Resolution No. 2023-57 Revising the City's Investment Policy- November 7, 2023 CITY OF AVENTURA RESOLUTION NO. 2023-57
A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF
AVENTURA, FLORIDA, REVISING CHAPTER 6.6 OF THE
ADMINISTRATIVE POLICY DIRECTIVES AND PROCEDURES
MANUAL, AS ATTACHED HERETO, ENTITLED "INVESTMENT
OBJECTIVES AND PARAMETERS" RELATING TO THE CITY'S
INVESTMENT POLICY FOR THE MANAGEMENT OF PUBLIC FUNDS;
AUTHORIZING THE CITY MANAGER TO DO ALL THINGS NECESSARY
TO CARRY OUT THE AIMS OF THIS RESOLUTION; AND PROVIDING
FOR AN EFFECTIVE DATE.
WHEREAS, on June 2, 2009, the City Commission adopted Chapter 6.6 of the
Administrative Policy Directives and Procedures ("APDP") Manual entitled "Investment
Objectives and Parameters"; and
WHEREAS, the City Commission last revised Chapter 6.6 by Resolution No. 2019-
10 on February 7, 2019; and
WHEREAS, the City Commission is desirous of amending further the above-
referenced Chapter 6.6 of the APDP Manual.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE
CITY OF AVENTURA, FLORIDA, THAT:
Section 1. The City Commission hereby revises Chapter 6.6 of the APDP
Manual, as attached hereto, entitled "Investment Objectives and Parameters" relating to
the City's Investment Policy for the management of public funds.
Section 2. The City Manager is hereby authorized to do all things necessary to
carry out the aims of this Resolution.
Section 3. This Resolution shall become effective immediately upon its
adoption.
The foregoing Resolution was offered by Vice Mayor Kruss, who moved its
adoption. This motion was seconded by Commissioner Bloom, and upon being put to a
vote, the vote was as follows:
Commissioner Amit Bloom Yes
Commissioner Rachel S. Friedland Yes
Commissioner Billy Joel Yes
Commissioner Dr. Linda Marks Yes
Commissioner Michael Stern Yes
Vice Mayor Paul A. Kruss Yes
Mayor Howard S. Weinberg Yes
City of Aventura Resolution No. 2023-57
PASSED AND ADOPTED this 7th day of November, 2023.
WARD S. WEINBERG, E
MAYOR
I :
ATTEST:
ELLISA L. HORVA MMC
CITY CLERK
APPROVED AS TO LEGAL SUFFICIENCY:
CITY ATTORNEY
Page 2 of 2
CITY OF AVENTURA 6 6 1
'-' ADMINISTRATIVE POLICY DIRECTIVES chapter# Sub Page
AND PROCEDURES MANUAL
Date May 22,
Issued: 2009
CHAPTER: FINANCE, BUDGET & PURCHASING APPROVED:
City Manager
SUBJECT: INVESTMENT OBJECTIVES AND PARAMETERS
PURPOSE
The purpose of this policy is to set forth the investment objectives and parameters for the management of public
funds of the City. These policies are designed to ensure the prudent management of public funds, the availability
of operating and capital funds when needed and a competitive investment return.
I. SCOPE
This investment policy applies to the investment of public funds in excess of amounts needed to meet
current expenses, which includes cash and investment balances of City funds.
This policy does not apply to the City's pension funds, including those funds in chapters 175 and 185 or
funds related to the issuance of debt where there are other existing policies or indentures in effect which
govern the investment of such funds.
This policy shall be construed and applied so as to comply with Section 218.415, F.S.
II. INVESTMENT OBJECTIVES
Investment objectives include safety of capital, liquidity of funds and investment income, in that order.
The following objectives will be applied in the management of the City's funds:
A. Safety of Capital
The primary objective of the City's investment program is the protection of public funds.
Investments shall be undertaken in a manner that seeks to ensure the preservation of capital in the
overall portfolio. The objective will be to mitigate credit risk and interest rate risk.
