ORD 1288 09/24/2019 ORDINANCE
AN ORDINANCE BY THE CITY COUNCIL OF THE CITY OF CIBOLO, TEXAS
APPROVING AN INVESTMENT POLICY OF THE CITY OF CIBOLO;
APPOINTING THE CITY'S INVESTMENT OFFICERS; PROVIDING THAT
THIS ORDINACE SHALL BE CUMULATIVE OF ALL OTHER ORDINANCES;
PROVIDING FOR A SEVERABILITY CLAUSE; AND PROVIDING FOR AN
EFFECTIVE DATE.
WHEREAS, Chapter 2256 of the Texas Government Code, commonly known as the "Public
Funds Investment Act" requires the City to adopt a written investment policy by rule, order,
ordinance or resolution annually; and
WHEREAS, the Public Funds Investment Act requires changes made to the Policy be recorded;
and
WHEREAS, the Public Funds Investment Act requires the City to designate by rule, order,
ordinance, or resolution, one or more officers or employees as investment officers responsible
for the investment of funds consistent with adopted written investment policy; and
WHEREAS, the City of Cibolo Investment Policy also includes the Cibolo Economic
Development Corporation to allow for the prudent investment of the CEDC's funds, as
authorized by the Cibolo City Council and the Cibolo Economic Development Corporation Board
of Directors; and
WHEREAS, the attached Investment Policy and incorporated revisions comply with the Public
Funds Investment Act, and authorize the investment of funds in safe and prudent investments.
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF CIBOLO,
TEXAS:
SECTION 1
The Investment Policy herein attached as Exhibit "A" to this Ordinance is compliant with the
requirements of the Public Funds Investment Act. The Investment Policy notes the following
changes from the prior year:
• None
SECTION 2
The City Manager and the Finance Director are hereby named as investment officers of the City
to be responsible for the investment of its funds consistent with the Investment Policy.
SECTION 3
CUMULATIVE CLAUSE
That this Ordinance shall be cumulative of all other ordinances of the City of Cibolo, Texas,
except where the provisions of this Ordinance are in direct conflict with the provisions of such
other ordinances, in which event the conflicting provisions of such ordinances are hereby
repealed.
SECTION 4
SEVERABILITY
That it is hereby declared to be the intention of the City Council of the City of Cibolo that the
phrases, clauses, sentences, paragraphs, and sections of this Ordinance are severable, and if
any phrase, clause, sentence, paragraph or section of this Ordinance should be declared
unconstitutional by the valid judgment or decree of any court of competent jurisdiction, such
unconstitutionality shall not affect any of the remaining phrases, clauses, sentences,
paragraphs or sections of the Ordinances, since the same would have been enacted by the City
Council without incorporation in this ordinance of any such unconstitutional phrases, clause,
sentence, paragraph or section.
SECTION 5
EFFECTIVE DATE
This Ordinance shall take effect immediately.
PASSED, APPROVED AND ADOPTED THIS 24TH DAY OF SEPTEMBER 2019.
Stosh BoyK', Mayor
ATTEST:
Peggy Cimics, City Secretary
Page 2 of 2
Exhibit A
CITY OF CIBOLO AND ECONOMIC DEVELOPMENT CORPORATION
INVESTMENT POLICY
I. INTRODUCTION
The purpose of this document is to set forth specific investment policy and strategy
guidelines for the City of Cibolo (the "City") and the Cibolo Economic Development
Corporation (the "EDC") in order to achieve the City's investment goals. In accordance
with state statute, the City Council and Board of Directors of the EDC ("the Board") shall
review its investment strategies and policy not less than annually. This Policy satisfies the
statutory requirement of Texas Government Code Chapter 2256, the Public Funds
Investment Act (the "Act").
Throughout this Investment Policy, the City and EDC shall be collectively referred to as
(the "Entity").
II. SCOPE
This Investment Policy applies to all financial assets of the Entity. The funds are
accounted for in the Entity's Comprehensive Annual Financial Report (CAFR) and include
(but are not limited to):
• General Fund
• Special Revenue Funds
• Debt Service Funds
• Capital Projects Funds
• Enterprise Funds
• Economic Development Funds
III. OBJECTIVES
The Entity shall manage and invest available funds with six major objectives:
• Understanding of the suitability of the investment to the financial requirements of
the entity;
• Preservation and safety of principal;
• Liquidity,
• Marketability of the investment if the need arises to liquidate the investment before
maturity;
• Diversification of the investment portfolio; and
• Yield.
