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HomeMy WebLinkAbout0280.094~) J • • ,- May 12, 1994 THE HOIIDRABL& CITY COUNCIL Palo Alto l California Attention: Finance'Committoe Members of "the Council: Report i!LQ):.:ief BUDGET C) ! II.! -95 The city of Palo Alto statement of Investment policy ,Attachment A) requires review by Council annually I as part of thn budget process. Staff is proposing changes to the current policy for the 1994··95 Budget. The current city of Palo Alto Statement of Investment Policy limits the Treasury Hanager to making transfers of no more than $3 million in a day from the City's general account to anyone financial institution. It also Ihdts the: investment authority of tho Tr~asury Division Financial Analyst. In order to increase the effectiveness of the Treasury Division, staff is recommendinq an incr~ase in the Treasury Manager and Treasury Financial Analy~t's trans.fer authorization limit to $5 million and to authorize thG­ Financial Analyst to purchas-=, securities with the same limitations as the Treasury Manager. In addition, under the Specific Investment Strategy section of the Investment Policy, staff recommends illcluding a limit of no more than 10 percent of the portfolio in government agency step-up securities. Background The city of Palo Alto statement of Investment Policy (CNR:563:93) stipulates that, CMR:280:94 i i I i b I I :[ i "' '\< Ulrhe Director of Finc:lnce 01' desi9neo is al..lthori?cd to make all investment transactions allowed by the Statement of Investment Policy. He or she may authorize the Treasury Manager or Financial Analyst to enter into investments within clearly ~peclfied parameters. ''In all circumstances approval from the Director of Finance is required b_efore se.11ing securities tro[T1. the City's pcrrtfolio. Tha: Treasury Manager may also transfer no more than $3 inilJ.ion in a day from the City's (jeneral account to anyone financial institution, without the prior approval of the Director of Finance. ' "The Financial Analyst I!lay transfer up to $1 million between the City's gener«l account, the Local Agency Investment Fund (I.J\If') and any approved mutual fund in any day." Th& second paragraph of this portion of the Investment Policy limits the Treasury Manager to transfers of no more than $3 million in a day from the City's general account to anyone financial institution, without thp-prior approval of the Director of Finance. The last paragraph limits the authority of the Financial Analyst to transfers of $1 mil Lion to LAU' or an approved mutual fund. All other investment decisions must be made by the Treasury Manager. F.2rt(oliQ Size The size of the portfolio has increased from $120 million in May 199:t, to $170 million in April 1994. The increase has reSUlted in large amounts of money (over $3 million) maturing, or accumulating _in a short period of' time. consequently, many of the City's investments are over the $3 million limitation. Many times, this results in staff having to invest over a t\li'o-to-three day period. spreadIng the investment over several days increases the cost of securities purchased. Often, cost increases are as much as $313 per nillion tor each extra day, because the brokers want to protect themselves froUt financial movements in the -market. In addition, spreading the investments increases the effort involved in administ.t"ation of the invest.ment "process. There is the need to move invested funds to overnight money market accounts temporarily, to avoid having lat'ge balances in the city's bank account, thereby losing interest-earning opportunities. Thi5 requires additional paperwork to document each transaction, the need to make additional wire transfers, and the need to reconcile additional securities. To ensure the City does not incur excess cost as a result of investing over several days and to minimize the administrative effort involved in each investment transaction, staff recommends council increase the transfer limit to $5 million. CMR:280:94 L \ I ., ( ," '" ~ .. \ ,,~!'J?;':~F . ;~': • .:'~'·:t·; ':'~:&'u~-;i;.:".: ;-::. :~, ?;io::, s;u:gan!uli.2.nJ .. L~.!1.Mi.u Durin9 the Uughes, Heiss organizational Revie~ ... , the position responsibilities 1n the 'l'reasury Division were (lvaluated. Althouqh the Financo Depat"trnoht has not finalized any associated or9~n12at1onal chan9~sf it became apparent that some immediate changes could ba DAde to position responsibilities to improve the operation of ths Tre~sury Division. The Treasury Division financial Analyst is currently responsible for the analysis of investment instruments, including the review of tho finfiinoial stnbiUty of sacurities. The Financial Analyst is also tespon$lblc (or obtaIning quotes and neqotiatinq rates with tinanoial institutions and broK.ers on investmont instl·u~.ents. The Financial Analyst, however, does not have the authority to purchase securities ~s~d on his or her knowledge of the associated ..