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open market prior to maturity The City will limit investments to a maximum maturity of <br /> five years (unless otherwise authorized by City Council) <br /> Foreign currency risk results from investment in foreign currency-denominated <br /> securities The City will not invest in foreign currency investments <br /> DELEGATION OF AUTHORITY <br /> Authority to manage the City's investment program is derived from Section 53600 et <br /> seq of the Government Code and Chapter 2 16 of the Pleasanton Municipal Code <br /> Management responsibility for the investment program is delegated by the City Council <br /> and City Manager to the Director of Finance The authority to manage some or all of the <br /> City's investment portfolio can be further delegated to outside professional investment <br /> managers (Advisers) at the election and further approval of the City Council at the <br /> recommendation of the City Manager and Director of Finance The Adviser shall be <br /> registered under the Investment Advisers Act of 1940 The Adviser shall follow this <br /> Investment Policy, written internal controls and other written instructions as provided by <br /> the City Such delegation is subject to City review and overriding discretion which will <br /> be exercised as needed <br /> ETHICS AND CONFLICTS OF INTEREST <br /> Officers and employees involved in the investment process shall refrain from personal <br /> business activity that could conflict with proper execution of the investment program, or <br /> which could impair their ability to make impartial investment decisions Employees and <br /> investment officials who manage the investment of public funds must file an annual <br /> Statement of Economic Interests <br /> AUTHORIZED FINANCIAL DEALERS AND INSTITUTIONS <br /> The Director of Finance will maintain a list of financial institutions authorized to provide <br /> investment services In addition, a list will also be maintained of approved security <br /> broker/dealers selected by credit worthiness, these may include "primary" dealers or <br /> regional dealers that qualify under Security & Exchange Commission Rule 15C3-1 <br /> (uniform net capital rule) All broker investment transactions require the approval of <br /> authorized City staff No public deposit shall be made except in a qualified public <br /> depository as established by state laws <br /> All financial institutions and broker/dealers who desire to become qualified bidders for <br /> investment transactions must supply the Director of Finance with the following audited <br /> financial statements, completed broker/dealer questionnaire, and certification of having <br /> read the City's investment policy <br /> 3 <br />