallecitos
Water District's objectives of safety, liquidity and return on investment through a
diversified investment portfolio. This policy also serves to organize and formalize the
District's investment -related activities, while complying with all applicable statutes
governing the investment of public funds. This policy is written to incorporate industry
best practices and recommendations from sources such as the Government Finance
Officers Association (GFOA), California Municipal Treasurers Association (CMTA),
California Debt and Investment Advisory Commission (CDIAC) and the Association of
Public Treasurers (APT).
Resolution No. 1641 Page 2
Section 1.2: Scope
This policy covers all funds and investment activities under the direct authority of the
District, as set forth in California Government Code, Sections 53600 et seq., with the
following exceptions:
• Proceeds of debt issuance shall be invested in accordance with the District's general
investment philosophy as set forth in this policy; however, such proceeds are to be
invested pursuant to the permitted investment provisions of their specific bond
indentures.
• Any other funds specifically exempted by the Board of Directors.
Section 1.3: Pooling of Funds
Except for cash in certain restricted funds, the District will consolidate cash and reserve
balances from all funds to maximize investment earnings and to increase efficiencies with
regard to investment pricing, safekeeping and administration. Investment income will be
allocated to the various funds based on their respective participation and in accordance
with generally accepted accounting principles.
Section 1.4: Prudence
Pursuant to California Government Code, Section 53600.3, all persons authorized to
make investment decisions on behalf of the District are trustees and therefore fiduciaries
subject to the Prudent Investor Standard:
"... all governing bodies of local agencies or persons authorized to make
investment decisions on behalf of those local agencies investing public funds
pursuant to this chapter are trustees and therefore fiduciaries subject to the
prudent investor standard. 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."
The Treasurer and other authorized persons responsible for managing District funds
acting in accordance with written procedures and this investment policy and exercising
due diligence shall be relieved of personal responsibility for an individual security's credit
risk or market price changes provided that the Treasurer or other authorized persons
acted in good faith. Deviations from expectations of a security's credit or market risk
should be reported to the Board of Directors in a timely fashion and appropriate action
should be taken to control adverse developments.
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Section 1.5: Objectives
The District's overall investment program shall be designed and managed with a degree
of professionalism worthy of the public trust. The overriding objectives of the program are
to preserve principal, provide sufficient liquidity, and manage investment risks, while
seeking a market -rate of return.
• Safety. Safety of principal is the foremost objective of the investment program.
Investments will be undertaken in a manner that seeks to ensure the preservation of
capital in the overall portfolio. To attain this objective, the District will diversify its
investments by investing funds among a variety of securities with independent returns.
• Liquidity. The investment portfolio will remain sufficiently liquid to meet all operating
requirements that may be reasonably anticipated.
• Return on Investments. The investment portfolio will be designed with the objective of
attaining a market rate of return throughout budgetary and economic cycles, taking
into account the investment risk constraints for safety and liquidity needs.
Section 2: Delegation of Authority
Authority to manage the District's investment program is derived from California
Government Code, Sections 41006 and 53600 et seq.
The Board of Directors is responsible for the management of the District's funds, including
the administration of this investment policy. Management responsibility for the cash
management of the District's funds is hereby delegated to the Treasurer.
The Treasurer will be responsible for all transactions undertaken and will establish a
system of procedures and controls to regulate the activities of subordinate officials and
employees. Such procedures will include explicit delegation of authority to persons
responsible for investment transactions. No person may engage in an investment
transaction except as provided under the terms of this policy and the procedures
established by the Treasurer.
The District may engage the services of one or more external investment advisers, who
are registered under the Investment Advisers Act of 1940, to assist in the management
of the District's investment portfolio in a manner consistent with the District's objectives.
External investment advisers may be granted discretion to purchase and sell investment
securities in accordance with this investment policy.
The District's overall investment program shall be designed and managed with a degree
of professionalism that is worthy of the public trust. The District recognizes that in a
diversified portfolio, occasional measured losses may be inevitable and must be
considered within the context of the overall portfolio's return and the cash flow
requirements of the District.
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Section 3: Ethics and Conflicts of Interest
All participants in the investment process shall act as custodians of the public trust.
Investment officials shall recognize that the investment portfolio is subject to public review
and evaluation. Thus employees and officials 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.
