HomeMy WebLinkAbout2026-01-06 Finance Committee Summary MinutesFINANCE COMMITTEE
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Special Meeting
January 6, 2026
The Finance Committee of the City of Palo Alto met on this date in the Community Meeting
Room and by virtual teleconference at 5:30 p.m.
Present In-Person: Burt (Chair), Lythcott-Haims, Reckdahl
Absent: None
Call to Order
Councilmember Burt called the meeting to order. The clerk called the roll.
Public Comment
None
Agenda Items
1. Recommend the City Council Adopt Revisions to the City’s Investment Policy; CEQA Status –
Not a Project
Administrative Services Department (ASD) Assistant Director Christine Paras said the Code and
the City’s Investment Policy required annual review by the City Council. Finance Committee
recommendation preceded City Council review. City staff worked in collaboration with Chandler
Asset Management to ensure the investment policy was current with laws, market trends and
best practices as well as in alignment with Council priorities. The proposed revisions increased
the permitted investment types to enhance diversification and return potential, augmented
concentration and credit quality limits to better mitigate risk, strengthened the list of
prohibited investments to provide stronger protections and improved policy readability by
clearly defining investment parameters. The revisions were categorized under policy philosophy
and governance, readability and technical updates. The objective was to shift from a hold-to-
maturity philosophy and a transactional focus to more active management with a defined
minimum liquidity needed to conduct operations. The new policy philosophy allowed tactical
sales before maturity, thus providing the ability to flex with the changing market, for example,
if a purchase of an investment was done in a very low interest rate market and an opportunity
arose where the City could invest in higher return and not a net loss. Governance was
established through clarifying management directives with Chandler Asset Management to
support the goals of safety, liquidity and return.
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Carlos Oblites, Senior Portfolio Strategist at Chandler Asset Management, added it was
desirable for the City to take a loss up front when the following 4 criteria were met: A greater
gain would be realized through the reinvestment of a higher yielding security when that action
netted a higher return and repositioned the portfolio to the target duration, rotated in sectors
that were in favor and improved liquidity and credit quality.
Councilmember Reckdahl inquired in what situations was the City not allowed to take a loss.
Mr. Oblites from Chandler Asset Management replied the City’s policy did not restrict taking
losses for certain circumstances. A sale before maturity that involved a loss may be done to
exchange it for something else to move the portfolio forward. Chandler Asset Management
tried to avoid taking a loss when the previously stated 4 criteria were not met.
Assistant Director Paras continued outlining the philosophy and governance revisions to the
investment policy. Reporting was shifted from par value to a market value basis to give readers
a reaI-time view of the portfolio’s worth and performance, which was important when making
investment decisions. A detailed review of the policy was completed to improve readability.
The revised policy included language to clarify prohibited investments, how trades and
relationships with financial institutions were governed and aligned the policy with Code to
enhance diversification and return potential. In the category of technical updates,
concentration and credit quality limits were changed for certain authorized investments. The
strategic goal was to change the investment mix. The ASD did not have resources to continually
monitor and evaluate credits. Now, the City would leverage Chandler Asset Management’s
credit research team to identify stable and improving credits as well as ensure that weak or
deteriorating credits were avoided and removed from the portfolio. This added layer of review
helped the City take on additional risk. The proposed policy revisions increased limits for
banker’s acceptance notes, collateralized bank deposits, negotiable CDs, medium-term notes
and supranational organizations. The proposed changes were in line with the California
Government Code. The credit rating agencies under the current policy were S&P, Moody’s and
Fitch, whereas the revised policy included all Nationally Recognized Statistical Rating
Organizations (NRSROs) registered and regulated by the SEC.
Council Member Reckdahl asked how many rating organizations there were. Council Member
Reckdahl wanted to clarify that the primary purpose for the change was due to the Government
Code but also to utilize other rating organizations as a second opinion.
Mr. Oblites from Chandler Asset Management stated there were approximately 10 rating
agencies but Chandler Asset Management primarily relied on the top 3. Part of the reason for
making the policy language change was because the California Government Code used the term
Nationally Recognized Statistical Rating Organization or NRSRO. Also, Chandler Asset
Management wanted to have flexibility. Businesses could change, merge or fold, so referring to
specific rating agencies by name was not optimal. When a security was rated by 1 main rating
agency, it could be helpful to get an opinion from minor rating agencies. Generally, Chandler
Asset Management did not buy if it was not rated what they wanted by 1 of the 3 rating
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agencies but their internal rating and credit analysis processes looked at research from minor
rating agencies.
Assistant Director Paras stated the bulk of the changes were in the Authorized Investments
section, which was shown on the slides.
Council Member Reckdahl asked if all GSEs had full faith and credit. Council Member Reckdahl
queried if revenue bonds would be purchased, such as those sold by the Post Office. The policy
was changed from 25 percent callable to 20 percent but Councilmember Reckdahl wondered if
the target was 20 percent or lower. Councilmember Reckdahl noted that bond prices fluctuated
and there was no upside to a callable bond. If the price goes down, you were stuck with the
bond and lost money. If the price goes up, the bond was called.
