Item 8BAGENDA ITEM # 8B
JANUARY 25, 2010
CITY OF ATLANTIC BEACH
CITY COMMISSION MEETING
STAFF REPORT
AGENDA ITEM: Review of the City of Atlantic Beach Investment Policy
SUBMITTED BY: Nelson Van Liere, Finance Director
DATE: January 13, 2010
BACKGROUND: In 1995, the then newly created Florida Statute 218.415 required cities to
adopt an investment policy. The City Commission passed an ordinance amending the
code to require the City of Atlantic Beach to adopt an investment policy. At the next
meeting; the City adopted its first investment policy by resolution. In 2006, the policy
was altered to improve some of the sections and bring them up to date. These changes
were not done with a resolution, but were approved by the commission.
On January 11, 2010, Resolution 10-01 to establish an account with the Florida
Municipal Trust, a Local Government Investment Pool, was deferred pending further
revisions to the investment policy to restrict the percentage of the City's funds to be
invested in the Trust.
Below are two sections of the Florida Statutes addressing this issue:
218.415 Local government investment policies
(7) PORTFOLIO COMPOSITION.--The investment policy shall establish
guidelines for investments and limits on security issues, issuers, and maturities.
Such guidelines shall be commensurate with the nature and size of the public funds
within the custody of the unit of local government.
(8) RISK AND DIVERSIFICATION.--The investment policy shall provide
for appropriate diversification of the investment portfolio. Investments held should
be diversified to the extent practicable to control the risk of loss resulting from
overconcentration of assets in a specific maturity, issuer, instrument, dealer, or
bank through which financial instruments are bought and sold. Diversification
strategies within the established guidelines shall be reviewed and revised
periodically, as deemed necessary by the appropriate management staff.
The City's current policy states that we must diversify the portfolio, but provides no
restrictions on portfolio composition and diversification as stated above.
Therefore, it is staff's recommendation that the City revise the current investment policy
to address portfolio composition and diversification provisions. As an example of how
this may be achieved, I have attached the Authorized Investment and Portfolio
Composition portion of the City of Melbourne's policy for your review.
RECOMMENDATION: That the City Commission directs staff to rewrite the City's
Investment Policy making revisions to include guidelines on
AGENDA ITEM # 8B
JANUARY 25, 2010
portfolio composition and diversification. These revisions are to
be proposed in a resolution amending the current investment policy
and will incorporate all other changes since the last resolution.
ATTACHMENTS: Atlantic Beach Investment Policy
Section XII of the City of Melbourne Investment Policy
REVIEWED BY CITY MANAG
AGENDA ITEM # 8B
JANUARY 25, 2010
CITY ATLANTIC BEACH, FLORIDA
INVESTMENT POLICY
May 2006
AGENDA ITEM # 8B
JANUARY 25, 2010
City of Atlantic Beach, Florida
Investment Policy
I. Sco e
This Investment policy applies to all fmancial assets, other than pension fund assets held by the City of
Atlantic Beach (City) or for the benefit of the City by a third party custodian and/or money manager.
This policy does not apply to the uninvested funds of the City, for example, demand deposit accounts and cash
on hand, or to the assets of municipal trusts for which separate Investment Policies are adopted, or certain
other non-City funds in the custody of the Finance Director.
The purpose of this policy is to set forth the policy and objectives governing the internal and external
investment management of the City's cash reserves. The City recognizes that liquidity needs must be met and
have established cash flow projections for the debt service fund, capital project funds and general operating
funds.
II. Investment Objectives
The investment objectives for the City's cash reserves are to ensure the safety and preservation of investment
principal, provide for liquidity, and maximize the return on investment (yield) while controlling risk through
diversification. The City's investment portfolio shall be managed in a manner to attain a market rate of return
throughout budgetary and economic cycles while preserving and protecting capital in the overall portfolio.
The Finance Director will set procedures to control risks and diversify investments regarding specific security
types, maturities and financial institutions.
III. Delegation of Authority
The Finance Director is responsible for investment decisions and activities, under the direction of the City
Manager. The Finance Director shall develop and maintain written administrative procedures for the operation
of the investment program, consistent with these policies.
IV. Investment Performance and Reporting
A portfolio report shall be provided monthly to the City Manager and the City Commission. This report shall
include a breakdown of the portfolio, as well as the performance during the period.