£nvest~ant: instruments and the rates negotiated. The Financial 1\n.tlilyst nust review the quotes wLth tho Treasury Manager, who is then al.lthoriz.ed to purchase the security. Staff believes that this pr(}Cess could be inproved bj+ allowing the Financial Analyst the authority to obtain quotes, negotiat,e rates, and purchase securltic$, in accordan-ce with the Investment Pollcy parameters. All invostM.onts nade by the Fill2l;ncial Analyst .... ·ill be reviewed by the Assi$tant FinAnce DiL"ector to :r:1oni tor cOlilpliance with the City's rnvost~ent Policy. T.ha current Investment. policy lit1lits callable agency securities to no more than 10 perc,.mt of the portfolio. Callable securities are defined 88 fi~ed intel'cot rate government agency secIJrities that qivQ \::he issuing ;;H}flOcy tho option of returning the invested funds at a spocific point in ti~Q. In early 1994, multi stop-up securities were introduced to investors.. These are qoveri\lltent agency securities wl,ere interest rates increase (listep-upil at pre-set intervals) either semi­ annually or annually. These seclIl'ities have a cal.1able feature that allows the issuing age.ncy to return t.he invested funds a·t each pre-set interval, "but beoau·se they also have built-in rate increases, they do not follow the traditional definition of callable securities. III order to recognize this new investment instrui":'Ient introduced into the marketplace, staff recommends the addition of a R?:parate limitation in the Investment Policy of no more th"n 10 percent of the portfolio for investment in multi step­ ups. C~IR: 280: 94 3 ..., : , <, IPPlot ot Hodityin~~ The increase in transfer lImitations to $5 million will not change the city'. investmont strategies or practices, It will sbply facilitate the investment of larger-ataounts of :monay, needed m01'e frequently} due to the increased si~e of t.he portfolio. In addition, the reconmended n'.cdif1catioll to the, authorlty of the Treasury }'.inancial lHHlIlyst will allow both the Troasury Jianagar and the Financial Analyst to enter into inv<tstnents, in accordanco wlth policy paramet~rs, This will Increase flexibility in tho Treasury oivision, and eliminate, duplicAte efforte bet .... een the Treasury Manager and the Financial lmC11yst. This 1Il.e>d1tlcation wl11 not chango the safeguards containaQ In the Investment Policy to ensure tho safety and liquidity of inYsAtnent&. AU cont.rols cur-r&ntly in place regarding the Treasury. Hana91!H' would also .opply to tho Financial Analystl including the review by tho Accountinq Division of ,all investMent transactions. The limitation of no More than 10 percent of the port.tolio in ::'Iulti step-up government agency securiti.es ""ill help to ensure that the Investment policy suppot'ts divorsifi(:lIt.lo~l of tho Cit.y's portfolio and, at the salno ti~e, protects the portfolio fron intorest i'ate movements. staff recommends that COUncil approve the statc~ent of ,Investnont Policy, which will incroase the ,transfer authorization lil':lit of the Treasury Manager and Treasury t~lnancial lmal)!st to no more than $5 Million in a day frol!l the City's general accQunt to tiny one financial institution. staft also recommends removing the paragr(\ph limiting th~ invostFU(lnt authority of t.ho Financial Analyst, as shown on pago 2 of Atta,chroent-A. and tho nddition of a limit of no more than 10 percent of the por-tfoiio in Huiti step-up gove:rnttlent agency s~curities. Respectfully submitted, ,~~ -(Q C "-V"<-q; J MELiSSA CAVALLO Assistant Finance Dire'ctor C)!R'280:94 "<,\,: 4 At.tachment A: City of Palo Alto Statement of Investment Policy Related Staff Reports; CMR;563:93 CMR:280:94 5 ·.j , 'J ~ • ',,-<. ,,' ", ... ,,,.~" .. 'j,'. ",,",,;_ •. , __ "''''.;'~'''''....;,.'+''"''.