Ord 1377 09/13/2022 Investment Policy y Of c'�
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'City of Choice'
ORDINANCE 1377
AN ORDINANCE BY THE CITY COUNCIL OF THE CITY OF CIBOLO, TEXAS
AMENDING THE INVESTMENT POLICY OF THE CITY OF: :CIBOLO;
APPOINTING THE CITY'S INVESTMENT OFFICERS; PROVIDING. THAT THIS .
ORDINANCE 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 the adopted written investment policy; and
WHEREAS,.the City of Cibolo Investment Policy also includes the Cibolo Economic Development
Corporation (CEDC) 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, Ordinance: 1333 adopted an investment policy.for the City of Cibolo in May 2021; :
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
following requirement of the Public Funds Investment Act. The Investment Policy notes the
following:changes from the prior year:
-_. :Developed individual investment strategies and maximum maturities for each type of
fund,'included in' the Investment Policy (operating funds, debt service funds,: debt,
service reserve funds, bond proceeds and capital projects funds and economic..
.development funds).
Removed the authority to invest in collateralized mortgage obligations.
Included the Assistant City Manager and Accounting Manager as Investment Officers.
- Included approved training organizations.
-=: Removed the Broker/Dealer Questionnaire.
Clarified existing wording and formatting.
Removed language that no longer applies.
SECTION 2
The .City Manager, Assistant City Manager, Finance Director, and Accounting Manager 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 ADPTED THIS 13th DAY OF SEPTEMBER.2022.
Stosh Boyle-
Mayor
ATTEST:
Peggy Cimics, TRMC
City Secretary
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
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's 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.
Li uidit
The Entity's 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
Marketability
The Entity's 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.
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.
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.
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.
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:
• 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.
• 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.
• 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.
• 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.
• 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.
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.
III. 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, Assistant City Manager, Finance Director, and Accounting Manager
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. A newly appointed Investment Officer
must attend a training session of at least 10 hours of instruction within twelve months of the date
the officer took office or assumed investment officer duties. The investment training sessions shall
be provided by an independent source approved and authorized to issue PFIA training
certification.
For purposes of this Policy, an "independent source" from which investment training shall be
obtained shall include a professional organization, an institution of higher education or any other
sponsor authorized to issue PFIA training certification. A list of independent training sources is
included in Appendix B.
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.
IV. 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.
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.
V. 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.
VI. 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.
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.
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.
Holdina 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 Obligations 50%
US Agencies/Instrumentalities 50%
Municipal instruments /see Vlll. F.) 20%
Certificates of Deposit 50%
Local Government Investment Pools 100%
Money Market Funds 100%
VII. 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; 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.
IX. 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
on 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.
X. COLLATERAL, SAFEKEEPING AND CUSTODY
Time and Demand Pledoed 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:
Cash.
FDIC insurance coverage.
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.
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.
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.
A letter of credit issued to the Entity by the Federal Home Loan Bank.
XI. INVESTMENT POLICY ADOPTION
The Entity's 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.
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, EDC Board, and PFC 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 Hilltop
Securities
Multi-Bank Securities, Inc. (MBS) Cantor
Fitzgerald & CompanyAPPENDIX C
CITY OF CIBOLO and CIBOLO ECONOMIC DEVELOPMENT CORPORATION BROKER/ DEALER
QUESTIONNAIRE
Name of Firm: Address:
Telephone:
Ownership/affiliation, if appropriate: Primary Representative on account:
Telephone: Fax:
E-Mail:
Backup representative or trading assistant: Telephone:
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.)
CITY OF CIBOLO and CIBOLO ECONOMIC DEVELOPMENT CORPORATION
BROKER 1 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. I
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Please attach a sample of standard research reports and your standard confirmation to be
provided to the Entity.
i
Please provide the firm's most recent audited financial statements. The Entity will require i
an annual financial statement be provided. j
What portfolio information do you require from your clients?
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1
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Describe the precautions taken by your firm to protect the interests of the public when
dealing with government agencies.
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j
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APPENDIX D
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:
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
The Representative of the Business Organization, have received and thoroughly reviewed
the Investment Policy of the Entity, and
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