Employees and investment officials shall disclose to the District's General Manager any
material financial interests in financial institutions that conduct business within their
jurisdiction, and they shall further disclose any large personal financial/investment
positions that could be related to the performance of the investment portfolio. Employees
and officers shall refrain from undertaking any personal investment transactions with the
same individual with whom business is conducted on behalf of the District.
Section 4: Internal Controls
The Treasurer is responsible for establishing and maintaining an internal control structure
designed to ensure that the assets of the entity are protected from loss, theft or misuse.
The internal control structure shall be designed to provide reasonable assurance that
these objectives are met. The concept of reasonable assurance recognizes that (1) the
cost of a control should not exceed the benefits likely to be derived; and (2) the valuation
of costs and benefits requires estimates and judgments by management.
Periodically, as deemed appropriate by the District and/or the Board of Directors, an
independent analysis by an external auditor shall be conducted to review internal controls,
account activity and compliance with policies and procedures.
Section 5: Authorized Financial Institutions, Depositories, and Broker/Dealers
To the extent practicable, the Treasurer shall endeavor to complete investment
transactions using a competitive bid process whenever possible. The District's Treasurer
will determine which financial institutions are authorized to provide investment services
to the District. It shall be the District's policy to purchase securities only from authorized
institutions and firms.
The Treasurer shall maintain procedures for establishing a list of authorized
broker/dealers and financial institutions which are approved for investment purposes that
are selected through a process of due diligence as determined by the District. Due inquiry
shall determine whether such authorized broker/dealers, and the individuals covering the
District are reputable and trustworthy, knowledgeable and experienced in Public Agency
investing and able to meet all of their financial obligations. These institutions may include
"primary" dealers or regional dealers that qualify under Securities and Exchange
Commission (SEC) Rule 15c3-1 (uniform net capital rule).
Resolution No. 1641 Page 5
In accordance with Section 53601.5, institutions eligible to transact investment business
with the District include:
• Institutions licensed by the state as a broker-dealer.
• Institutions that are members of a federally regulated securities exchange.
• Primary government dealers as designated by the Federal Reserve Bank and non -
primary government dealers.
• Nationally or state -chartered banks.
• The Federal Reserve Bank.
• Direct issuers of securities eligible for purchase.
Selection of financial institutions and broker/dealers authorized to engage in transactions
will be at the sole discretion of the District, except where the District utilizes an external
investment adviser in which case the District may rely on the adviser for selection.
All financial institutions which desire to become qualified bidders for investment
transactions (and which are not dealing only with the investment adviser) must supply the
Treasurer with audited financials and a statement certifying that the institution has
reviewed the California Government Code, Section 53600 et seq. and the District's
investment policy. The Treasurer will conduct an annual review of the financial condition
and registrations of such qualified bidders.
Public deposits will be made only in qualified public depositories as established by State
law. Deposits will be insured by the Federal Deposit Insurance Corporation, or, to the
extent the amount exceeds the insured maximum, will be collateralized in accordance
with State law.
Selection of broker/dealers used by an external investment adviser retained by the District
will be at the sole discretion of the adviser. Where possible, transactions with
broker/dealers shall be selected on a competitive basis and their bid or offering prices
shall be recorded. If there is no other readily available competitive offering, best efforts
will be made to document quotations for comparable or alternative securities. When
purchasing original issue instrumentality securities, no competitive offerings will be
required as all dealers in the selling group offer those securities at the same original issue
price.
Section 6: Authorized Investments
The District's investments are governed by California Government Code, Sections 53600
et seq. Within the investments permitted by the Code, the District seeks to further restrict
eligible investments to the guidelines listed below. In the event a discrepancy is found
between this policy and the Code, the more restrictive parameters will take precedence.
Percentage holding limits and credit quality minimums listed in this section apply at the
time the security is purchased.
Resolution No. 1641 Page 6
Any investment currently held at the time the policy is adopted which does not meet the
new policy guidelines can be held until maturity, and shall be exempt from the current
policy. At the time of the investment's maturity or liquidation, such funds shall be
reinvested only as provided in the current policy.
An appropriate risk level shall be maintained by primarily purchasing securities that are
of high quality, liquid, and marketable. The portfolio shall be diversified by security type
and institution to avoid incurring unreasonable and avoidable risks regarding specific
security types or individual issuers.
