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<br />cash flow requirements. Unless matched with a specific cash flow, the City will not <br />directly invest in securities maturing more than ten (10) years from the date of <br />purchase. Average life will be used as the maturity for mortgage-backed securities <br />and the intergovernmental pool investments. <br /> <br />Because of inherent difficulties in accurately forecasting cash flow requirements, a <br />portion of the portfolio should be continuously invested in readily available funds such <br />as Local Government Investment Pools, or money market funds to ensure that <br />appropriate liquidity is maintained to meet ongoing obligations. <br /> <br />VII. SAFEKEEPING AND CUSTODY <br /> <br />A. Authorized Investment Institutions and Dealers <br /> <br />The City shall only purchase investments from the State Board of Administration, <br />Florida Municipal Investment Trust, financial institutions which are qualified as public <br />depositories by the Treasurer of the State of Florida, primary security dealers (or their <br />agents) as designated by the Federal Reserve Bank of New York, or by secondary <br />securities dealers (or their agents) who act as investment banking arms of local <br />qualified banking institutions. <br /> <br />B. Delivery vs. Payment <br /> <br />All trades where applicable will be executed by delivery versus payment ("DVP") to <br />ensure that securities are deposited in an eligible financial institution prior to the <br />release of funds. Securities will be held by a third-party custodian as evidenced by <br />safekeeping receipts. <br /> <br />C. Bid Requirements <br /> <br />Investments will be chosen based on liquidity needs and market conditions. The <br />investments will be competitively bid when feasible and appropriate. Except as <br />required by law, the bid deemed to be the most responsive to the needs of the City <br />must be selected. <br /> <br />D. Internal Controls <br /> <br />The Finance Director is responsible for establishing and maintaining an internal <br />control structure designed to ensure that the assets of the City are protected from <br />loss, theft or misuse. The internal control structure shall 'be designed to provide <br />reasonable assurance that these objectives are met. The concept of reasonable <br />assurance recognizes that the cost of a control should not exceed the benefits likely <br />to be derived and the valuation of costs and benefits requires estimates and <br />judgments by management. <br /> <br />Accordingly, the Finance Director shall establish a process for an annual <br />independent review as part of the annual financial audit to assure compliance with <br />the policies and procedures. The internal controls shall address the following points: <br /> <br />1. Control of collusion - Collusion is a situation where two (2) or more employees are <br /> <br />7 <br />