Safety of principal is the primary objective. All investments shall be managed in a manner
responsive to the public trust and consistent with state and local law.
Suitability
The Entity investment portfolio will include only investments that are appropriate in terms
of investor knowledge, level of risk, and allocation of assets.
Safety
The primary objective of the Entity's investment activity is the preservation of capital in the
overall portfolio. Each investment transaction shall be conducted in a manner to avoid
capital losses, whether they are from securities defaults or erosion of market value.
Liquidity
The investment portfolio shall be structured to meet all cash flow obligations in a timely
manner. This shall be achieved by matching investment maturities with forecasted cash
flow requirements, and maintain additional liquidity for unexpected liabilities
Diversification
The Entity's portfolio shall be diversified by market sector and maturity in order to reduce
the risk of loss resulting from over concentration of assets in a specific maturity, a specific
issuer, or a specific class of investments.
Marketability
The Entity investment portfolio will include only investments that are marketable should
the need arise to liquidate the investment prior to maturity to meet the Entity's financial
obligations.
Yield
The benchmark for the Entity's portfolio shall be the six-month treasury and the one-year
treasury, designated for their comparability to the weighted average maturity indicated in
investment strategies outlined in Section IV. The benchmark will serve as a risk
measurement on the portfolio. The investment program may seek to augment returns
above this threshold consistent with risk limitations identified herein and prudent
investment policies. Weighted average yield to maturity shall be the portfolio performance
measurement standard.
IV. INVESTMENT STRATEGIES
The Entity shall maintain a proactive cash management program which includes timely
collection of accounts receivable, vendor payments in accordance with invoice terms, and
prudent investment of assets. Cash management is the process of managing monies in
order to ensure maximum cash availability and reasonable yield on short-term
investments.
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The Entity maintains one commingled portfolio for investment purposes which
incorporates the specific investment strategy considerations and the unique
characteristics of the fund groups represented in the portfolio:
A. The investment strategy for operating, enterprise, and special revenue funds
has as its primary objective assurance that anticipated liabilities are matched
and adequate investment liquidity provided. The secondary objective is to
create a portfolio structure that will experience minimal volatility during
economic cycles. This may be accomplished by purchasing high quality,
short to medium-term investments that will complement each other in a
laddered maturity structure permitting some extension for yield
enhancement. The maximum dollar weighted average maturity of 270 days
or less will be calculated using the stated final maturity date of each
investment. The maximum maturity of an individual investment shall not
exceed two years.
B. The investment strategy for debt service funds shall have as its primary
objective the assurance of available funds adequate to fund each debt
service obligation on the required payment date. Investments purchased
shall not have a stated final maturity date which exceeds the next unfunded
debt service payment date.
C. The investment strategy for debt service reserve funds shall have as its
primary objective the ability to generate a dependable revenue stream to the
appropriate debt service fund from high quality investments with a low
degree of volatility. Securities should be high credit quality and, except as
may be required by the bond ordinance specific to an individual issue, of
short to intermediate-term maturities that do not exceed the final debt
service payment date or five years, whichever is shorter.
D. The investment strategy for capital projects or capital projects funds will
have as its primary objective assurance that anticipated cash flows are
matched and provide adequate investment liquidity. These portfolios should
include at least 10% total liquidity to provide for flexibility and unanticipated
project outlays. The stated final maturity dates of investments held shall not
exceed the estimated project completion date.
E. The investment strategy for EDC will consider that these fund balances are
designated for economic development projects and will be scheduled by the
EDC. In addition to considerations addressed in the balance of this
Investment Policy, the maximum weighted average maturity of EDC Funds
shall not exceed one year. The maximum maturity of an individual
investment shall not exceed two years. To ensure adequate liquidity for
unanticipated cash needs, a portion of the fund balances shall be invested in
financial institution deposits, constant dollar investment pools, or money
market mutual funds. Any term-specific investments shall be matched with
anticipated cash requirements.
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The Entity shall pursue a proactive investment portfolio management strategy. Securities
may be sold before they mature if market conditions present an opportunity for the Entity
to benefit from the trade but the strategy will be primarily buy-and-hold. The Investment
Officer will continuously monitor the contents of the portfolio, the available markets, and
the relative value of competing instruments to adjust the portfolio in response to market
conditions.