Mr. Oblites from Chandler Asset Management explained that federal agencies and government-
sponsored enterprises (GSEs) had full faith and credit of the actual agency. Only the
Government National Mortgage Association (Ginnie Mae) had full faith and credit of the United
States Government. Ginnie Mae issued long-term mortgages. Federal agencies had an implied
backing from the federal government. Fannie Mae and Freddie Mac played a pivotal role in the
United States housing market and greater economy, thus the federal government had a strong
incentive to not allow federal agencies such as those to go under. Chandler Asset Management
planned to buy some GSE mortgages primarily packaged by Freddie Mac that had the full
backing of the federal agency. The desire was to have GSEs that were large issuers of debt
where you were a minority lender in a very large program. Chandler Asset Management
generally did not purchase revenue bonds because the post office or small business bureau
typically did not have that bulk. Chandler Asset Management wanted to introduce liquidity and
widely held issues.
Mr. Oblites from Chandler Asset Management did not see any reason to buy callable agencies
because the extra yield paid by the issuer generally did not compensate for the investor’s
additional risk; therefore, callable agencies would be much lower than 20 percent. A callable
agency is a bond where the issuer could call it back before maturity to reissue it. Chandler Asset
Management bought when market forces made callable bonds cheap with a high enough yield.
In the last 15 years, Mr. Oblites from Chandler Asset Management had seen 2 time periods in
the markets when it made sense to buy callable agencies but not up to 20 percent.
Councilmember Burt wanted to clarify if “callable and step-up securities from 25 percent to 20
percent of portfolio” on the slide referred to a range or a reduction from 25 percent to 20
percent of the portfolio. Councilmember Burt also sought clarification on the new 30 percent
limit in any single GSE.
Mr. Oblites from Chandler Asset Management stated the 20 percent limit was only applicable
to federal agency callable securities. The California Government Code placed no limit on
callable agencies and the City’s current investment policy did not have any limits but it was
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prudent to have a 30 percent limit per issuer. Callable and step-up securities decreased from 25
percent to 20 percent in the red line of the revised investment policy.
Councilmember Lythcott-Haims inquired how many more entities did the City now have access
to as a result of the decision to allow investments in bonds with an A rating.
The Code did not allow buying DDD, which was the bottom of the investment-grade world. The
City’s current investment policy allowed AA and AAA corporate debt. The revised policy allowed
corporate debt in medium-term notes, A, AA and AAA. Mr. Oblites from Chandler Asset
Management said AAA names could be counted in 1 hand, AA was maybe 10 to 15 percent and
A was 40 to 60 percent of the investment-grade world. The ability to buy A gave access to many
more names in different subsectors such as finance, consumer staples, technology and
insurance; however, this introduced additional credit risk to the portfolio. Risk could not be
eliminated but Chandler Asset Management used various tools to mitigate risk, including a
credit analysis process, risk management process and issuer limits. Credit rating was the initial
filter for a list of names to review. Chandler Asset Management only bought names that met
certain criteria, were vetted through their credit committee and approved by their chief
investment officer. The Code was silent on issuer limits unless it was bought in conjunction with
commercial paper unsecured debt. The revised policy had a 5 percent issuer limit; however,
Chandler Asset Management generally did not expose a portfolio to more than 2 percent per
name. Some of the stronger credits might make up 1 or 1.5 percent of the portfolio and very
few were more than 1.5 percent.
Councilmember Burt posed the following questions: In the Great Recession, at what point were
there defaults or near defaults in different categories? On average, how much greater gain did
an A provide versus AA or AAA? What were the benefits of diversification? Of the names that
the City might have an investment in, which ones were most exposed to an AI bubble bust?
Was it transparent what businesses were investing in real estate related to server farms?
Mr. Oblites from Chandler Asset Management said the government stepped in and took over
the GSEs and federal agencies because they packaged mortgages that included subprime but
they never went under or defaulted during the global financial crisis. Chandler Asset
Management did not buy subprime but would buy federal agency-issued mortgages and some
of them carried extraordinary protections for investors. Because of the hit to the greater
economy during the global financial crisis, some names experienced downgrades in the
medium-term note sector. The ones that took the biggest hits were Washington Mutual, AIG,
Lehman Brothers, and Bair Sterns. Most reputable firms having a strong credit process were not
invested in most of those names. For example, Lehman Brothers stock price dropped quickly, so
investors knew. To mitigate risk, Chandler Asset Management used risk management, credit
analysis and fundamental analysis of financials including a company’s ability to generate cash
and revenue, if there were multiple lines of revenue, its holdings and how a company compared
against their peer group. Chandler Asset Management did not buy GE months before they had
problems with their turbines.
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Mr. Oblites from Chandler Asset Management noted there was not a lot of credit spread
between AA and A. Between A, AA and AAA, you pick up additional yield from 5 to 15 basis
points higher (15 basis points was 0.15 percent), providing additional payoff and diversification.