~~~i:": AnACHMENT A CITY OF PAr.o ALTO statement of Investment Policy A$ a charter city, Palo Alto oporates its pooled idle cash investments under the prudent investor rule and in conformance with california law. Investments are made with" the judgement and care, under the. circumstances then prevailing, which investors with prudence, discretion, and intelliqence' would make considerinq the safety of their"capital as well as probable income. This affords the City a broad spectrum of investment opportunities, 50 long as the investment is deemed prudent and is allowable unde~ current legislation of the state of California and the charter. of the City of Palo Alto. Palo Alto strives to maintain the level of investment of all idle funds as near 100 percent as possible, through daily and projected cash flow determinations. Investments are made so that maturities match or precede cash nneds of the city. PHILOSOPHY The basic premise underlying Palo Alto's investment philosophy is to insure that SUfficient money is always available to meet current expenditures. The city is able to take advantage of the relatively large reserve balances maintained by its utilities, Which. allow it to take advantage of the general tendency of the market to provide a higher return for longer-term investTllents ,known as liquidity preference) • up to 20 percent of the portfolio may be in investments maturing in more than five years. Consequently, in the long run, the City shOUld average a higher total return tharl most cities without such reserves to invest. ~he economy, the money n'larkets, and various financial institutions (such as t~e Federal Reserve System) are monitored carefully to assess the probable course of interest rates. In a market with increasing interest rates, the City will tend to invest new cash in securities with t'elativety shQrter maturities. This will allo ..... the funds to be available for other investments when the interest rates are higher. 1 , ,.': "-.:"~. , .' ~".' \-» :.';;' ., MmJ.2lUZ.EQ INVESTMENT PERSOJjl!£1 Idle cash management and .l.nvestment transactions are the responsibility of the Finance Department. The Departnent of Finance is und~r the control of the DIrector of Finance, ~ho is accountable to the city Manager. The department is CO~po8Qd of tha divisions of Administration, Accounting, Treasury, BU,dgot, Purchasing, and Real Estate, as set forth in sections 2.00.130 through 2.08~190 of the Palo Alto Municipal Code. The Treasury Division is under the supervision of 8 Treasury Hanaqar, .... ho is accountable to the Director of Finance. The dL1ties ot the Treasury Manager include managing the city's portfolio of treasury investments, remaining accountable for the city's treasury balance, developing and monitoring the city's cash flow model and doveloping long-term revenue and financing strategies and forecasts. A Financial An~lyst reports to the T.t>casury Manager. The Financial Annlyst assists the Treasury Manager in the purchase and sale of aecut'lties. The Financial Analyst also prepares the monthly report, and dai ly records all illvestment transactions as to the type of investment, amount, yield! and maturity. Cash flow projections are prepared as needed. 'i'h~ Director of Finance or desig.)ee is authoriz.ed to make all investment transactions allowed by the Statement of Investment Policy. He or she may authorize the Treasury Manager or Financial .1malyst to enter into investments within clearly specifie.d paral!'letars. In all circul'llstances approval from the Director of l,'inance is required before sellin9 securities from the City's portfolio. The Tre.asury M"nagor may also transfer no more than $3 million in a da'y fro~ the City's general account to anyone financial institution, without the prior ~pproval of the Director of Finance. The Financial Analyst may transfer up to $1 million between the C.lty/s general account, the Local Agency Investment Fund {LAIF) ana any approved l1mtual .fund in any day. No other person has authority to make investment transactions without the written authority of the Finance Director. 2 1. " <'l \ ',;' ; , . . , .. !, n:~JJl.\1£lffi!llli'f Investments are linited to tho follo~ing media, 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Securities of the u.s. GoYornment, or its aq:oncies Certific.tes ot Deposit (oi' tb,,, Deposits) (CD) Negotiable certificat •• of Uoposit (NCO) Banker's Accept~nce Notes (SAl Comnercial Pap~r Local Agenoy Inv.stRent FUnd (LAIF) Short-tcr~ Repurchase Agree=ents (REPO) City of Palo Alto Pond. ~oney Market Accounts; And .Mutual t-Uhds IIhich arc 1 hoitQd essentiBlly to the abovt! investae:ntG end "fur the': dotined in note 9 of Appendix A. ~ppondlx A prQv!des a ~ore dotailed description of each investment vehicle and its security and liquidity features. Most of the city's short .. tern Invcstcents \lill bo in securities which pay principal upon 1~a.tUl·itYI lo:hile long-tern investments :rnay be in securities which periodically rep"y principal as ,"'al} as interest. Most of the Cily's invostnents will be at a fixed rate. However, SQme o£ tho. investr'JGnts: 1!lt'lY be at B v.lriable rate. criteria for solecting investments are (1n order of importance): 1. Safoty I 2. Liquidity. and 3. Yield. ~eof 8r9kers.