1. Credit Risk — The City will minimize credit risk, the risk of loss due to the failure of the security
issuer or backer, by:
a) Limiting investments to the safest type of securities;
b) Pre-qualifying the financial institution, broker/dealer, intermediaries and advisors with which
the City will do business;
c) Diversifying the investment portfolio so that potential losses on individual securities will be
minimized.
2. Interest Rate Risk — The City will minimize the risk that the market value of securities in the
APDP 6.6.2
3. portfolio will fall due to changes in general interest rates, by:
a) Structuring the investment portfolio so that securities mature to meet cash requirements for
ongoing operations, thereby avoiding the need to sell securities on the open market prior to
maturity;
b) Investing operating funds primarily in shorter-term securities, money market mutual funds or
similar investment pools.
B. Liquidity of Funds
The City's investment strategy will provide sufficient liquidity to meet the City's operating, payroll
and capital requirements. To the extent possible, an attempt will be made to match investment
maturities with known cash needs and anticipated cash flow requirements. Since all possible cash
demands cannot be anticipated, the portfolio should consist largely of securities with active
secondary or resale markets. A portion of the portfolio also may be placed in money market mutual
funds or local government investment pools which offer same-day liquidity for short-term funds.
C. Investment Income
The City's investment portfolio shall be designed with the intent of attaining a market rate of return
throughout the budgetary and economic cycles, taking into account the City's investment risk
constraints and liquidity needs. Return on investment is of secondary importance compared to the
safety and liquidity objectives described above.
III. PERFORMANCE MEASUREMENT
The investment portfolio will be managed in accordance with the parameters specified within this policy.
The portfolio should obtain a market average rate of return during a market/economic environment of
stable interest rates while insuring sufficient liquidity within the portfolio.
The short-term investment portfolio shall be designed with the annual objective of exceeding the return of
the Florida State Board of Administration LGIP.
The long-term investment portfolio shall be designed with the annual objective of exceeding the return of
the Bank of America Merrill Lynch 1-3 Year Treasury/Agency Index compared to the portfolio's total rate
of return. The Bank of America Merrill Lynch 1-3 Year Treasury/Agency Index represents all U.S.
Treasury/Agency securities maturing over one (1) year, but less than three (3) years. This maturity range
is an appropriate benchmark for the core portfolio based on the objectives of the City. For the Enhanced
Cash portfolio we will use the Bank of America Merrill Lynch 6 month Treasury Index.
IV. ETHICAL STANDARDS
The investment officer and staff, acting in accordance with the written procedures and exercising due
diligence, shall not be held personally responsible for a specific security's credit risk or market price
changes, provided that these deviations are reported immediately and that appropriate action is taken to
control adverse developments.
A. Ethics and Conflicts of Interest
The City's staff involved in the investment process shall refrain from personal business activity that
could conflict with the proper execution and management of the investment program, or that could
APDP 6.6.3
impair their ability to make impartial decisions. All employees involved in the investment process shall
disclose to the City any material financial interests in financial institutions that conduct business with
the City, and they shall further disclose any material personal financial/investment positions that could
be related to the performance of the City's investment program. Applicable ethics standards provided
by the City Charter, City Code, Section 2-11.1 of the Miami-Dade County Code, and Part III of
Chapter 112, F.S., shall be complied with.
B. Investments should be made with judgment and care, under circumstances then prevailing, which
persons of prudence, discretion and intelligence exercise in the management of their own affairs, not
for speculation, but for investment, considering the probable safety of their capital as well as the
probable income to be derived from the investment.
C. Designation of Investment Officer
The Finance Director is designated as investment officer of the City and is responsible for investment
decisions and the day-to-day administration of the cash management program. No person may
engage in an investment transaction except as provided under the terms of this policy and the
procedures so established. The City may appoint an outside investment manager as "Agent" for the
City's cash reserves. The "Agent" for the City shall have discretion over the purchase and sale of
securities within and subject to compliance with this investment policy. Such investment manager
must be registered under the Investment Advisor Act of 1940. The Finance Director shall consult with
the City Manager as necessary regarding the City's investment activity.
