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No. 609

SECTION: FINANCES


TITLE: INVESTMENT OF

DISTRICT FUNDS


ADOPTED:
REVISED:


SOUTHEASTERN GREENE

SCHOOL DISTRICT















609. INVESTMENT OF DISTRICT FUNDS


1. Purpose


It shall be the policy of the Board to optimize its return through investment of cash balances in such a way as to minimize noninvested balances and to maximize return on investments.





The primary objectives of investment activities, in priority order, shall be:





Legality - All investments shall be made in accordance with applicable laws of Pennsylvania.





Safety - Safety of principal shall be of highest priority. Preservation of capital in the portfolio of investments shall be ensured through the mitigation of credit risk and interest rate risk.





Liquidity - Investments shall remain sufficiently liquid to meet all operating requirements that are reasonably anticipated. A fiscal year operations anticipated cash flow shall be developed so that investments can be made as early as possible, with maturities concurrent with anticipated cash demands.





Yield - Investments shall be made with the objective of attaining a market- average rate of return throughout the budgetary and economic cycles, taking into account the investment risk constraints and liquidity needs.


2. Authority

SC 440.1, 621, 622, 623




All investments of the school district made by an officer and/or employee of the district shall be made in accordance with this policy and a Board-approved investment program.


3. Definitions


Short-term - any period thirteen (13) months or less.





Long-term - any period exceeding forty-eight (48) months' duration.





Mid-range - any period between short-term and long-term.











Concentration of credit risk - the risk associated with the consolidation of investments in a single pool, institution, or instrument.



Credit risk - the risk of loss of principal due to the failure of the security issue or backer of the issue.
Custodial credit risk - the risk of loss associated with consolidation of investments with a single institution where the district may rely on the institution to hold investments on behalf of the district or through collateral action when the instruments are not in the district name.

Foreign currency risk - the risk associated with investment in foreign currency that is subject to market fluctuation and associated currency conversion.








Interest rate risk - the risk that the market value of securities will fall due to changes in general interest rates.





Investment program - the specifically enumerated and Board-approved investment strategy.


4. Delegation of Responsibility

SC 440.1



The Board shall delegate to a designated individual the responsibility to manage the district's investment program, in accordance with written, Board-approved procedures for operation of the investment program.





After securing the best possible interest rate, the designated individual shall authorize the bank, in writing, to invest for Southeastern Greene School District General Fund and to issue a safe keeping receipt for the amount of the investment. Perpetual investment records shall be maintained on all investments and include the cost and certificate number.





An annual review of the investment program shall be prepared by the designated individual, based upon the anticipated cash flow of all district funds, i.e. general, capital reserve, bond, etc. The investment program shall be submitted to the Board no later than sixty (60) days after adoption of the annual budget.


SC 440.1


The designated individual responsible for investments shall report monthly to the Board the following:





1. Amount of funds invested.





2. Interest earned and received to date.












3. Types and amounts of each investment and the interest rate on each.





4. Names of the institutions where investments are placed.





5. Current market value of the funds invested.
6. Other information required by the Board.





The Board directs the Superintendent to have developed written procedures that will ensure compliance with this policy. Such procedures shall include a disclosure form for designated individuals involved in the investment process and/or required written statements for advisors and bidders.


5. Guidelines

SC 440.1



Investments permitted by this policy are those defined in Section 440.1 of the School Code, as amended, which are collateralized in accordance with applicable laws.



17 CFR 270

All securities shall be purchased in the name of the school district, and custody of the securities shall be specified within the district's investment program.
An exception to purchases in the name of the school district is permitted for the purchase of shares of an investment company that is or conducts business voluntarily in compliance with SEC section 2a7.


SC 440.1


All investment advisors or bidders shall verify in writing that they have received a copy of this policy. Such written statement shall indicate that they have read and understand this policy and all applicable statutes related to school district investments, along with their intent to comply fully with these requirements.





The district shall require all investment advisors/bidders to submit annually any or all of the following, as appropriate:


  1. Audited financial statements.







  1. Proof of National Association of Securities Dealers (NASD) certification.







  1. Proof of state registration.







  1. Provide annually the rating from a recognized rating agency.











































Disclosure


65 P.S.

1101 et seq


Designated officers and employees involved in the district's investment process shall disclose any personal business activity that could conflict with the proper execution and management of the investment program or could impair their ability to make impartial decisions.





Audit





The Board directs that all investment records be subject to annual audit by the district's independent auditors.





The audit shall include but not be limited to independent verification of amounts and records of all transactions, as deemed necessary by the independent auditors.





It shall be the responsibility of the investment advisor and/or bidder to maintain necessary documents to permit independent audit of the district's investments.




53 Pa. C.S.A.

Sec. 8001 et seq

Sec. 8224


Bond Proceeds
Bond proceeds shall be invested in accordance with the Local Government Unit Debt Act and applicable federal and state laws, subject to approval by the solicitor and/or bond counsel and the School Board.





Investment transactions arising from bond proceeds shall be reported monthly to the Board, in accordance with this policy.




Compliance With GAAP





SC 218

GASB Stmt 40

The following is intended to guide district investments as limited by Section 440.1 of the School Code:





  1. District funds shall not be invested in foreign currency and shall not have any related risk that would require disclosure pursuant to GASB Statement 40.







  1. District investments shall limit the exposure to loss of principal due to market changes in interest rates.












  1. District investments in authorized instruments that are not backed by the “full faith and credit” of the federal or state government shall be limited to those with the highest credit rating available for such instruments issued by a recognized organization.


If, after purchase, the rating of any instrument is reduced and is no longer in compliance with this policy, the individual responsible for district investments shall advise the Board at the earliest opportunity of such action and make recommendations for altering investments.




  1. When district funds are invested in any one (1) issuer other than designated depository accounts, the amount of the investment shall be unlimited, but the Board shall be notified of such investment monthly.







  1. For purposes of interest rate disclosure in the annual financial report, the method of determining interest rate risk shall be based on weighted average maturity.








References:





School Code – 24 P.S. Sec. 218, 440.1, 621, 622, 623
Ethics Standards And Financial Disclosure – 65 P.S. 1101 et seq
Title 17, Code of Federal Regulations – 17 CFR 270














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