Currently, the City was limited to a few names and unable to diversify the medium-term
corporate notes in the portfolio. Chandler Asset Management wanted names from different
subsectors in the City’s portfolio because their responses to a movement in the greater
economy were less correlated. NVidia was most exposed to an AI bubble bust. Some tech
names Chandler Asset Management bought were Meta, Amazon.com, Apple and Alphabet
(Google) but did not purchase NVidia. Chandler Asset Management bought Prologis, a logistics
corporation that moved merchandise. Chandler Asset Management invested in a REIT that
issued bonds to acquire and manage warehouse space. Chandler Asset Management had an
approved list of private placements and purchased AAA rated bonds from U.S. Bank, New York
Life, MetLife, Guardian, and Chubb. Information was very accessible and there was
transparency on the fundamentals that drove the value of the bond, the way the issuer
generated cash and their ability to pay you back. Chandler Asset Management’s credit process
included meeting with the finance teams of every issuer on their approved list to understand
how they thought about the markets, their future prospects, how they explain various aspects
of their balance sheet and income statement and where the company was headed.
As of September, Councilmember Reckdahl noted Palo Alto owned the corporate bonds of
Alphabet, Microsoft, Apple, Johnson & Johnson, Northwestern Mutual Life Insurance and a
couple universities.
Councilmember Lythcott-Haims pointed out there had been many bubbles over the decades. To
avoid getting caught in an unfortunate position if and when an AI bubble occurred,
Councilmember Lythcott-Haims wanted Chandler Asset Management to be aware this was a
concern and thought it might be helpful to periodically check back in on this issue on an
ongoing basis.
Mr. Oblites from Chandler Asset Management would keep in mind the Committee’s interest in
the AI field. Mr. Oblites was the Co-Chair for Chandler Asset Management’s Multi-Asset Class
Committee and that committee was keenly focused on the outlook, the next bubble, AI,
geopolitical risk, currency risk and what was happening with oil and commodities. That
information was shared with all of Chandler Asset Management’s committees and their Risk
Management Committee addressed those things.
Councilmember Reckdahl asked the following questions: Were A-rated investments limited to
short-term notes and AA for intermediate-term bonds? Did Chandler Asset Management sell
immediately if an A went down to DDD? Would Chandler Asset Management call the City if
there was a ratings watch?
Mr. Oblites from Chandler Asset Management was comfortable buying an A credit on their list
of approved issuers out to the maximum limit of 5 years. Going beyond 5 years for medium-
term corporate notes was not allowed. By law, you could only go beyond 5 years for federal
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agencies, municipal securities and treasuries. Chandler Asset Management did not sell
immediately when an A went down to DDD. Sometimes the rating change did not make sense.
According to Section 53601, California Government Code only applied at the time of purchase.
There was no requirement to sell a downgraded security. A bond lost value when it
downgraded beneath eligible credit quality. Not always but Mr. Oblites from Chandler Asset
Management generally observed an immediate overreaction by investors and then the levels
came back, so it was not always economically advisable to get rid of the bond. It did not happen
very often but if there was a downgrade beneath A in any of the City’s issuers, Mr. Oblites from
Chandler Asset Management would call to notify the City’s team and ensure staff was
comfortable with the advised plan. Staff might opt to wait a certain amount of time before
getting out of the bond, request getting rid of the bond immediately, or ask what would trigger
Chandler Asset Management to start moving out of the bond. Chandler Asset Management
would not notify City staff of a ratings watch, although it would factor heavily in the analysis of
that issuer and their credit team may place a hold on it or start selling it gradually.
The discussion moved to Authorized Investments, Slide 5. Councilmember Reckdahl asked for
more information on collateralized bank deposits and if it was the same as a repo.
Councilmember Reckdahl questioned why the portfolio had a limit for CDs if they could be
spread out among different places to be under FDIC.
Mr. Oblites from Chandler Asset Management explained that California Government Code
treated the City’s bank deposit as part of the City’s investment program. By law, the bank
where the City had its banking account was required to collateralize the City’s deposits,
meaning the bank was required to hold collateral in some form, typically treasuries and
agencies. Bank deposits in the United States carried FDIC insurance up to $250,000. Credit
unions carried NCUA insurance up to $250,000. The CFO or Finance Director, whoever was the
City’s treasurer, could waive collateral for the portion covered by FDIC insurance but the bank
was legally required to collateralize anything over $250,000. On a weekly basis, banks had to
submit to the State Controller’s Office or the State Finance Office in Sacramento the collateral
held for any local government money.
Certificates of deposits were illiquid time deposits that accrued interest until it matured and
you get your money back but there was a penalty if you broke it early. The negotiable
certificates of deposits (brokered CDs) in the City’s policy were popular and traded in a
secondary market. A brokered CD servicer gets CDs from banks all over the country and
aggregated them. Under banking rules, brokered CDs were considered a deposit and had FDIC
insurance for the first $250,000. Negotiable certificates of deposits were illiquid. The City would
pay a penalty if it locked a $250,000 tranche for 5 years and had to get out of it for
repositioning to get a better yield or because money was needed. Chandler Asset Management
wanted liquidity for the City to access cash if there was an emergency, not just yield.