Positions authorized as investment signatories are the City Manager and Finance Director.
V. LISTING OF AUTHORIZED INVESTMENTS — (SUMMARY TABLE IN APPENDIX A)
The following investments will be permitted by this policy as consistent with Section 218.415 (16) F.S.
Those investments not listed in this section are prohibited.
A. United States Government Securities
Negotiable direct obligations or obligations the principal and interest of which are unconditionally
guaranteed by the United States Government. Such securities will include, but not be limited to the
following:
➢ Treasury Bills
➢ Treasury Notes
➢ Treasury Bonds
➢ Treasury Strips
➢ Treasury Securities—State and Local Government Series ("SLGS")
➢ Treasury Inflation Protection Securities ("TIPS")
Portfolio Composition
A maximum of 100% of available funds may be invested in the United States Government Securities
with the exception of Treasury Strips which are limited to 10% of available funds.
Maturity Limitations
The maximum length to maturity of any direct investment in the United States Government Securities
is seven (7) years from the date of purchase.
APDP 6.6.4
B. United States Government Agencies
Bonds, debentures or notes which may be subject to call, issued or guaranteed as to principal and
interest by the United States Governments agencies, provided such obligations are backed by the full
faith and credit of the United States Government. Such securities will include, but not be limited to the
following:
➢ United States Export— Import Bank
- Direct obligations or fully guaranteed certificates of beneficial ownership
➢ Federal Financing Bank
- Discount notes, notes and bonds
➢ Federal Housing Administration Debentures
➢ FDIC guaranteed notes ("TLGP" bonds)
➢ Government National Mortgage Association ("GNMA")
- GNMA guaranteed mortgage-backed bonds
- GNMA guaranteed pass-through obligations
➢ General Services Administration
➢ United States Public Housing Notes and Bonds
- United States Government guaranteed public housing notes and bonds
➢ United States Department of Housing and Urban Development
- Project notes and local authority bonds
Portfolio Composition
A maximum of 50% of available funds may be invested in United States Government agencies.
Limits on Individual Issuers
A maximum of 10% of available funds may be invested in individual United States Government
agencies.
Maturity Limitations
The maximum length to maturity for an investment in any United States Government agency security
is five (5) years from the date of purchase. Mortgage backed securities will have average duration
not greater than five (5) years.
C. United States Government Sponsored Agencies
Bonds, debentures or notes which may be subject to call, issued or guaranteed as to principal and
interest by United States Government sponsored agencies which are non-full faith and credit
agencies limited to the following:
➢ Federal Farm Credit Bank ("FFCB")
➢ Federal Home Loan Bank or its City Banks ("FHLB")
➢ Federal National Mortgage Association ("FNMA")
➢ Federal Home Loan Mortgage Corporation ("Freddie-Macs") including Federal-Home Loan
Mortgage Corporation participation certificates
Portfolio Composition
A maximum of 80% of available funds may be invested in Federal Instrumentalities.
APDP 6.6.5
Limits on Individual Issuers
A maximum of 25% of available funds may be invested in any one (1) issuer.
Maturity Limitations
The maximum length to maturity for an investment in any Federal Instrumentality security under this
Section (C) is seven (7) years from the date of purchase. Mortgage backed securities will have
average duration not greater than five (5) years.
D. Interest Bearing Time Deposit or Savings Account
Non-negotiable interest bearing time certificates of deposit or savings accounts in banks organized
under the laws of Florida or the United States provided that all deposits are secured by collateral as
prescribed by the Florida Security for Public Deposits Act, Chapter 280, Florida Statutes. The
concentration restriction outlined below does not apply to the City's operating account.
Portfolio Composition
A maximum of 10% of available funds may be invested in non-negotiable interest bearing time
certificates of deposit.
Limits on Individual Issuers
A maximum of 5% of available funds may be deposited with any one (1) issuer.