V. RESPONSIBILITY AND CONTROL
Delegation of Authority and Training
Authority to manage the Entity's investment program is derived from adoption of this
Investment Policy. The City Manager and the Finance Director are designated as
Investment Officers of the Entity. The Investment Officers are authorized to give written
and oral instructions to place orders for the purchase of investments. No other person
may deposit, withdraw, invest, transfer or otherwise manage Entity funds eligible for
investment. The Finance Director is responsible for day-to-day investment decisions and
activities. The Finance Director shall establish procedures for the operation of the
investment program, consistent with this Investment Policy.
Any security requiring a credit rating by the Act and this Policy will not be authorized
during the time that the security does not hold that rating. The Investment Officer will
obtain credit rating information from a reliable source on at least a quarterly basis. Should
the rating fall below accepted levels, the Investment Officers will decide on the prudent
action with respect to the security.
The Officer will monitor on no less than a monthly basis, the FDIC or collateralized status
of any bank that issued a CD owned by the Entity. If a merger or acquisition of the bank
has placed the Entity in a position which is not insured by FDIC within the holding
company of the bank, the Investment Officer will liquidate the CD immediately, regardless
of principal loss, to assure all funds are insured by FDIC.
In order to ensure qualified and capable investment management, each Investment
Officer shall attend at least one training session, from an approved independent training
source and containing at least 10 hours of instruction relating to the Officer's responsibility
under the PFIA within 12 months after assuming duties. Thereafter, each Investment
Officer shall additionally attend at least one training session, from an approved
independent training source, and containing at least 8 hours of instruction relating to the
Officer's responsibility under the PFIA not less than once in a two-year period. 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.
The approved independent sources of training are: Government Finance Officers
Association, Government Finance Officers Association of Texas, Government Treasurers
Organization of Texas, Alamo Area Council of Governments, Texas City Managers'
Association, International City Manager's Association, University of North Texas, and the
Texas Municipal League.
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Investment Advisor
The governing body of the Entity may contract with an investment management firm,
registered under the Investment Advisor's Act of 1940 (15 U.S.C. Section 80b-1 et seq.),
to provide for the investment and management of the funds of the Entity. The original
contract will be for a term no longer than two (2) years. Renewal or extension of the
contract must be by resolution of the governing body of the Entity.
Internal Controls
The Finance Director is responsible for establishing and maintaining an internal control
structure designed to reasonably assure that assets are protected from loss, theft or
misuse. 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 ongoing estimates and judgments by management.
The internal controls shall address the following points:
• Control of collusion.
• Separation of transaction authority from accounting and record keeping.
• Custodial safekeeping.
• Avoidance of physical delivery securities.
• Clear delegation of authority to subordinate staff members.
• Written confirmation for all transactions.
In conjunction with the annual audit, the external auditor shall provide an annual
independent review to assure compliance with state law, policies and procedures.
VI. PRUDENCE
The standard of prudence to be applied to all Entity investments shall be the "prudent
person" rule, which states:
"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 their capital as well as the probable
income to be derived."
In determining whether an Investment Officer has exercised prudence with respect to an
investment decision, the determination shall be made taking into consideration the
investment of all funds under the Entity's control, over which the Officer has responsibility
rather than a consideration as to the prudence of a single investment and whether the
investment decision was consistent with the written Investment Policy.
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The Investment Officer, acting in accordance with written procedures and exercising due
diligence, shall not be held personally liable for a specific security's credit risk or market
price changes, provided that these deviations are reported immediately to the City
Manager, the City Council and/or Board and that appropriate action is taken to control
adverse developments.
VII. ETHICS AND CONFLICTS OF INTEREST
Investment Officers shall refrain from personal or business activity that could conflict with
proper execution of the investment program, or which could impair the ability to make
impartial investment decisions. City staff shall disclose to the City Manager any conflict
with or personal and business financial interests in financial institutions that conduct
investment business with the Entity. They shall further disclose positions that could be
related to the performance of the Entity's portfolio. Investment Officers shall subordinate
their personal financial transactions to those of the Entity, particularly with regard to timing
of purchases and sales.