Assistant Director Paras recalled there were about 7 or 8 pages of CDs on the last investment
activity report. The revised policy allowed the City to consolidate CDs above the $250,000 FDIC
insured amount into single issuers rated A-1 or better.
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Mr. Oblites from Chandler Asset Management clarified that A-1 was a short-term rating. The
Code was silent on a maximum maturity for CDs, municipal securities, treasuries, and agencies.
The revised investment policy stated that any amount beyond FDIC insurance needed to have
either a short-term rating for shorter maturities or a long-term rating for longer maturities.
Councilmember Reckdahl pointed out that issuers shopped for rating agencies and paid the
rating agency, so he wondered if it was safer to have 2 rating agencies instead of a single rating
agency and if it was addressed by Dodd-Frank. Councilmember Reckdahl asked if it was legal for
the City to buy Palo Alto municipal bonds.
Mr. Oblites said NRSROs took note after the global financial crisis because they got in trouble
for a lot of those mortgage ratings, so Chandler Asset Management was not concerned now.
Most issuers got 2 ratings from S&P, Moody’s or Fitch; however, most municipal bonds carried
1 rating. Some had split ratings. Goldman Sachs was A rated by a major rating agency and the
other was a BBB; therefore, it was not a name that Chandler Asset Management would put in
the City’s portfolio because the City was very sensitive about credit. The City’s revised
investment policy mirrored the law. California Government Code required 1 NRSRO. Mr. Oblites
from Chandler Asset Management did not think Dodd Frank touched the rating agencies but
Sarbanes-Oxley did. The City was allowed to buy Palo Alto municipal bonds but had to be very
careful and work with the City’s municipal advisor because that action could be considered a
pre-refunding and have tax implications. The City could buy Palo Alto municipal bonds on a
secondary market and this was addressed in the City’s policy language.
With the policy change in compliance limits from par value to market value, Councilmember
Reckdahl inquired how often the portfolio’s compliance was determined because the market
value had to be calculated to see if the portfolio became uncompliant. Councilmember
Reckdahl wanted to know how difficult it was to find the market value for bonds and if
Chandler Asset Management had to call a broker for a quote when buying corporate or
municipal bonds.
Mr. Oblites said the City’s current pre-trade compliance policy was reviewed by Chandler Asset
Management’s compliance team and written as a set of rules into the Bloomberg AIM
compliance module after review by the portfolio manager and Mr. Oblites. Chandler Asset
Management did all their trading on the Bloomberg system. Pre-trade when the portfolio
manager purchased a bond, the Bloomberg AIM compliance module checked if the trade met
the rule requirements; if not, the trade was automatically kicked out. If the portfolio manager
tried to override a kicked-out trade, a notification was sent to the Chandler Asset Management
Chief Investment Officer and Chief Compliance Officer. Bloomberg AIM generated a VMGR
(Violation Manager) to warn of compliance violations. There was a daily electronic review of the
portfolio. City staff would receive a monthly report on the compliance status along with the
City’s month-end statements. Mr. Oblites from Chandler Asset Management would come
quarterly to review a report with City staff on the status of the portfolio.
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Lauren Lai, Chief Financial Officer and Administrative Services Department Director, mentioned
the compliance confirmation was included in the quarterly investment report submitted to the
Council.
Mr. Oblites from Chandler Asset Management emphasized this was a safety and liquidity
portfolio. The average duration of this portfolio was 2½ years, which meant it would take a
dramatic 100 basis point shift in the capital markets in rates across the board to cause a 2½
percent move in the portfolio market value. The last time that happened was during the
pandemic when rates went from 1 to 0. Mr. Oblites from Chandler Asset Management
reiterated that compliance under the law was at time of purchase. It was not a compliance
violation if the market value changed such that the percentages went beyond what was allowed
by the City’s investment policy, although Chandler Asset Management’s compliance team
would notify somebody internally and it might be flagged and have a note put next to it saying
it complied at time of purchase.
Mr. Oblites from Chandler Asset Management said there were no more phone calls to brokers
for quotes and to buy bonds, everything was done electronically. Chandler Asset Management
saw the brokerage inventory. Bonds had different prices depending on where they were bought
and Chandler Asset Management would look to purchase at the lowest price. The market value
of securities purchased in the bond markets was whatever somebody was willing to sell it for,
so most institutions used a third-party pricing source to value it in the portfolio. Market values
may differ very minimally from the vendor that provided a pricing source to Chandler Asset
Management and U.S. Bank, the City’s prior pricing source. The Governmental Accounting
Standards Board pronouncement GASB No. 72 required City staff to classify the market values
observed for every asset in its portfolio in 3 categories (immediately observable, observable
based on similar securities, and not observable) at fiscal yearend when financial statements
were issued in the audit. Mr. Oblites from Chandler Asset Management said the desire was to
make decisions based on the true economic value of the portfolio and you could not do that
with par value. Market value was a better representation of the City’s economic position by
reflecting the true value of the assets.