Section 6.1: Municipal Securities include obligations of the District, 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 the "A" category or higher by at least one nationally
recognized statistical rating organization ("NRSRO").
• No more than 5% of the portfolio may be invested in any single issuer.
• No more than 25% of the portfolio may be in Municipal Securities.
• The maximum maturity does not exceed five (5) years.
Section 6.2: U.S. Treasuries and other government obligations for which
the full faith and credit of the United States are pledged for the payment of principal and
interest. There are no limits on the dollar amount or percentage that the District may invest
in U.S. Treasuries, provided that the maximum maturity is five (5) years.
Section 6.3: Federal Agencies 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. There are no limits on the dollar amount or
percentage that the District may invest in Federal Agency or Government -Sponsored
Enterprises (GSEs), provided that:
• No more than 30% of the portfolio may be invested in any single agency/GSE issuer.
• The maximum maturity does not exceed five (5) years.
Section 6.4: Banker's Acceptances, provided that:
• They are issued by institutions which have short-term debt obligations rated "A-1" or
higher by at least one NRSRO; or long-term debt obligations which are rated in the
"A" category or higher by at least one NRSRO.
• No more than 20% of the portfolio may be invested in Banker's Acceptances.
• No more than 5% of the portfolio may be invested in any single issuer.
0 The maximum maturity does not exceed 180 days.
solution No. 1641 Paae 7
Section 6.5: Commercial Paper, provided that:
• The issuer is a corporation organized and operating in the United States with assets
in excess of $500 million.
• The securities are rated "A-1" or the equivalent or higher by at least one NRSRO.
• They are issued by corporations which have long-term obligations, if any, that are
rated in the "A" category or higher by at least one NRSRO.
• The District may also purchase commercial paper issued by entities organized within
the United States as a special purpose corporation, trust, or limited liability company,
provided that the securities have program -wide credit enhancements including, but
not limited to, overcollateralization, letters of credit, or a surety bond.
• District may purchase no more than 10% of the outstanding commercial paper of any
single issuer.
• No more than 25% of the portfolio may be invested in Commercial Paper if the
District's assets total $100 million or less. If the District's investment assets total more
than $100 million, then no more than 40% of the portfolio may be invested in
commercial paper until January 1, 2026 unless this is extended.
• No more than 5% of the portfolio may be invested in any single issuer.
• The maximum maturity does not exceed 270 days.
Section 6.6: Certificates of Deposit (CDs), in or issued by a nationally or
state -chartered bank, a savings association or a federal association, a state or federal
credit union, or by a federally licensed or state -licensed branch of a foreign bank, provided
that:
• The amount of the CD insured up to the Federal Deposit Insurance Corporation (FDIC)
or National Credit Union Administration (NCUA) limit does not require any credit
ratings.
• For Negotiable CDs, any amount above the FDIC or NCUA insured limit must be
issued by institutions which have short-term debt obligations rated "A-1" or higher by
at least one NRSRO; or long-term obligations rated in the "A" category or higher by at
least one NRSRO.
• For Non-negotiable CDs (Time Deposits), amounts deposited in excess of insured
amounts are fully collateralized with securities in accordance with California law.
• No more than 20% of the total portfolio may be invested in CDs.
• No more than 5% of the portfolio may be invested in any single issuer or institution.
• The maximum maturity does not exceed five (5) years.
solution No. 1641 Paae 8
Section 6.7: Collateralized Bank Deposits. District's deposits with financial
institutions will be collateralized with pledged securities per California Government Code,
Section 53651.
Section 6.8: Repurchase Agreements collateralized with securities
authorized under California Government Code, maintained at a level of at least 102% of
the market value of the Repurchase Agreement, provided that:
• Securities used as collateral for Repurchase Agreements will be delivered to an
acceptable third party custodian.
• Repurchase Agreements are subject to a Master Repurchase Agreement between the
District and the provider of the repurchase agreement. The Master Repurchase
Agreement will be substantially in the form developed by the Securities Industry and
Financial Markets Association (SIFMA).
• No more than 25% of the portfolio can be invested in Repurchase Agreement.
• No more than 10% of the portfolio may be invested in any single participating
institution.
• The maximum maturity does not exceed one (1) year.