Limits on Maturities
The maximum maturity on any certificate shall be no greater than one (1) year from the date of
purchase.
E. Repurchase Agreements
1. Invest in repurchase agreements composed of only those investments based on the requirements
set forth by the City's Master Repurchase Agreement. A third party custodian with whom the City
has a current custodial agreement shall hold the collateral for all repurchase agreements with a
term longer than one (1) business day. A clearly marked receipt that shows evidence of
ownership must be supplied to the Finance Director or designee and retained. All firms are
required to sign the Master Repurchase Agreement prior to the execution of a repurchase
agreement transaction.
2. Collateralized by full faith or general faith and credit obligations of the United States Government
or United States Government Agency securities. Securities authorized for collateral must have
maturities under five (5) years and with market value for the principal and accrued interest of 102
percent of the value and for the term of the repurchase agreement. Immaterial short-term
deviations from 102 percent requirement are permissible only upon the written approval of the
Finance Director or designee and/or the City's Investment Manager.
Portfolio Composition
A maximum of 20% of available funds may be invested in repurchase agreements excluding one (1)-
business day agreements and overnight sweep agreements.
Limits on Individual Issuers
A maximum of 5% of available funds may be invested with any one (1) institution excluding one (1)-
business day agreements and overnight sweep agreements.
Limits on Maturities
The maximum length to maturity of any repurchase agreement is 90 days from the date of purchase.
APDP 6.6.6
F. The Florida Local Government Surplus Funds Trust Fund
(State Board of Administration —SBA)`
Portfolio Composition
A maximum of 65% of available funds may be invested in the SBA.
G. Intergovernmental Investment Pools
Investment Authorization
Intergovernmental investment pools that are authorized pursuant to the Florida Interlocal
Cooperation Act, as provided in Section 163.01, Florida Statutes and provided that said funds
contain no derivatives.
Portfolio Composition
A maximum of 25% of available funds may be invested in intergovernmental investment pools.
Due Diligence Requirements
A thorough review of any investment pool/fund is required prior to investing, and on a continual
basis. There shall be a questionnaire developed by the Finance Director or designee and/or the
City's Investment Manager that will contain a list of questions that covers the major aspects of any
investment pool/fund.
H. Registered Investment Companies (Money Market Mutual Funds)
Registered with the Securities and Exchange Commission with the highest credit quality rating from a
nationally recognized rating agency; portfolio is limited to direct obligations of the United States
Government or any agency or instrumentality thereof.
Portfolio Composition
A maximum of 35% of available funds may be invested in money market funds.
Limits of Individual Issuers
A maximum of 15% of available funds may be invested with any one (1) money market fund.
Rating Requirements
The money market funds shall be rated "AAAm" or "AAAm-G" or better by Standard & Poor's, or the
equivalent by another rating agency.
Due Diligence Requirements
A thorough review of any money market fund is required prior to investing, and on a continual basis.
There shall be a questionnaire developed by the Finance Director or designee and/or the City's
Investment Advisor/s that will contain a list of questions that covers the major aspects of any money
market fund.
I. Commercial Paper
Commercial paper of any United States company that is rated "Prime-1" by Moody's and "A-1" by
Standard & Poor's (prime commercial paper). If the commercial paper is backed by a letter of credit
("LOC"), the long-term debt of the LOC provider must be rated "A" or better by at least two (2)
nationally recognized rating agencies.
APDP 6.6.7
Portfolio Composition
A maximum of 25% of available funds may be directly invested in prime commercial paper.
Limits on Individual Sectors
A maximum of 10% of available funds may be invested with any one sector.
Limits on Individual Issuers
A maximum of 2% of available funds may be invested with any one issuer.
Maturity Limitations
The maximum length to maturity for prime commercial paper shall be 270 days from the date of
purchase.
I Corporate Notes
Corporate notes issued by corporations organized and operating within the United States or by
depository institutions licensed by the United States that have a long term debt rating, at the time or
purchase, "A" or better by at least two (2) nationally recognized rating agencies.