Councilmember Reckdahl felt that City staff and Chandler Asset Management did a good job
overall. On Packet Page 13, Councilmember Reckdahl agreed with the change from yield to
return and getting rid of buying and holding. The maximum maturity was 10 years in General
Investment Guideline 1 on Packet Page 14. Councilmember Reckdahl wondered if the City
would be buying 10-year bonds and if there were compliance requirements on duration.
Councilmember Lythcott-Haims asked for an explanation on the difference between yield and
return.
Mr. Oblites from Chandler Asset Management answered that yield was the same as an internal
rate of return (IRR), which referred to the income generated expressed as a percentage of what
you paid for the security and was on an annualized basis to see what you should be earning into
the future. Return meant how much a given activity had grown the portfolio over a specific
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period. The 2 factors that drove a return were interest income determined by the yields you
pick up and the change in fair value of the portfolio. The total return would be reported to staff
and the Council. Chandler Asset Management wanted to mirror the prioritized objectives in
California Government Code Section 53600 of safety first, followed by liquidity and then return.
Mr. Oblites said the City’s investment strategy was to maintain the bulk of the investments
between 1 and 5 years with an average duration of 2½ years; therefore, Chandler Asset
Management would not buy 10-year bonds. Sometimes there was value in buying something
beyond the 5-year range because those issuers lost a percentage of the market to sell to and
sometimes provided a slightly higher yield to attract investors. Every once in a while, Chandler
Asset Management may pick something up in the 5½, 5¾ or 6-year range but Mr. Oblites
doubted there would be anything beyond 7 years. Before the City engaged Chandler Asset
Management, City’s policy allowed for investments longer than 5 years and the City’s portfolio
allowed securities where allowed by Code (treasuries, agencies, munis, and negotiable CDs).
Mr. Oblites from Chandler Asset Management had not seen a City with a financial operation
that could withstand 10-year cash flows. The City of San Mateo and City of Sunnyvale
recognized the opportunity and wrote their investment policy to 7 years. There were no
compliance requirements on duration. As policymakers, the Council would be involved at the
policy level to meet the goals of the investment program, safeguard the money and make sure
it was there for the objectives and mission identified by the City. The portfolio may shift day to
day, so staff would control it instead of waiting for the next Council meeting or a change to the
policy to address it.
CFO/Director Lai added that the reason for the option of a 10-year duration was the desire to
retain flexibility for staff to be strategic on the City’s portfolio throughout the year.
Councilmember Reckdahl agreed with providing more flexibility when you have a trusted asset
manager, so having some long-term bonds was acceptable particularly because the portfolio
duration target was 2½ years. Regarding General Investment Guideline 3, Councilmember
Reckdahl wanted a clear definition in the policy language for “liquid investments”.
Mr. Oblites from Chandler Asset Management explained that the City’s preexisting section of
the policy had a dollar amount that he thought was $50 million and was updated to “liquid
investments” because a steady dollar figure was not reflective of the investment program
shrinking or growing through returns, revenue collection and debt issuance. Generally, the
investment world considered liquid investments 1 year or shorter. The policy touched on all the
City’s investments, not only the investment portfolio that Chandler Asset Management
managed on the City’s behalf. City staff directly controlled the City’s investments in the Local
Agency Investment Fund (LAIF) and the funds that flowed through the bank. Recently, City staff
set up a money market sweep through the bank to earn more yield.
Assistant Director Paras mentioned that even though a dollar amount was not defined in
General Investment Guideline 3, City staff knew a certain dollar amount needed to be kept
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liquid and continually monitored at an operational level how much to maintain in the City’s
banking account, LAIF and the like.
Assistant City Manager Kiely Nose echoed the definition of liquid investments was the money
sitting in the City’s bank account and LAIF account.
Mr. Oblites from Chandler Asset Management requested the policy be updated to include the
definition of liquid investments as bank accounts, external money funds, LAIF and investments
in the investment portfolio of securities that were 1 year or less.
Before this goes to Council, CFO/Director Lai stated the investment policy would be updated
with the definition of liquid investments based on this conversation.
On Packet Page 15, Councilmember Reckdahl requested the policy include a definition of
“reasonable timeframe” in General Investment Guideline 4. Councilmember Reckdahl did not
like the phrase “as soon as possible” in General Investment Guideline 5 and wanted it replaced
with verbiage that described the intention, such as “Percentage limitations will be restored over
time as investments mature in each category.”
CFO/Director Lai said the City had a managed portfolio and it was not desirable to react to
changes when the market moved a lot, so the reasonable timeframe in General Investment
Guideline 4 referred to a disclosure in the quarterly reports.
Regarding General Investment Guideline 4, Assistant Director Paras noted the current process
was to report it in the quarterly investment activity report. After the pandemic, the value of the
portfolio dipped for 8 straight quarters until it recently came above 95 percent.