An Investment Officer who has a personal business relationship with an organization
seeking to sell an investment to the Entity shall file a statement disclosing that personal
business interest. An Investment Officer who is related within the second degree by
affinity or consanguinity to an individual seeking to sell an investment to the Entity shall
file a statement disclosing that relationship. A statement required under this subsection
must be filed with the Texas Ethics Commission and the governing bodies of the Entity.
VIII. AUTHORIZED INVESTMENTS
Assets of the Entity may be invested only in the following instruments as further defined
by the Act. If changes are made by the Act they are not authorized until this Policy is
modified and adopted by the City Council. All securities transactions will be made on a
delivery-versus-payment basis and all owned securities will be safekept by the Entity's
safekeeping agent or approved depository and those held as collateral will be held by the
Entity's Custodian.
A. Obligations, including letters of credit, of the United States or its agencies
and instrumentalities.
B. Direct obligations of this state or its agencies and instrumentalities.
C. Collateralized mortgage obligations directly issued by a federal agency or
instrumentality of the United States, the underlying security for which is
guaranteed by an agency or instrumentality of the United States.
D. Other obligations, the principal and interest of which are unconditionally
guaranteed or insured by, or backed by the full faith and credit of, this state
or the United States or their respective agencies and instrumentalities,
including obligations that are fully guaranteed or insured by the FDIC or by
the explicit full faith and credit of the United States.
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E. Obligations of any state or political subdivisions of a state rated A or better
by a nationally recognized credit rating agency, not to exceed two years to
maturity.
F. Interest-bearing banking deposits that are guaranteed or insured by the
Federal Deposit Insurance Corporation or its successor; or the National
Credit Union Share Insurance Fund or its successor.
G. Certificates of deposit issued by a depository institution that has its main
office or branch office in Texas which meets the requirements of the PFIA
and is guaranteed or insured by the FDIC, or its successor or the National
Credit Union Share Insurance Fund or its successor or collateralized as
defined by this Policy. The maximum maturity shall not exceed two years to
the stated final maturity.
H. Brokered Certificates of Deposit issued by one or more federally insured
depository institutions, wherever located, provided that the funds are
invested through a broker or depository institution that has its main office or
branch office in Texas, is selected from a list of authorized brokers, and
deposited for the account of the Entity. The full amount of the principal and
accrued interest of each certificate of deposit is insured by the United States
or an instrumentality of the United States. The maximum maturity shall not
exceed two years to the stated final maturity.
I. AAA-rated, constant dollar Local Government Investment Pools as defined
by the Act and authorized by the City Council and Board of Directors.
J. SEC registered, money market mutual funds that comply with the
requirements of State law.
The Entity's authorized investment options are more restrictive than those allowed by
State law. State law specially prohibits investment in the following investment securities:
A. Obligations whose payment represents the coupon payments on the
outstanding principal balance of the underlying mortgage-backed security
collateral and pays 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 10 years.
D. Collateralized mortgage obligations the interest rate of which is determined
by an index that adjusts opposite to the changes in a market index.
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Delivery versus Payment
All securities shall be purchased on a delivery versus payment (DVP) settlement basis.
Funds shall not be released until receipt of the security by the Entity's approved
safekeeping agent. The security shall be held in the name of the Entity or held on behalf
of the Entity. The safekeeping agent's records shall assure the notation of the Entity's
ownership of or explicit claim on the securities and shall provide the Entity proof of
possession with an original safekeeping receipt/report delivered directly to the Entity.
Holding Period
The Entity intends to match the holding periods of investment funds with liquidity needs of
the Entity. The maximum final stated maturity of any investment shall not exceed five
years.
Risk and Diversification
The Entity recognizes that investment risk can result from issuer defaults, market price
changes or various technical complications leading to temporary illiquidity. Risk is
controlled through portfolio diversification. The maximum limits for diversification will be.-
US
e:US Obligations 50%
US Agencies/Instrumentalities 50%
Municipal instruments (see vni. F.) 20%
Certificates of Deposit 50%
Local Government Investment Pools 100%
Money Market Funds 100%
IX. QUARTERLY REPORTING
The Finance Director shall submit a written investment report to Council and the Board on
a quarterly basis at a minimum and in a timely manner. The reports shall detail positions
and all investments. It may include strategies employed in the most recent quarter and
describe maturities, risk characteristics, and investment performance against the Policy
benchmark. The report must:
• Describe in detail the investment position of the City on the date of the report;
• Be prepared jointly by all Investment Officers;
• Be signed by each Investment Officer;
• Contain a summary statement of each pooled fund group that states the:
a. Beginning market value for the reporting period;
b. Ending market value for the period; and
c. Fully accrued interest for the reporting period.