Section 6.9: Local Government Investment Pools (LGIPs), including State
of California Local District Investment Fund (LAIF) and the California Asset Management
Program (CAMP), provided that:
• The District may invest up to the maximum amount permitted by the LGIP.
• The LGIP's investments in instruments prohibited by or not specified in the District's
policy do not exclude the investment in the LGIP itself from the District's list of
allowable investments, provided the LGIP's reports allow the Treasurer to adequately
judge the risk inherent in the LGIP's portfolio.
Section 6.10: Corporate Medium Term Notes (MTNs), provided that:
• The issuer is a corporation organized and operating within the United States or by
depository institutions licensed by the United States or any state and operating within
the United States.
• The securities are rated in the "A" category or higher by at least one NRSRO.
• No more than 25% of the total portfolio may be invested in MTNs.
• No more than 5% of the portfolio may be invested in any single issuer.
• The maximum maturity does not exceed five (5) years.
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Section 6.11: Asset -Backed Securities, including Mortgage -Backed,
Mortgage Pass -Through, and Collateralized Mortgage Obligations, provided that:
• The securities are rated in the "AK category or higher by a NRSRO.
• No more than 20% of the total portfolio may be invested in these securities.
• No more than 5% of the portfolio may be invested in any single Asset -Backed or
Commercial Mortgage security issuer. There is no issuer limitation on any Mortgage
security where the issuer is the US Treasury or a Federal District/GSE.
• The maximum legal final maturity does not exceed five (5) years.
Section 6.12: Money Market Mutual Funds that are registered with the
Securities and Exchange Commission under the Investment Company Act of 1940,
provided that:
• Such Funds meet either of the following criteria:
1. Have attained the highest ranking or the highest letter and numerical rating
provided by not less than two (2) NRSROs; or
2. Have retained an investment adviser registered or exempt from registration with
the Securities and Exchange Commission with not less than five years'
experience investing in the securities and obligations authorized by California
Government Code, Section 53601 and with assets under management in excess
of $500 million.
• No more than 20% of the total portfolio may be invested in Money Market Mutual
Funds.
Section 6.13: Supranationals, provided that:
• Issues are US dollar denominated senior unsecured unsubordinated obligations
issued or unconditionally guaranteed by the International Bank for Reconstruction and
Development, International Finance Corporation, or Inter -American Development
Bank.
• The securities are rated in the "AX category or higher by a NRSRO.
• No more than 25% of the total portfolio may be invested in these securities.
• No more than 5% of the portfolio may be invested in any single issuer.
• The maximum maturity does not exceed five (5) years.
Resolution No. 1641 Page 10
Section 6.14: Permissible Investments and Limits Summary Table,
notwithstanding further detailed provisions, limitations, and restrictions of this Policy:
Investment Type
% of Investment Portfolio
Maturity
Minimum
Credit
Rating
Type
Issuer/
Institution
Bank Deposits
100%
100%
LGIPs (including LAIF
and CAMP)
100%
100%
US Treasuries
100%
100%
5 years
Federal A encies/GSEs
100%
30%
5 years
Repurchase Agreements
25%
10%
1 year
Municipals
25%
5%
5 years
A
Corporate MTNs
25%
5%
5 years
A
Su ranationals
25%
5%
5 years
AA
Commercial Paper
25%*
5%
270 days
A-1 /A, if
an
MM Mutual Funds
20%
20%
AAA
Certificates of Deposit
20%
5%
5 years
Asset -Backed Securities
20%
5%
5 years
AA
Banker's Acceptances
20%
5%
180 days
A-1 /A_
*40% if AUM >$100 million
Section 7: Prohibited Investment Vehicles and Practices
• State law notwithstanding, any investments not specifically described herein are
prohibited, including, but not limited to futures and options.
• In accordance with Government Code, Section 53601.6, investment in inverse
floaters, range notes, or mortgage derived interest -only strips is prohibited.
• Investment in any security that could result in a zero interest accrual if held to maturity
is prohibited.
• Trading securities for the sole purpose of speculating on the future direction of interest
rates is prohibited.
• Purchasing or selling securities on margin is prohibited.
• The use of reverse repurchase agreements, securities lending or any other form of
borrowing or leverage is prohibited.