Mr. Oblites from Chandler Asset Management noted General Investment Guideline 4 used
legacy language. The ratio of the market value to the book value falling more than 95 percent
meant a delta or difference between book value and market value of more than 5 percent,
which was the unrealized gain/loss of the portfolio. Market forces moved the market value. The
book value shifted every day because of amortizations, premiums and discounts. Most of the
policies that Mr. Oblites from Chandler Asset Management had seen did not include a
requirement similar to Guideline 4 and he had not seen anything more frequent than quarterly
reporting because the volatility was very low. Mr. Oblites thought it was reasonable to notify
the City Council quarterly when the portfolio had lost value beyond the 5 percent threshold.
Staff agreed to replace “reasonable timeframe” with “quarterly” in General Investment
Guideline 4.
Mr. Oblites from Chandler Asset Management explained the policy language for concentration
limits in General Investment Guideline 5 meant the percentage limitations for a particular
category of investment had to be restored. It was not a compliance violation or a violation of
the law. Generally, the concentration percentage was restored with the next purchase;
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however, you want to make a trade because it was advantageous to the City rather than forcing
a purchase to restore the concentration percentage.
Assistant City Manager Nose noted reporting was addressed in the section at the end of the
policy. Instead of staff making adjustments specific to individual items, Assistant City Manager
Nose recommended aligning it with the reporting requirements so any changes that were made
would trigger throughout the policy. Assistant City Manager Nose suggested substituting “as
soon as possible” with “as soon as reasonably possible” in General Investment Guideline 5.
CFO/Director Lai thought the reason for the phrase “as soon as possible” in General Investment
Guideline 5 was a desire to put some urgency into it while making sure it was reasonable
because the ASD staff had a duty to cure any noncompliance. CFO/Director Lai believed
“reasonable” made sense because different objectives were managed within this policy and
keeping it vague provided flexibility.
Councilmember Reckdahl agreed with adding “reasonable” in General Investment Guideline 5.
Councilmember Reckdahl felt that percentage limitations provided protection against a market
crash. Councilmember Reckdahl recalled Orange County went bankrupt due to a rogue trader
making some bets. A rogue trader or an employee mistake was a common way that people get
in trouble, so Councilmember Reckdahl asked if the City had any protection against those
situations or if it needed to be addressed in the policy. Councilmember Reckdahl questioned if 1
person could do a trade without a second set of eyes on that trade, for example, to flag if
someone made a typo and bought 100 times more shares than expected.
Mr. Oblites from Chandler Asset Management clarified the case that Councilmember Reckdahl
referred to was the Orange County Treasurer/Tax Collector, not a rogue trader. Chandler Asset
Management had processes or policies and procedures in place to prevent that. As an example,
the pre-trade compliance process and post-trade compliance review described earlier would
prevent that. The policy was meant to stand alone, whether or not the City used an investment
advisor. As the City’s registered investment advisor, Chandler Asset Management would have
to make the City whole if a trade was made that violated the policy or the law, which provided
some protection. Mr. Oblites from Chandler Asset Management had seen this happen at other
firms and, as the registered investment advisor, it came out of their pocket to make the client
whole.
Assistant City Manager Nose explained that greater liberties were taken in this policy because
of the change from doing it in-house to having a registered investment advisor and a more
robust organization helping provide this professional service.
Councilmember Reckdahl posed the following questions. On Packet Page 17, what were
banker’s acceptance notes and do they need rating requirements? On Packet Page 18, did
commercial paper have rating requirements? On Packet Page 18, to minimize the counterparty
risk of short-term repurchase agreements (REPOs), should the requirements specify the type of
REPOs, type of collateral and a certain rating for primary dealers? Should the policy specify that
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treasuries were desired? On Packet Page 19, what was the liquidity of a JPA and did a certain
credit rating need to be specified? Regarding medium-term corporate bonds at the bottom of
Packet Page 20, Councilmember Reckdahl thought a basket of corporate bonds had a very good
risk-return tradeoff overall because the bonds could be diversified over different industries to
mitigate risks and it provided a return higher than treasury but there was a headline risk. Did
the City want to buy individual corporate bonds when corporate actions, for example,
supporting abortion rights or the mistreatment of workers in another country could cause the
public to urge the City to divest? Was it was legal for the City to buy ETFs? Choosing
corporations that fit certain characteristics such as antipollution carried the danger of being
very tech heavy and less diversified. Did corporate bonds have liquidity requirements?
Assistant Director Paras called attention to Packet Page 18 where it said in (a) (ii) commercial
paper must be in a rating category of A-1 or equivalent but at least 1 NRSRO. A-1 was the
highest S&P rating category. Moody’s highest rating was P-1 and Fitch was F-1.
Mr. Oblites from Chandler Asset Management explained that a banker’s acceptance note was a
trade instrument with a time value, was part of the money markets, was allowed by Code and
should be included in the City’s investment policy. A time value associated with money could be
arbitraged to make money. A retailer goes to their local bank to take out a letter of credit to
purchase merchandise to sell. It had been a long time since Mr. Oblites had seen someone buy
a banker’s acceptance note. The Code did not require rating requirements for banker’s
acceptance notes because the investor could take hold of the merchandise if the borrower
defaulted. Commercial paper had rating requirements.