• State the book value and market value of each separately invested asset at the
beginning and end of the reporting period by the type of asset and fund type
invested;
• State the maturity date of each separately invested asset that has a maturity date;
• State the account or fund or pooled group fund in the City for which each individual
investment was acquired;
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• State the compliance of the investment portfolio of the City as it relates to:
a. The investment strategy expressed in the City's Investment Policy; and
b. Relevant provisions of the PFIA; and
• State the rate of return on the investment portfolio.
Market prices for the calculation of market value will be obtained from independent
sources.
Effect of Loss of Authorization or Rating
The Entity is not required to liquidate investments that were authorized investments at the
time of purchase but no longer meet one or more requirements of this Policy. An
investment that requires a minimum credit rating does not qualify as an authorized
investment if, during the period, the investment does not have the minimum required
rating. The Entity shall take all prudent measures that are consistent with this Investment
Policy to liquidate an investment that does not have the minimum rating.
X. SELECTION OF QUALIFYING INSTITUTIONS
Depository
At least every five years, a City Depository shall be selected through a formal request for
application (RFA) process in accordance with Texas Government Code 105.017. In
selecting a primary depository, the services, cost of services, credit worthiness, earnings
potential, and collateralization by the institutions shall be considered. It is the policy of the
Entity to permit selection of a depository outside municipal boundaries.
Broker/Dealers
Broker/dealers who desire to transact business with the Entity must supply the following
documents which will be maintained by Finance.
• Financial Industry Regulatory Authority (FINRA) registration and CRD number.
• Proof of Texas State Securities registration
• Completed broker/dealer questionnaire
• Annual audited financial statement
• Policy review certification
Each counter-party must be provided a copy of the current investment policy and certify to
a review stating understanding of the Policy and that controls are in place to assure only
authorized investments will be sold to the Entity. Any material changes to the Policy will
require that the Investment Officer send out the amended Policy.
A list of qualified broker/dealers will be reviewed at least annually by the City Council or a
Council appointed committee. No broker/dealer may be used if not on the approved list.
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XI. COLLATERAL, SAFEKEEPING AND CUSTODY
Time and Demand Pledged Collateral
All Entity demand and time deposits shall be secured above FDIC coverage by pledged
collateral. In order to anticipate market changes and provide a level of security for all
funds, collateral will be maintained and monitored by the depository at 102% of market
value of principal and accrued interest on the deposits. It is the responsibility of the bank
to monitor collateral margins on a daily basis.
Collateral pledged to secure deposits of the Entity shall be held by a third party financial
institution outside the holding company of the depository in accordance with a custodial
agreement signed by authorized representatives of the Entity, the Depository, and the
Custodian (with the exception of the Federal Reserve as custodian). A custodial receipt
shall be issued to the Entity listing the specific investment, rate, maturity, and other
pertinent information. The custodian shall provide a complete, monthly listing of collateral
directly to the Entity.
All collateral shall be subject to inspection and audit by the Finance Director or the Entity's
independent auditors.
Authorized Collateral
The Entity shall accept only the following securities as collateral for time and demand
deposits or repurchase agreements:
A. Cash.
B. FDIC insurance coverage.
C. A bond, certificate of indebtedness, debenture or letter of credit of the United
States or its agencies and instrumentalities, or other evidence of
indebtedness of the United States that is guaranteed as to principal and
interest by the United States or its agencies and instrumentalities.
D. Obligations, the principal and interest on which, are conditionally guaranteed
or insured by the State of Texas or other US states rated A or better by a
nationally recognized credit rating agency.
E. A bond of a county, city or other political subdivision of the State of Texas or
other states having been rated no less than "A" or its equivalent by a
nationally recognized credit rating agency, with a remaining maturity of ten
(10) years or less.
F. A letter of credit issued to the Entity by the Federal Home Loan Bank.
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XII. INVESTMENT POLICY ADOPTION
The Entity Investment Policy shall be reviewed and adopted by resolution of the City
Council and the EDC Board no less than annually, whether or not any changes are to be
made. The resolution shall include a description of all changes made to the policy.