• The purchase of foreign currency denominated securities is prohibited. �,
Resolution No. 1641 Page 11
Section 8: Investment Pools/Mutual Funds
The District shall conduct a thorough investigation of any pool or mutual fund prior to
making an investment, and on a continual basis thereafter. The Treasurer shall develop
a questionnaire which will answer the following general questions:
• A description of eligible investment securities, and a written statement of investment
policy and objectives.
• A description of interest calculations and how it is distributed, and how gains and
losses are treated.
• A description of how the securities are safeguarded (including the settlement
processes), and how often the securities are priced and the program audited.
• A description of who may invest in the program, how often, what size deposit and
withdrawal are allowed.
• A schedule for receiving statements and portfolio listings.
• Are reserves, retained earnings, etc. utilized by the pool/fund?
• A fee schedule, and when and how is it assessed.
• Is the pool/fund eligible for bond proceeds and/or will it accept such proceeds?
Section 9: Collateralization
Certificates of Deposit (CDs). The District shall require any commercial bank or savings
and loan association to deposit eligible securities with an agency of a depository approved
by the State Banking Department to secure any uninsured portion of a Non -Negotiable
Certificate of Deposit. The value of eligible securities as defined pursuant to California
Government Code, Section 53651, pledged against a Certificate of Deposit shall be equal
to 150% of the face value of the CD if the securities are classified as mortgages and 110%
of the face value of the CD for all other classes of security.
Collateralization of Bank Deposits. This is the process by which a bank or financial
institution pledges securities, or other deposits for the purpose of securing repayment of
deposited funds. The District shall require any bank or financial institution to comply with
the collateralization criteria defined in California Government Code, Section 53651.
Repurchase Agreements. The District requires that Repurchase Agreements be
collateralized only by securities authorized in accordance with California Government
Code:
• The securities which collateralize the repurchase agreement shall be priced at Market
Value, including any Accrued Interest plus a margin. The Market Value of the
securities that underlie a repurchase agreement shall be valued at 102% or greater of
the funds borrowed against those securities.
Resolution No. 1641 Page 12
• Financial institutions shall mark the value of the collateral to market at least monthly
and increase or decrease the collateral to satisfy the ratio requirement described
above.
• The District shall receive monthly statements of collateral.
Section 10: Delivery, Safekeeping and Custody
Delivery -versus -Payment (DVP). All investment transactions shall be conducted on a
delivery -versus -payment basis.
Safekeeping and Custody. To protect against potential losses due to failure of individual
securities dealers, and to enhance access to securities, interest payments and maturity
proceeds, all cash and securities in the District's portfolio shall be held in safekeeping in
the District's name by a third party custodian, acting as agent for the District under the
terms of a custody agreement executed by the bank and the District. All investment
transactions will require a safekeeping receipt or acknowledgment generated from the
trade. A monthly report will be received by the District from the custodian listing all
securities held in safekeeping with current market data and other information.
The only exceptions to the foregoing shall be depository accounts and securities
purchases made with: (i) local government investment pools; (ii) time certificates of
deposit, and, (iii) money market mutual funds, since the purchased securities are not
deliverable.
Section 11: Maximum Maturity
To the extent possible, investments shall be matched with anticipated cash flow
requirements and known future liabilities.
The District will not invest in securities maturing more than five (5) years from the date of
trade settlement, unless the Board of Directors has by resolution granted authority to
make such an investment.
Section 12: Risk Management and Diversification
Section 12.1: Mitigating Credit Risk in the Portfolio
Credit risk is the risk that a security or a portfolio will lose some or all of its value due to a
real or perceived change in the ability of the issuer to repay its debt. Concentration of
credit risk is the risk of loss attributed to the magnitude of a District's investment in a
single issuer. Custodial credit risk is the risk that the District will not be able to recover
deposits or the value of an investment or collateral securities that are in the possession
of an outside party. The District will mitigate credit risk by adopting the following
strategies:
• The diversification requirements included in Section 6: Authorized Investments of this
policy are designed to mitigate credit risk in the portfolio.
Resolution No. 1641 Page 13
No more than 5% of the total portfolio may be invested in securities of any single
issuer, except where the issuer is the US Government, its Agencies and GSEs, an
authorized Supranational issuer or where the security is a Money Market Mutual Fund,
Local District Investment Fund (LAIF) or other Local Government Investment Pool
unless otherwise specified in this investment policy.