Mr. Oblites from Chandler Asset Management said the policy described triparty REPOs, which
were over-collateralized under California Government Code, meaning the collateral was valued
at more than what was loaned. The collateral was placed into an escrow account. If the
borrower did not pay you back, the collateral was yours. A repurchase agreement was when a
bank needed short-term financing and the collateral was in treasury or agency bonds that the
issuer sold to you and the issuer repurchased their securities with interest usually the next day.
Generally, a master repurchase agreement was signed with a bank to set up and participate in a
REPO program. REPOs were included in the investment policy in case the City grew big enough
to where it made sense to have REPOs. Local government investment pools (LGIPs) had
repurchase agreements. REPOs were a very important part of the money markets and were
short term, most matured overnight. According to Mr. Oblites’ recollection, the Code specified
the percentage of treasuries as collateral but the City’s policy could specify it.
Assistant City Manager Nose asked Mr. Oblites from Chandler Asset Management to reference
the Code section for collateral in the policy revision.
CFO/Director Lai agreed with referring to the Code section for collateral in the policy revision to
make it easier to maintain when technical updates were performed every year.
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Mr. Oblites from Chandler Asset Management explained the Joint Powers Authority (JPA)
vehicle in California had been primarily used to manage pooled risk. Palo Alto belonged to a
JPA. A JPA was an investment pool that functioned a lot like a Rule 2a-7 money market mutual
fund for local governments. The value of the shares was pegged to $1. In California, there were
4 existing JPAs with the most recent starting about 4 months ago, all AAA rated. To be
competitive in California, a JPA had to have very high credit quality and be AAA rated. The Code
did not have a credit rating requirement for JPAs. To mirror the Code, Mr. Oblites from
Chandler Asset Management recommended not specifying a credit rating requirement for JPAs
in the City’s policy. If desired, this would permit AA-rated JPAs that sponsored a longer-term
pool. Most JPAs in California followed the GASB 79 framework to provide liquidity for
participants. All JPAs in California provided same-day availability up to a certain cutoff time.
JPAs were liquid investments, very highly rated and well run. JPA liquidity depended on the
pool. When buying a longer-term pool, some may have a 1 or 2 day redemption but the most
popular JPAs had a same-day cutoff. Chandler Asset Management ran a JPA called California
Fixed Income Trust (CalFIT) that had same-day availability for your entire account up to an
11:00 cutoff currently but was moving to a 12:00 cutoff by the end of this month.
Mr. Oblites from Chandler Asset Management said the City could buy ETFs because an ETF was
a mutual fund and there was a provision for mutual funds in California; however, ETFs were
limited to securities allowed by California Government Code. The problem with ETFs was not
having the ability to customize those pools or run a credit analysis because you get whatever
the ETF manager bought. It was much more difficult to diversify the portfolio in an index or
generate the value you get with individual investments; therefore, Mr. Oblites from Chandler
Asset Management recommended buying individual bonds to have diversity in the City’s
portfolio and hopefully additional return potential. Mr. Oblites from Chandler Asset
Management had seen activists related to fossil fuels and the war in Gaza as well as activists
going after a particular bank that was perceived to be lending to an industry that somebody did
not like or people who owned index funds that contained a company that they had views
against.
CFO/Director Lai pointed out a section in the policy that spoke to environmental, social and
governance responsibility and addressed the issue of activists. Staff had some flexibility and
would use their judgment.
Referring to Packet Page 21, Authorized Investment 15, asset-backed securities, tranches made
Councilmember Reckdahl nervous. In the Great Recession, tranches did not predict how their
mortgages were going to behave. Councilmember Reckdahl inquired if the tranche for auto
loans was divided by the credit of the persons taking out the loans and what happened when
someone defaulted. Councilmember Reckdahl questioned if Chandler Asset Management
thought they could do enough analysis so that there was minimal risk and whether the top
tranche was generally chosen for repayments.
Mr. Oblites from Chandler Asset Management explained that Authorized Investment 15 on
Packet Page 21 applied to private label mortgages and asset-backed securities but did not apply
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to federal agency mortgages. A mortgage-backed security issued by a federal agency was
considered a federal agency under California Government Code, not a mortgage-backed
security governed by Subparagraph O of California Government Code 53601. Chandler Asset
Management only bought federal agency mortgages, not private label mortgages.
Asset-backed securities referred to a pool of receivables (a pool of debt) such as a credit card
pool or an auto loan pool divided into tranches based on the credit of the persons taking out
the loans. The tranches were in line to receive the repayments. As the debtors in the pool
repaid their debt, the repayments cascade after a certain threshold to the next tranche in line.
The tranches at the top of the line get the repayments first, were much more liquid, had higher
FICO scores and paid a little less yield. The tranches at the bottom of the line were less liquid,
higher risk and paid a higher yield. Part of the analysis was to understand what tranches to buy
and what to avoid, and Mr. Oblites believed Chandler Asset Management could do enough
analysis that there was minimal risk. AA was the minimum credit rating per California Code.