~~~eX~ ThQ Financ& Departeent maintains a list of acceptable brokers and daalera. Any brokor or dealer l'\ust have at least three years experienca operatinq with California Runicipa}ities, maintain an inventory of trading. secur1ties of at loast $10 million, and be approved by the finance Director boforo baing added to the City's list-of opprove"d bro)o;;ers and dealers. A broker or dealer will be removed froJl the list should there develop -d history of problems, (i.e., fail to' doliver securities as pro~iscd, failure to honot transactions as quoted, or failure to provide reasonable information) . 3 "", ' ~iew Bnd Rep~ting on Investne~ Monthly, the Finance Department will revle~ perfor~a~ce in relation to the Council-adopted policy. Monthly, the Depart.ont will ropo"t to the Council t in a manner approved by the Coullci 1, its performance-in relation to this policy und fJxplain any devlati.on from the policy and reco-mmend<:ltions for chzJnges, if 8ny~ Thu Council will revi.", this policy annually as part of the Budgot Process. All changes in policy i'I'Iust be approved by the Council prior to implernontation. Depending upon the City's financIal situation and condItions in thCl money markets l the investment strate9Y vill change t~ achieve the" appropriate balance of safety, liquidity and yield~ Safety olio mora than 10 percent of the portfolio in collatora­ lized CDs of any institution. -An institution Jllust be ft'derally insured; and -Have been in operation tor at least three ye~rs, ~ith positive earnings fOl" at least three of the past four quarters of operatioh; and -Report equity in exeC-S5 of 3 pGrcent or assets; and Report scheduled items not in excess of 1.5 porcont of assets. o No more than 30 percent of tho portfolio In neqotiable CDs, No more than $2 ltdl~J-=-l1 'With anyone ins.titution. -No negotiable CDs/with tllaturities heyond 90 days. -An institution"must meet the sa-me safety teste as collateralized CDs. o No more than 30% of the portfolio in Banker'S Acceptance Notes. No more than $5 million with anyone institution. o No more than 15 percent of the portfo] io in COlf,mercial Paper. No more than $3 million 'With anyone institution. 4 , \ I 11 11 o Limit investments exclusively to those stipulated under typas of investments (specifically, there will be no investments involving Reverse Purchase Agreements) . o No new Farm credit securities. o No more than 2 percent of the portfolio 1n the Guaranteed Portion of Small Blloiness Administration Notes. o No more than 15 percent of pot'tfolio in Mutual Funds. o No more tha.n 10 pe'rcent of portfolio in callable agency securities. Liqyidity Any investment must be eval~'>ated on its market-rate and illterest rate risk. If the security must be liquidated, it may have a s~all market and need to be sold at a loss, and if i.ntercst rates increasft J tha value of an investment may go do ..... n. The maJ':'kct rate risk is very low for U.S. agencies and BAs since there is an active market in these securities. It is more difficult to find a purchaser of NCDs or commercial paper, and most COs cannot be liquidated without a substantial loss of interest. Usually, the longer term the investment the larger degree of interest rate risk. If interest rates increase, it is likely that the long-term investments would de.crease in value. This is primarily a factor for securities which have maturities itl e>.:cess of two years, Since almost all of the investments held by the City of Palo Alto with maturities in excess of two years are U.S. government securities, it is possible to maintain fairly accurate records on the market value of these secuJ:"ities and show the market value and potential loss to interest rate risk. This risk Is a part of all long-term investment portfolios and does not become an important factor unless there is a need for the cash, and the loss (if any) must be realized. The followinq are' liquidity constraints: . c Liquidity Elnough to ,meet one month's cash needs. o o o At .least $5'0 million maturing in less than 2 years. No more than 20 percent of the portfolio shall be in investments maturing in more than five years. Any security purchased with a maturity greater than 10 years may pay principal as well as interest on a periodic hasis. 