Portfolio Composition
A maximum of 25% of available funds may be directly invested in corporate notes.
Limits on Individual Sectors
A maximum of 10% of available funds may be invested with any one sector.
Limits on Individual Issuers
A maximum of 2% of available funds may be invested with any one issuer.
Maturity Limitations
The maximum length to maturity for corporate notes shall be five (5) years from the date of purchase.
K. Taxable/Tax-Exempt Municipal Bonds
Debt obligations of non-profit entities such as states, counties, cities, authorities or other institutions.
These may be taxable or tax-exempt and may be General Obligation (GO's) and/or Revenue Bonds
and must be rated "A" by Moody's, Standard & Poor's or Fitch for long term debt, or rated at least
WIG-2 by Moody's, SP-2 by Standard & Poor's or F-2 by Fitch.
Portfolio Composition
A maximum of 25% of available funds may be directly invested in Taxable and/or Tax Exempt Debt.
Limits on Individual Issuers
A maximum of 2% of available funds may be invested with any one issuer.
Maturity Limitations
The maximum length to maturity for Taxable and/or Tax Exempt Debt shall be five (5) years from the
date of purchase
APDP 6.6.8
L. Asset Backed Securities
Invest in Asset Backed Securities (ABS) issued by corporations organized and operating within the
United States or by depository institutions licensed by the United States that have a long term debt
rating, at the time of purchase, AAA or the equivalent by at least two (2) nationally recognized
rating agencies.
Portfolio Composition
A maximum of 15% of available funds may be directly invested in ABS.
Limits on Individual Sectors
A maximum of 10% of available funds may be directly invested in ABS of any one industry sub-sector
as defined by Bloomberg Industry Groups.
Limits on Individual Issuers
A maximum of 2% of available funds may be invested with any one issuer.
Maturity Limitations
The maximum length to maturity for ABS shall be (5) 5 years from the date of purchase.
M. Israel Bonds
Direct obligations from the State of Israel denominated in US dollars. Obligations may include, but
are not limited to:
• Institutional-class bonds that are broadly syndicated and registered with the SEC or other US
regulatory agency
• Retail-class offerings that may require safekeeping arrangements, may not be registered by the
SEC or other US regulatory agency and/or may not offer secondary market liquidity
Portfolio composition
A maximum of $399,999.99 500,000.00 in par value may be invested in direct obligations from the
State of Israel, excluding securities guaranteed by the US government through its AID program or any
of its agencies.
Maturity Limitations
The maximum length to maturity for Israel bonds shall be three (3) years from the date of purchase.
VI. PROHIBITIONS
The purchase of derivative instruments as defined by the Government Account Standards Board
("GASB") or any investment instrument which is structured to derive a rate of return from an investment
source other than the originally purchased investment is strictly prohibited.
VI I. INVESTMENT PARAMETERS
A. Maturity and Liquidity Requirements
To the extent possible, the City shall attempt to match its investments with anticipated cash flow
requirements. Unless matched with a specific cash flow, the City will not directly invest in securities
maturing more than seven (7) years from the date of purchase. Mortgage backed securities will have
average duration not greater than five (5) years.
APDP 6.6.9
Because of inherent difficulties in accurately forecasting cash flow requirements, a portion of the
portfolio should be continuously invested in readily available funds such as Local Government
Investment Pools, or money market funds to ensure that appropriate liquidity is maintained to meet
ongoing obligations.
Vill. SAFEKEEPING AND CUSTODY
A. Authorized Investment Institutions and Dealers
The City shall only purchase investments from the State Board of Administration, Florida Municipal
Investment Trust, financial institutions which are qualified as public depositories by the Treasurer of
the State of Florida, primary security dealers (or their agents) as designated by the Federal Reserve
Bank of New York, or by secondary securities dealers (or their agents) who act as investment banking
arms of local qualified banking institutions.
