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4. Maintaining the Public's Trust <br /> All officials and employees who are part of the investment process shall seek to act <br /> responsibly as custodians of the public trust. Investment officials shall avoid any <br /> transaction that might impair public confidence in the municipality's ability to govern <br /> effectively. <br /> Authority to manage the City of Elk River's investment program is derived from Minnesota Statutes <br /> §118A. Management responsibility for the investment program is hereby delegated to the Finance <br /> Director. No person may engage in an investment transaction except as provided under the terms <br /> of this policy and the procedures established by the Finance Director. The Finance Director shall be <br /> responsible for all transactions undertaken and shall establish a system of controls to regulate the <br /> activities of subordinate officials. <br /> Officers and employees involved in the investment process shall refrain from personal business <br /> activity that could conflict with the investment program, or which could reasonably cause others to <br /> question or doubt their ability to make impartial investment decisions. Employees and investment <br /> officials shall disclose to the Finance Director any material financial interests in financial institutions <br /> that conduct business within this jurisdiction, and they shall further disclose any large personal <br /> financial/investment positions that could be related to the performance of the City of Elk River's <br /> portfolio. <br /> The Finance Director will maintain a list of financial institutions authorized to provide investment <br /> services. In addition, a list will be maintained of approved security broker/dealers selected by credit <br /> worthiness,who maintain an office in the State of Minnesota. These may include "primary dealers" <br /> or regional dealers that qualify under Securities &Exchange Commission Rule 15c3-1 (uniform net <br /> capital rule). All brokers doing business with the city shall have a Broker Certification form on file <br /> with the Finance Director in accordance with Minnesota Statutes §118A.04, Subd 9. All investments <br /> must be placed with brokers whose office is in the State of Minnesota. No investments may be <br /> made with out of state brokers. <br /> Investment instruments authorized and permitted by this policy are as follows: <br /> A. Repurchase Agreements <br /> Repurchase agreements consisting of collateral allowable in Section 118A.04. <br /> B. United States Securities <br /> Governmental bonds,notes,bills,mortgages (excluding high-risk mortgage-backed <br /> securities), and other securities,which are direct obligations or are guaranteed or insured <br /> issues of the United States,its agencies,its instrumentalities, or organizations created by an <br /> act of Congress. <br /> High risk mortgage-backed securities are as follows: <br /> 1. interest-only or principal-only mortgage-backed securities;or, <br /> 2. any mortgage derivative security that: <br /> a. has an expected average life greater than ten years; <br /> b. has an expected average life that: <br /> i. will extend by more than four years as the result of an immediate and <br /> sustained parallel shift in the yield curve of plus 300 basis points; or <br /> Financial Management Policies Page 4 <br />