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APPENDIX A
AUTHORIZED BROKER/DEALER AND COUNTER-PARTY LIST
The authorized broker/dealer list for the Entity is shown below. Each of these firms, and
the individual covering the account, are sent the current Investment Policy. In accordance
with the Public Funds Investment Act [Texas Government Code 2256.005(k)] before any
broker/dealer transacts business with the Entity it will have had to certify in writing to a
review of the Policy and have certified that procedures are in place to assure compliance
with that Policy. An effort is made to diversify brokerage coverage between primary and
regional providers.
The Policy establishes specific criteria for the broker/dealers and requires that the list of
broker/dealers be approved annually by the Council and the EDC Board.
When any material changes are made to the Investment Policy the new Policy is sent out
for re-certification.
National and/or Regional Non-Primary Dealers
FTN Financial
Wells Fargo Securities
Southwest Securities
First Southwest Company
Multi-Bank Securities, Inc. (MBS)
Cantor Fitzgerald & Company
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APPENDIX B
CITY OF CIBOLO and CIBOLO ECONOMIC DEVELOPMENT CORPORATION
BROKER / DEALER QUESTIONNAIRE
Name of Firm:
Address:
Telephone.-
Ownership/affiliation,
elephone:Ownership/affiliation, if appropriate:
Primary Representative on account:
Telephone: Fax:
E-Mail:
Backup representative or trading assistant:
Telephone.-
Branch
elephone:Branch Manager:
Telephone: Fax:
E-Mail.
Is the firm designated as a Primary Dealer by the Federal Reserve?
How long has the firm had Primary Dealer status?
Is the firm registered with the Texas State Securities Board?
Is the firm and representative registered with FINRA? CRD#:
How long has the designated representative been an institutional fixed income broker at
this firm? In total?
In what market sectors does the account representative specialize?
List three comparable public sector clients currently working with this representative.
Entity, name and telephone number.
Please attach complete delivery instructions. (All transactions will be completed delivery
versus payment.)
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CITY OF CIBOLO and CIBOLO ECONOMIC DEVELOPMENT CORPORATION
BROKER / DEALER QUESTIONNAIRE
(This section completed only by Non-Primary Dealers)
Name of Firm: CRD #:
Years in business at this location: In total years:
Indicate the approximate sales volume in the following sectors for the previous year:
US Treasuries Repo
US Agencies MBS
CP Other
BA
Has your firm, or this account representative, been subject to a regulatory agency, state of
federal, investigation for alleged improper, disreputable, unfair, [or] fraudulent activities
related to the sale of securities or money market instruments in the past five years? Are
there any outstanding claims? If yes, please explain.
Have any of your public-sector clients ever reported to your firm, its officers of employees,
orally or in writing, that your firm, was responsible for investment losses? If yes, please
explain.
Please attach a sample of standard research reports and your standard confirmation to be
provided to the Entity.
Please provide the firm's most recent audited financial statements. The Entity will require
an annual financial statement be provided.
What portfolio information do you require from your clients?
Describe the precautions taken by your firm to protect the interests of the public when
dealing with government agencies.
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APPENDIX C
CITY OF CIBOLO and CIBOLO ECONOMIC DEVELOPMENT CORPORATION
TEXAS PUBLIC FUNDS INVESTMENT ACT
CERTIFICATION BY BUSINESS ORGANIZATION
This certification is executed on behalf of the City of Cibolo, The Cibolo Economic
Development Corporation (collectively "the Entity") 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 Entity and the Business
Organization. The undersigned Authorized Representative certifies on behalf of the
Business Organization that:
1. The undersigned is an Authorized Representative of the Business Organization
offering to enter into 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 Representative of the Business Organization, have received and
thoroughly reviewed the Investment Policy of the Entity, and
3. The Business Organization has implemented reasonable procedures and
controls in an effort to preclude investment transaction conducted between the
Business Organization and the Entity that are not authorized by the Entity's
Investment Policy, except to the extent that this authorization is dependent on
an analysis of the makeup of the Entity's entire portfolio or requires an
interpretation of subjective investment standards.
Representative's Signature
Printed Name
Title
Broker's Signature
Printed Name
Title
Date
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