All financial institutions and broker/dealers who desire to provide investment services must supply the
following as appropriate and as requested:
1. Annual audited financial statements;
2. Public depository certification;
3. Proof of National Association of Securities Dealer ("NASD") Certification;
4. Certification of having read the City's investment policy;
5. Credit rating provided by a nationally recognized monitoring agency.
B. Delivery vs. Payment
All trades where applicable will be executed by delivery versus payment ("DVP") to ensure that
securities are deposited in an eligible financial institution prior to the release of funds. Securities
will be held by a third-party custodian as evidenced by safekeeping receipts.
C. Master Repurchase Agreement
The investment policy shall require all approved institutions and dealers transacting repurchase
agreements to execute and perform as stated in the Master Repurchase Agreement. All
repurchase agreement transactions shall adhere to the requirements of the Master Repurchase
Agreement.
D. Bid Requirements
Investments will be chosen based on liquidity needs and market conditions. The investments will
be competitively bid when feasible and appropriate. Except as required by law, the bid deemed to
best meet the investment objectives must be selected.
E. Internal Controls
The Finance Director is responsible for establishing and maintaining an internal control structure
designed to ensure that the assets of the City 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 the cost of a control should not exceed the
benefits likely to be derived and the valuation of costs and benefits requires estimates and
judgments by management.
APDP 6.6.10
Accordingly, the Finance Director shall establish a process for an annual independent review as
part of the annual financial audit to assure compliance with the policies and procedures. The
internal controls shall address the following points:
1. Control of collusion — Collusion is a situation where two (2) or more employees are working in
conjunction to defraud their employer.
2. Separation of transaction authority from accounting and record keeping — By separating the
person who authorizes or performs the transaction from the people who record or otherwise
account for the transaction, a separation of duties is achieved.
3. Custodial safekeeping — All securities, with the exception of certificates of deposit, shall be held
with a third-party custodian; and all securities purchased by, and all collateral obtained by the City
should be properly designated as an asset of the City. The securities must be held in an account
separate and apart from the assets of the financial institution. No withdrawal of such securities, in
whole or in part, shall be made from safekeeping except by the Finance Director as authorized
herein, or by their respective designee.
4. Certificates of Deposit issued by a local bank or savings and loan association may be held in
safekeeping at that institution. The institution shall issue a copy of the certificate of deposit, a
safekeeping receipt, or some other confirmation of the purchase that is satisfactory to the Finance
Director. This will be kept on file in the Finance Department and will indicate the amount, interest
rate, issue date and maturity date of the certificate of deposit.
5. Avoidance of physical delivery securities — Book entry securities are much easier to transfer and
account for since actual delivery is never taken. Physical delivery securities must be properly
safeguarded against loss or destruction. The potential for fraud and loss increases with physically
delivered securities.
6. Clear delegation of authority to subordinate staff members — Subordinate staff members must
have a clear understanding of their authority and responsibilities to avoid improper actions.
7. Written confirmation of telephone transactions for investments and wire transactions — Due to the
potential for error and improprieties arising from telephone transactions, all telephone transactions
should be supported by written communications and approved by appropriate personnel unless an
agreement is executed with a financial institution as discussed in paragraph B.8 below.
8. Development of a wire transfer agreement with a bank or third-party custodian — This agreement
should outline the various controls and security provisions for making and receiving wire transfers.
IX. CONTINUING EDUCATION
The Finance Director and Controller shall annually complete eight (8) hours of continuing education in
subjects or courses of study related to investment practices and products.
X. REPORTING
The Finance Director shall provide a quarterly investment report to the City Manager. The report shall list
investments by fund and type and include the book value, income earned and market value as of the
report date.
