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<br />Approved by Finance Committee-December 18, 2006 . <br />Authorized Financial Institutions. Depositories. and Broker-Dealers <br />The Finance Department shall maintain a list of financial institutions and depositories authorized by the <br />City to provide investment services for the City from those eligible public depositories, as designated by <br />the Banking Board. In addition, The Finance Department shall maintain a list of approvee! security bro- <br />ker/dealers that may include "primary" dealers or regional dealers qualifying under Securities and Ex- <br />change Commission Rule 15C3-1 (uniform net capital rule). To qualify for consideration for investment <br />transactions with the City, all financial institutions and broker-dealers must supply the following, as ap- <br />propriate: <br />. Proof of state registration (except for those firms providing safekeeping and custodial services only) <br />. Audited financial statements demonstrating compliance with state and federal capital adequacy <br /> guidelines <br />. Proof of National Association of Securities Dealers (NASD) certification <br />. Evidence of adequate insurance coverage <br />. Certification of having read and understood and agreeing to comply with the City's investment pol- <br /> icy <br />An annual review of the financial condition and registration of all qualified financial institutions and <br />broker/dealers will be conducted by the investment officer. <br />Safekeepin2 and Custody <br />All trades of marketable securities will: be executed "delivery versus payment" (where applicable) to <br />ensure that securities are deposited in an eligible financial institution prior to the release of funds. <br />Securities will be held by an indepene!l~nt third-party custodian selected by the City as evidenced by <br />safekeeping receipts. The safekeeping institution shall provide on an annual basis a copy of its most <br />recent report on internal controls (Statl~ment of Standards 70). <br />Moreover, the investment officer is responsible for establishing and maintaining an internal control <br />structure designed to ensure that the assets of the City are protected from loss, theft, or misuse. The in- <br />ternal control structure shall be designed to provide reasonable assurance that these objectives are met. <br />The concept of reasonable assurance n~cognizes that (I) the cost of a control should not exceed the bene- <br />fits likely to be derived, and (2) the valuation of costs and benefits requires estimates and judgments by <br />management. The internal controls structure should address the following points: <br />. Control of collusion <br />. Separation of transaction authority from accounting and recordkeeping <br />. Custodial safekeeping <br />. A voidance of physical delivery securities <br />. Written confirmation of transactions for investments and wire transfers <br />. Dual authorization of wire transfers <br />Compliance with these controls shall be reviewed and confirmed through the City's annual independent <br />audit. <br /> 4 <br />