The District may elect to sell a security prior to its maturity and record a capital gain
or loss in order to manage the quality, liquidity or yield of the portfolio in response to
market conditions or District's risk preferences.
If securities owned by the District are downgraded by an NRSRO to a level below the
quality required by this investment policy, making the security ineligible for additional
purchases, the following steps will be taken:
Any actions taken by the investment manager related to the downgrade will be
communicated to the Treasurer in a timely manner.
If a decision is made to retain a downgraded security in the portfolio, the credit
situation will be monitored and reported to the Board of Directors.
Section 12.2: Mitigating Market Risk in the Portfolio
Market risk is the risk that the portfolio value will fluctuate due to changes in the general
level of interest rates. The District recognizes that, over time, longer-term portfolios have
the potential to achieve higher returns. On the other hand, longer-term portfolios have
higher volatility of return. The District will mitigate market risk by providing adequate
liquidity for short-term cash needs, and by making longer-term investments only with
funds that are not needed for current cash flow purposes.
The District further recognizes that certain types of securities, including variable rate
securities, securities with principal paydowns prior to maturity, and securities with
embedded options, will affect the market risk profile of the portfolio differently in different
interest rate environments. The District, therefore, adopts the following strategies to
control and mitigate its exposure to market risk:
• The District will maintain a minimum of six months of budgeted operating expenditures
in short term investments to provide sufficient liquidity for expected disbursements.
• The maximum percent of callable securities in the portfolio will be 30%. (Does not
include "make whole call" securities as defined in the glossary).
• The maximum stated final maturity of individual securities in the portfolio will be five
(5) years, except as otherwise stated in this policy.
• The duration of the portfolio will generally be approximately equal to the duration
(typically, plus or minus 20%) of a Market Benchmark, an index selected by the District
based on the District's investment objectives, constraints and risk tolerances.
Section 12.3: Foreign Currency Risk
Foreign currency risk is the risk that changes in exchange rates will adversely affect the
fair value of the portfolio. The District shall be prohibited from investing in foreign
Resolution No. 1641 Paae 14
currency -denominated securities, unless permissible within the California Government
Code and specifically approved by the Board prior to purchase.
Section 13: Review and Reporting
Section 13.1: Review of Investment Portfolio
The Treasurer shall periodically, but no less than quarterly, review the portfolio to identify
investments that do not comply with this investment policy and establish protocols for
reporting incidences of noncompliance to the Board of Directors.
Section 13.2: Performance Evaluation
The investment portfolio shall be designed to attain a market -average rate of return
throughout budgetary and economic cycles, taking into account the District's risk
constraints, the cash flow characteristics of the portfolio, and state and local laws,
ordinances or resolutions that restrict investments.
The Treasurer shall monitor and evaluate the portfolio's performance relative to the
chosen market benchmark(s), which will be included in the Treasurer's quarterly report.
The Treasurer shall select an appropriate, readily available index to use as a market
benchmark.
Section 13.3: Monthly Reports
Monthly transaction reports will be submitted by the Treasurer to the Board of Directors
within 30 days of the end of the reporting period in accordance with California Government
Code Section 53607.
Section 13.4: Quarterly Reports
The Treasurer will submit a quarterly investment report to the Board of Directors which
provides full disclosure of the District's investment activities within 30 days after the end
of the quarter. These reports will disclose, at a minimum, the following information about
the District's portfolio:
• An asset listing showing par value, cost and independent third -party fair market value
of each security as of the date of the report, the source of the valuation, type of
investment, issuer, maturity date, and interest rate.
• Transactions for the period.
• A description of the funds, investments and programs (including lending programs)
managed by contracted parties (i.e. LAIF; investment pools, outside money managers
and securities lending agents)
• A one-page summary report that shows:
• Average maturity of the portfolio and modified duration of the portfolio;
• Maturity distribution of the portfolio;
0 Percentage of the portfolio represented by each investment category;
Resolution No. 1641 Page 15
• Average portfolio credit quality; and,
Time -weighted total rate of return for the portfolio for the prior one month, three
months, twelve months and since inception compared to the District's market
benchmark returns for the same periods;
• A statement of compliance with investment policy, including a schedule of any
transactions or holdings which do not comply with this policy or with the California
Government Code, including a justification for their presence in the portfolio and a
timetable for resolution.
• A statement that the District has adequate funds to meet its cash flow requirements
for the next six months.