5 , . '-, . o Market value of the portfolio will exceed 95 percent' of the cost basis of the portfolio.' Should the ratio fall below 95" percent the Finance Department will restrict future lnvest[!1ents to those maturing in one year or less and/or-liquidate securities 8S deemed flnancially prudent until the ratio is achieved. o Commitments to purchase new securities shall be made no bore than three (3) working days before pricing. Yield, which ,is def.ined as the return on an investment, will be the third criteria for investments, after safety and liquidity. Whenever possible I the City will obtain three or more bids on the purchase or sale of securities and t~ke the higher yield on purchase or higher price on sale. This rule will not apply to new issues which are purchased at market no :more than three (3) working days before pricing, IAIF J City of Palo Alto bondS, money market accounts or mutual f\mds, which shall be evaluated separately. Adopted by city Council October 221 1984. Monthly reporting effective January 1985. Amen.ded and Adopted by City Conncil June 24, 1985. Amended by City Council December 2, 1985. Amended by City Council June 23, 1986. Amended by city Council June 22, 1987. Amended by city Council August 8, 19S8 A~end~d by City Council November 28 1 1988. Amended by City Council June 26, 1989. Amended by City Council May 14, 1990. Amended by City Council June 24, 1991. Amended by City Council June 22, 1992. Amended by 'City Council June 23, 1993. Amended by Cit}'" Coulleil !~ovember 1&, 1993. 6 APPENDIX A I1XPLMIII'l'ION OF JlLLOflJl8LE IIIVES'l'HENTS y,s Coyernme0t.......A9.e..nQy securities. U. s. Govfll'nment Agency ObligatiQns inolude the se.curities of the Federal National Mortgage As~oc1.tio" (FilM), Federal Land Banks (FLB) , Federal Interaediate Credit Banks (FICB), aemks for cooperatives, F~deral' Home l.,Q,z!In Banke-(FHLB), Government National Mortgaqe Association (GN"MJ;.), Federal Home Loan Mortgage corporation (FIIUle), St"dent wan Market.ing Associ"tion (SLMJ\). small Businoss Administration (SUA) Hnd Tennessee Valley Authority (TVA). federal Agency securities are debt obligations th~t essentially result frQ:r.I lending programs of the Government. federal agency securities differ from other types of secul."ities DB woll as 81'1100q themselves. Their characteristics dep~nd on the i6suin9 agency. It is possible to dtstinguish three typos of issues: (A) participntion certificates (pooled G8cur-ltl(9), (8) Certificate of Interest (pooled loans), (e) notes, bonds, and debentures. The securities of a few agencies are explicitly hacked by the full faith and credit of the u.s. Covernment. All issues, however, have dcfacto bl'lcldrHl fr.on the fedoral government, and it is highly unlikely that tho gov~rnment would let any agency default on its obl1q.!'otions. ~J:.t11j~~.t.~~ Deposit ..... A certificate of Deposit (CD) is a receipt tor funds deposited in a bank, savings bank, or sayings and loan association for a specified period of time at a specified rate of irlt~rest. Denominations are $100,000 and up. 'l'he -fit'st $100,000 of a Certificate of Deposit is quaranteed by tlH~ Federal Oepos! t lnsurance corporatlon (FDIC) if the deposit is with a bank or savings banxJ or the Savings Association JnsUl"anCe Fund (SAIF) if the deposit is with a sbvJnqs and loan. COs with a face value in excess of $100,000 can be collaterali2cd by U.S. GOVernment Agency and Treasury Department securities or first mortgage loans. Government securities lIIuat be at least 110 percont of the face value of the CD collaterali2ed in e~cess of the first $100,000. The value, 'of first, mortgages must be at least 150 percent of the face v.esluo of the CD b.:lliance insured 1<1 excess of the first $100 /000. Generally, COs are issued for l'Ilore than 30 days and the maturity can be selected by the purchaser., :I. HQgQ.tiable CertiLt~il~.....QJ __ ~osit. Negotiable Certificates of Deposit (l~COs) are-usually supported only by the strength of the issuing_institution, but can be sold at any time and thus provide liquidity. 4. !