APDP 6.6.11
XI. SECURITIES; DISPOSITION
A. Every security purchased under this section on behalf of the governing body of the City must be
properly earmarked and:
1. If registered with the issuer or its agents, must be immediately placed for safekeeping in a location
that protects the governing body's interest in the security;
2. If in book entry form, must be held for the credit of the governing body by a depository chartered
by the Federal Government, the state, or any other state or territory of the United States which
has a branch or principal place of business in this state as defined in s. 658.12, or by a national
association organized and existing under the laws of the United States which is authorized to
accept and execute trusts and which is doing business in this state, and must be kept by the
depository in an account separate and apart from the assets of the financial institution; or
3. If physically issued to the holder but not registered with the issuer or its agents, must be
immediately placed for safekeeping in a secured vault.
B. The City may also receive bank trust receipts in return for investment of surplus funds in securities.
Any trust receipts received must enumerate the various securities held, together with the specific
number of each security held. The actual securities on which the trust receipts are issued may be
held by any bank depository chartered by the Federal Government, this state, or any other state or
territory of the United States which has a branch or principal place of business in this state as defined
in s. 658.12, or by a national association organized and existing under the laws of the United States
which is authorized to accept and execute trusts and which is doing business in this state.
XII. SALE OF SECURITIES
When the invested funds are needed in whole or in part for the purposes originally intended or for more
optimal investments, the City may sell such investments at the then-prevailing market price and place the
proceeds into the proper account or fund of City.
XIII. PREEXISTING CONTRACT
Any public funds subject to a contract or agreement existing on May 1, 2009, may not be invested
contrary to such contract or agreement.
XIV. AUDITS
Certified public accountants conducting audits of the City pursuant to s. 218.39 shall report, as part of the
audit, whether or not the City has complied with section 218.415, F.S., and this Investment Policy.
XV. AUTHORIZED DEPOSITS
In addition to the investments authorized for the City in subsection (VIII), as authorized by paragraph (23)
of Section 218.415, F.S., the City may deposit any portion of surplus public funds in its control or
possession in accordance with the following conditions:
A. The funds are initially deposited in a qualified public depository, as defined in s. 280.02, selected by
APDP 6.6.12
the City.
B. The selected depository arranges for the deposit of the funds in certificates of deposit in one (1) or
more federally insured banks or savings and loan associations, wherever located, for the account of
the City.
C. The full amount of principal and accrued interest of each such certificate of deposit is insured by the
Federal Deposit Insurance Corporation.
D. The selected depository acts as custodian for the City with respect to such certificates of deposit
issued for its account.
E. At the same time the City's funds are deposited and the certificates of deposit are issued, the selected
depository receives an amount of deposits from customers of other federally insured financial
institutions, wherever located, equal to or greater than the amount of the funds initially invested by the
City through the selected depository.
XVI. PROHIBITED INVESTMENTS
The City is prohibited from investing in any company that engages in business with the countries of Iran
and Sudan. The City Manager may promulgate specific requirements for the implementation of this
provision based upon criteria applied by the Local Government Surplus Funds Trust Fund for such
purpose.
The City may not invest in companies that are included in the Scrutinized Companies that Boycott Israel
List as provided by Sec. 215.4725, Florida Statutes, which is used by the State Board of Administration,
unless an exception provided in that statute is applicable.
XVII. INVESTMENT POLICY REVIEW
The Finance Director shall review this Investment Policy on a semi-annual basis. Any recommended
changes to this policy must be approved by the City Manager and subsequently by the City Commission.
However, upon the initial approval of this Investment Policy by resolution of the City Commission, this
Investment Policy shall be amended by the City Manager without the necessity of further action by the
City Commission, to the extent that said amendments are necessary for conformance with any
amendments made to Section 218.415, F.S.
Originally Adopted —June 2, 2009 (Resolution No. 2009-30)
Revised —September 22, 2009 (Ordinance No. 2009-17)
Revised — November 1, 2011 (Resolution No. 2011-61)
Revised —July 8, 2014 (Resolution No. 2014-33)
Revised —October 10, 2016 (Resolution No. 2016-59)
Revised —October 18, 2018 (Resolution No. 2018-88)
Revised — February 7, 2019 (Resolution No. 2019-10)
*Investments managed internally by City staff, not managed by Investment Advisor
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