Section 13.5: Annual Reports
A comprehensive annual report will be presented to the Board of Directors. This report
will include comparisons of the District's return to the market benchmark return, suggest
policies and improvements that might enhance the investment program, and will include
an investment plan for the coming year.
Section 13.6: Review of Investment Policy
The investment policy will be reviewed and adopted at least annually within 30 days of
the end of the calendar year, to ensure its consistency with the overall objectives of
preservation of principal, liquidity and return, and its relevance to current law and financial
and economic trends.
Any recommended modifications or amendments shall be presented by Staff to the Board
of Directors for their consideration and adoption.
Section 14: Glossary of Terms
Asset-backed securities (ABS) are securities whose income payments and hence value
is derived from and collateralized (or "backed") by a specified pool of underlying assets
which are receivables. Pooling the assets into financial instruments allows them to be
sold to general investors, a process called securitization, and allows the risk of investing
in the underlying assets to be diversified because each security will represent a fraction
of the total value of the diverse pool of underlying assets. The pools of underlying assets
can comprise common payments credit cards, auto loans, mortgage loans, and other
types of assets. Interest and principal is paid to investors from borrowers who are paying
down their debt.
Bankers' Acceptances 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.
Resolution No. 1641 Page 16
Broker -Dealer is a person or a firm who can act as a broker or a dealer depending 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.
California Asset Management Program (CAMP) is a California Joint Powers Authority,
which was established in 1989 to provide California public agencies with professional
investment services. Investments offered through the Cash Reserve Portfolio (the "CAMP
Pool") are permitted for all local agencies under California Government Code Section
53601(p). There are no investment or transaction minimums or maximums associated
with the CAMP Pool, which offers daily liquidity.
Certificates of Deposit
Negotiable Certificates of Deposit are large -denomination CDs issued in $1 million
increments. These securities have average trades in the secondary market of $5
million to $10 million. 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 is 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.
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 Fannie Mae (FNMA), Freddie Mac (FHLMC), the Federal Home Loan Bank
Resolution No. 1641 Paae 17
system (FHLB), and Federal Farm Credit Bank (FFCB). The Agency market is a very
large and liquid market, with billions traded every day. 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 per cent
of the earnings.
Local Government Investment Pool (LGIP) is a collection of funds from various
governmental entities invested in a common portfolio. Each investor earns interest
proportional to their investment in the overall pool.
Make Whole Call is a type of call provision on a bond that allows the issuer to pay off the
remaining debt early. Unlike a call option, with a make whole call provision the issuer
makes a lump sum payment that equals the net present value of future coupon payments
that will not be paid because of the call. With this type of call, an investor is compensated
or "made whole".
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.
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 term "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.
Resolution No. 1641 Page 18
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 maintain a stable net asset value (NAV) of $1 per share.
Municipal Obligations are debt instruments issued by a state or local government unit or
public agency. The vast majority of municipals are exempt from state and federal income
tax, although some non-qualified issues are taxable.
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 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 Repo. Repurchase Agreements must
be collateralized.
Supranationals are United States dollar denominated senior unsecured unsubordinated
obligations issued or unconditionally guaranteed by the International Bank for
Reconstruction and Development (IBRD), International Finance Corporation (IFC), or
Inter -American Development Bank (IADB), with maximum remaining maturity of five years
or less, and eligible for purchase and sale within the United States.
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:
Treasury Bills that 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.
Treasury Notes that have original maturities of one to ten years.
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. 0
Resolution No. 1641 Page 19
NOW, THEREFORE, BE IT RESOLVED by the Board of Directors of the Vallecitos
Water District as follows:
The Annual Statement of Investment Policy for calendar year 2023 is hereby
approved and replaces and previous versions. The District Treasurer is directed to follow
this Statement of Investment Policy in investing funds of the District.
PASSED AND ADOPTED by the Board of Directors of the Vallecitos Water District
at a regular meeting held on this 7th day of June 2023, by the following roll call vote:
AYES: BOYD-HODGSON, ELITHARP, GROSET, HERNANDEZ, PENNOCK
NOES:
ABSTAIN:
ABSENT:
Jim Her ez, President
Board of Directors
Vallecitos Water District
ATTEST:
Glenn Pruim, Secretary
Board of Directors
Vallecitos Water District