(A) Purpose. The purpose of this policy is to provide investment objectives and guidelines for the management of public funds, to safeguard funds on behalf of the city, to assure the availability of funds when needed, to encourage investments that earn a competitive rate of return, and, at all times, to invest according to and consistent with IC 5-13-9 et seq., as amended.
(B) Investing officer. The City Controller is hereby designated, for the limited purpose of this section, as the city's investing officer and is hereby authorized to invest city funds in authorized funds or any fund that state statutes, as amended, may deem or consider an authorized fund prior to expiration of this Investment Policy. For the avoidance of doubt, this Policy shall be interpreted to authorize the City Controller to invest in any manner allowed by the Act (as defined in division (D) below); and to the extent that the Act allows greater investment authority than this section, the Act shall control.
(C) Minimum rating. Authorized funds in which the city's investing officer invests city funds shall have attained at least the minimum rating required by state statutes, as amended.
(D) State statutes. All investments made by the city's investing officer shall be made in accordance with IC 5-13 et seq. (the “Act”).
(E) Maturity date. The city's investing officer is hereby authorized to make investments up to five years in maturity. This policy authorizes longer term investments, defined as more than two years but not more than five years after the date of purchase or entry into a repurchase agreement ("longer term investments") pursuant to IC 5-13-9-5.6, as amended.
(F) Longer-term investments. The city's investing officer shall limit total longer-term investments outstanding to not more than 25% of the city's total portfolio, including balances in the city's transaction accounts. However, an investment is authorized and remains legal even if a subsequent decrease in the city's total portfolio of public funds invested, including balances in transaction accounts, causes the percentage of longer-term investments outstanding to exceed 25% of the city's total portfolio.
(G) Term of policy.
(1) This Investment Policy is and shall be effective upon adoption and publication as required by IC 5-13-9-5.7 and shall expire on May 15, 2027 (the "expiration date"). The power to make investments under this Investment Policy terminates on the expiration date.
(2) Investments made in accordance with this Investment Policy that are outstanding on or after the expiration date remain valid investments, and nothing herein shall be construed to render such investments improper or unlawful.
(H) Approval of investment officer. All investments made pursuant to this Investment Policy must be approved by the investing officer.
(I) Internal control/external review.
(1) The City Controller is responsible for establishing and maintaining policies and procedures to ensure that city assets are protected from loss, theft, or misuse. Such policies and procedures shall be discussed with and approved by the Mayor. The City Controller shall review all proposed investments with the Mayor or his/her designee before investing to maintain dual control, legal/ethical compliance, and to ensure both parties agree with the proposed investment.
(2) Annually, the City Controller shall conduct an independent review by an external auditor to ensure compliance with policies and procedures.
(J) Investment advisor. The investing officer is hereby authorized to contract with a federally regulated investment advisor or other institutional money manager to make investments under this Investment Policy.
(K) Certificates of deposit (CDs). Certificates of deposits, transaction accounts, and other interest-bearing deposit accounts may be used for investment of city funds pursuant to IC 5-13-9-5. The investment pool may be invested in negotiable CDs provided that market yields on CDs exceed treasury bills of comparable maturity and duration. All CD investments shall be insured by the FDIC. However, for institutions rated Prime-1, there is no limitation of total investment per institution. Total investment with a non-rated institution is limited to the lessor of 10% of the institution's capital and 90 days maximum maturity. In accordance with state law, this subchapter will expire two years from the date this section is adopted.
(L) Diversification of investments. The city's investment portfolio shall be diversified by institution, investment instruments and maturity schedule to the extent practical and prudent. Maturities shall be time diversified over a schedule determined by known liability to achieve target duration or weighted average maturity for the portfolio based on the judgment of the City Controller.
(M) Ethics and conflicts of interest. The Investment Officer and employees 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 which could impair their ability to make impartial decisions. The Investment Officer and employees involved in the investment process shall complete a conflict-of-interest form provided by the City Attorney affirming that the Investment Officer or employee does not have a pecuniary interest in the city's investments.
(N) Reporting.
(1) The City Controller shall maintain an inventory of all obligations and securities and shall provide quarterly investments reports to the city's Finance Committee detailing the following information: types of investments, depository institutions, principal balances, maturity dates, rates of return, purchases, and sales.
(2) The City Controller shall make an annual written report to the City Council summarizing the city's investments during the previous calendar year. The report must contain the name of each financial institution, government agency or instrumentality, or other person with whom the city invested money during the previous calendar year (IC 5-13-7). The City Council shall review the report and review the city's overall investment policy.
(3) The City Controller or his or her designee shall review the investment policy at least annually and propose such changes to safeguard funds on behalf of the city, to assure the availability of funds when needed, and to provide a competitive investment return.
(Ord. 091712A, passed 9-17-12; Am. Ord. 091514A, passed 11-17-14; Am. Ord. 061515D, passed 6-15-15; Am. Ord. 021819D, passed 2-18-19; Am. Ord. 051523A, passed 5-15-23)
Cross-reference:
Finance and revenue, see Ch. 34