Chandler Asset Management bought only AAA rated deals, the most liquid tranches with the
strongest credits, the top tier that was first in line to receive repayments, and looked for
overcollateralization. Everything Chandler Asset Management bought was senior, which was a
term specific to the credit rating. Chandler Asset Management did not buy subordinated debt.
An example of overcollateralization was $80 million borrowed from a $100 million tranche, so
more debtors were in the pool than there was debt outstanding. Another overcollateralization
was establishing lines of credit to cover a certain amount of modeled defaults in the pool.
Councilmember Reckdahl asked if forward contracts or futures were a prohibited investment. If
the yield curve was steep at 3 years, you could buy a 3-year bond and then buy a forward
contract to sell it in 1 year. Councilmember Reckdahl requested information about mortgage
strips.
Mr. Oblites from Chandler Asset Management stated there was no language to address or
prohibit forward contracts. It was not unreasonable to get into forward contracts when you buy
bond proceeds and forward rate agreements where you basically arbitrage a rate, which was
allowed under Code. Chandler Asset Management did not buy forward contracts, forward rate
agreements or hedge anything like that because it could throw off their risk management
approach and it was not worth it. Investment in interest-only strips was prohibited in
accordance with the California Government Code. Although it was allowed, it had been a long
time since Mr. Oblites from Chandler Asset Management saw investments in principal-only and
interest-only mortgage strips because of the risk.
Councilmember Lythcott-Haims encouraged staff to begin the presentation to the City Council
with a preamble including the reason for the shift to Chandler Asset Management, why this was
the right time, why this move was not done sooner, what was wrong with the way the City had
been doing it and what kind of risk the City was in. Councilmember Lythcott-Haims
recommended updating the staff report where it said “the City and Chandler” to instead refer
to Chandler by its formal name, Chandler Asset Management. To facilitate a greater ease in
accepting the transition, Councilmember Lythcott-Haims suggested providing a link to Chandler
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Asset Management for people who want to gain a better understanding of this organization.
The City was in a budget deficit environment projected out for many years. The shift to
Chandler Asset Management was done in part to protect the City from various risks and to
increase its return, so Councilmember Lythcott-Haims requested a conservative projection of
how this change might impact the City’s conversations around the projected budget deficit
because people were rightly very concerned.
Councilmember Burt recalled a ballpark expectation was mentioned during the discussion at
the last Finance Committee meeting. Councilmember Lythcott-Haims did not remember if it
was 2.7 and now would be 4.1.
MOTION: Councilmember Reckdahl moved, seconded by Councilmember Lythcott-Haims, to
recommend the City Council approve revisions to the City’s Investment Policy (Attachment B)
with the following changes:
• In #3 of the General Investment Guidelines section, define “liquid investments.”
• Edit #4 of the General Investment Guidelines section to read: “Should the ratio of the
market value of the portfolio to the book value of the portfolio fall below 95 percent,
the Administrative Services Department will report this fact to the City Council quarterly
and evaluate whether there is any risk of holding any of the securities to maturity.”
• Edit the final sentence of #5 of the General Investment Guidelines section to read: “As
soon as reasonably possible, percentage limitations will be restored as investments
mature in each category.”
• In #8 of the Authorized Investment section, reference the California Government Code
limits and collateralization requirements.
MOTION PASSED: 3-0
Item 1 Public Comment - None
Future Meetings and Agendas
Lauren Lai, Chief Financial Officer and Administrative Services Department Director, said staff
was working on the tentative agenda items but typically financial forecasts and utility rates
came back in the spring.
Councilmember Burt wondered whether the Committee would have ample time for a midyear
review, even if the staff report was unable to incorporate any feedback prior to the packets
going out. Councilmember Burt noted there was an open Committee request for the number of
employed workers by department going back to pre-COVID.
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CFO/Director Lai acknowledged the request for midyear review at this committee level. Staff
was still working on the midyear. The team had a couple new budget managers. This afternoon,
an ASD staff member and CFO/Director Lai reviewed the number of employed workers by
department back to 2019. The ASD staff member was working on the 2026 employees by
department. CFO/Director Lai had asked to listen to the Council meeting from September.
CFO/Director Lai will review the employee numbers one more time and hoped to include it as
an attachment to the long-range financial forecast being sent this week in Council’s packet for
the meeting scheduled on January 20. If 2026 was not ready to include in this week’s packet,
the attachment would show the number of authorized employees and filled positions by
department from 2019 through 2025.
Councilmember Reckdahl asked when the last presentation occurred.
CFO/Director Lai answered that staff brought it in September but there were some gaps in the
data.
Councilmember Lythcott-Haims realized the Council reorganization would result in committees
getting shuffled. If this was Councilmember Lythcott-Haims’s last Finance meeting, she wanted
to say how much she unexpectedly enjoyed it, she learned a lot and she appreciated having had
the opportunity to be a part of these conversations.
Adjournment: The meeting was adjourned at 7:25 p.m.