}~.LS' l\cc@.1.a~~" A Banker's Acceptance is a negotiable time draft or bill of exchange drawn on and accepted by a col':'tr.1.crcial bank. Acceptance of the draft irrevocably obligates the bank to pay the bearer the face amount of the draft at l1latui'ity. BAs are usually created to finance the L , , ~ 5, 6. , ' ill1port and export of goOds, the shiplllont of goods ""J.thin the United States and stOt'iHJO of xondily ;aarketablo staple commodities. In ovar 70 yearo of usago in the United states, thcr.o has beon no known .l.nst-ance of principal loss to any investor in BAs. In addition to the qUf\rantec by the accepting hank t the transactiotl is identified with • sp~cific comroodity. Warehouse recoipts verify that the plodged conmQditios ~xist, and, by definitlon, thesQ cOF\modlt ies are l'eadl1y I':u~t''''otablc. The sale of the undorlying goods generates the nocessllt'y fUnds to liquidate the indebt'edne.". B~s enjoy ... rl<etabll1ty since ther"der.l lle~erv. Bonk 1s authorized to buy and sell primo BAs with ~aturltle9 of up to nine months. The Federal Ros~rve Bank enters into repurchase agreeMents in tho nor-Qa} course of open E:ar)c,et operolltions 1.'ith B,' dealers. BAs are Gold at-a discount ft'()!l par. "n acceptance is tied to a specific loan tl'ansaction; therefore, the et':ount and maturity of the Dccept~nco is fixed . . (QlNriQ!·.G.j.J!LJ?_~.I:l. COThme);'cial pdpcr notes are unsecured promissory notes of industrial corporations, utilities, and bank holding cornpanie5. II)tcrest is' discounted fL.'"Ol"l par and calculated using actuel nunber of days 0)) a 3,60-day year. 'i'he­ notes are in bearer for", with rnatur ities [rol'!l one to 210 dayp selected by the purchasor, and denominations generally start at '$100,000. Thore is a small secondary filnrkot for commercial paper notes and'an investor may s~ll 3 note prior to maturity. Commercial paper notes are backed by unused linos oC credit from lllajor banks. So=.e issuer/::;. notes are insured while Game are backed by irrevocable lotte):s ot credit from r:;ajor banks. state law limits a City to in'lcstcl!nts in United statea corporations having assets in e~c~ss of five hundred million dollars 'With an ",VI or higooX'" ratinq for the iSSUQ~'6 debentures. Cities may riot in ..... est lnore than 30 pe:rcent of idle cash in commercial papor. Local Mency InyeGt.a!Ult....rYlliL~~_M Deposit. The Local Agency Investment Fund (LAIY) was established by the state to enable treasurers to place funds in a pool for invest~ents. The City .i.s limited to an investnent of the amount allowed by LAIF (currently $15 million). LAIr has been parttcularly beneficial to those jurisdictions ~ith s~all portfolios. Palo Alto uses this fund for short~term investment, liquidity, and yield. 7. R~...!lEJli!~~_~_g!:~_~~ A "Repurchase l\g;a:"{H_~t:te"t (RRPOS) is not a secut"ity, but a contractual .. ·H:·rangemcnt be-tween a financial 2 . \, , , ,"-,-... , .' -. ..",::.." ~--:,.. ::.;:;~"'---. .. , institution or dealer and an investor. The dqreemant nor~ally can run for one or more days. The investor puts up funds tor a certain number of days at a stated yield.' In return the Investor takes title to a given block of securl ties as collateral. At maturity tha securities are repurchased and the ,funds repaid plus interest. Usually, amounts are $500,000 or more, but soma repurchase agreements can be smaller. B. Mone.y Mnxket ACC9U.nlli. Money Market nepos it Accounts are market-sensitive bank accounts, which are available to depositors at any time without penalty. The interest rate is generally comparable to ra,tes on Rloney market lIutual funds, . though any individual b~nk'B rate lIIay be higher or lower. These accounts are insured by the Federal Deposit Insurance Corporation or the Savings Association Inouranca Fund. 9. Mutual Fu~ Mutual Funds are shares of beneficial interest issued by dive"rsified management companies, as defined by section 23701 M of the Revenue and Taxation Code.' To, bo eligible for investmeni:, these funds must: a. Attain the highest ranking in the highest letter and numerical rating provided by not l(!ss than two of the three largest nationally recognized rating services; Ol" b~ Have an investment. adviaor registered with the securities and Exchange Commission with not less than fiYe years experience investing in the securities and obliqations as autnorized by subdi.visions {a) to (m) r inclusive, of Section 5:1601 of the California Government Code, .and '.11th assets under management i-."I excess of live Ilundred ~illion dollars; and c. Invest solely in those securiti~s and obligatiollS authorized by Sections 53601 and 53635 of the California Government code. Where the Investment Policy of t.ho City of Palo Alto may be more restrictive than the Stc'\te Code, the 'policy authorizes investments in 'mutual funds 'Which shall have minimal investment in securities otherwisQ restricted by the City's policy. Minimal invc-stJ!1ent is defined as 1$88 than 5 perc(lnt of the mutual fund portfolio; and d. The pur-chase price of shares of beneficial interest purchased shall not include any cOrn7llission that these companies may charge. TII:EAS/IIiV(ST)I£1rj J: 1 "I'iI'Ot93. ~ 1-03-94 .. , , ," 3 .. f , J' .,. , . \ \ '. , .'~ \' . .1