V. Prudence and Ethical Standards
The City shall adopt the Prudent Person Rule, which states that: "Investments shall be made with judgment
and care, under circumstances then prevailing, which persons of prudence, discretion, and intelligence exercise
in the management of their own affairs, not for speculation, but for investment, considering the probable safety
of their capital as well as the probable income to be derived from the investment."
VI. Authorized Instruments
The Finance Director shall purchase or sell investment securities at prevailing market rates. Authorized
instruments are as follows:
A. The Florida Local Government Surplus Funds Trust Fund (SBA):
B. Negotiable direct obligations, or obligations the principal and interest of which are unconditionally
guaranteed by the United States Government. Such securities will include, but not be limited to, the
following:
AGENDA ITEM # 8B
JANUARY 25, 2010
1. Treasury Securities -State Government Series (SLGS)
2. Treasury Bills
3. Treasury Notes
4. Treasury Bonds
5. Treasury Strips
C. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by United States agencies,
provided such obligations are backed by the full faith and credit of the United States Government. Such
securities will include, but not be limited to, the following:
1. United States Export-Import Bank
(Direct obligations or fully guaranteed certificates of beneficial ownership)
2. Farmers Home Administration
(Certificates of beneficial ownership)
3. Federal Financing Bank
(Discount notes, notes and bonds)
4. Federal Housing Administration Debentures
5. General Services Administration Participation Certificates
6. Government National Mortgage Association
(GNMA)
(GNMA-guaranteed mortgage-backed bonds)
(GNMA-guaranteed pass-through obligations)
6. United States Maritime Administration Guaranteed Title XI Financing
7. New Communities Debentures
(United States Government guaranteed debentures)
8. United States Public Housing Notes and Bonds
(United States Government guaranteed public housing notes and bonds)
l O.United States Department of Housing and Urban Development (Project notes and local authority
bonds)
D. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by the United States
Government agencies (Federal Instrumentalities) which are nonfull faith and credit agencies limited to the
following:
1. Federal Farm Credit Bank (FFCB)
2. Federal Home Loan Bank or its district banks (FHLB)
3. Federal National Mortgage Association (FNMA)
4. Federal Home Loan Mortgage Association (FHLMA)([Freddie Macs] including Federal Home
Loan Mortgage Corporation participation certificates)
E. Nonnegotiable interest bearing time certificates of deposit or savings accounts in banks or savings
associations organized under the laws of this state and/or in national banks or savings associations
organized under the laws of the United States and that any such deposits are secured by the Florida
Security of Public Deposits Act, Chapter 280, Florida Statutes, and provided that the bank or savings
association is not listed with any recognized credit watch information service.
F. Repurchase agreements comprised of only those investments as authorized in Sections B, C and D.
G. Bankers' Acceptances which are inventory-based and issued by a domestic bank which has an unsecured,
uninsured and unguaranteed obligation rating of at least "Prime-1" and "A" by Moody's Investor Service
and "A-1" and "A" by Standard and Poor's Corporation and ranked in the top fifty (50) United States
banks in terms of total assets by the American Banker's yearly report.
H. Commercial Paper rated, at the time of purchase, "Prime-1" by Moody's and "A-1" by Standard & Poor's
(prime commercial paper).
AGENDA ITEM # 8B
JANUARY 25, 2010
I. State and/or local government taxable and/or tax-exempt debt, General Obligation and/or Revenue Bonds
rated at least "Aa" by Moody's and "AA" by Standard & Poor's for long-term debt, or rated at least "MIG-
2" by Moody's and "SP-2" by Standard & Poor's for short-term debt.
J. Government fixed income mutual funds as defined by the SEC; which primarily invest in instruments as
authorized in Sections B, C, D, I, and H.
VII. Investment Maturity
To the extent possible, an attempt will be made to match investment maturities with known cash needs and
anticipated cash flow requirements. Investments of current operating funds shall have maturities of no longer
than eighteen (18) months. Investments of bond reserves, construction funds, and other non-operating funds
shall have a term appropriate to the need for funds and in accordance with debt covenants, but in no event
shall exceed ten (10) years.
VIII. Risk and Diversification
Assets held should be diversified to control the risk of loss resulting from over investing in specific
instruments, individual financial institutions or maturities. Diversification strategies within the established
guidelines shall be reviewed and revised periodically, as necessary, by the appropriate management staff.
IX. Authorized Investment Institutions and Dealers
The Finance Director shall only purchase securities from financial institutions which are qualified as public
depositories of the State of Florida as identified by the Treasurer of the State of Florida or dealers designated
as "Primary Securities Dealers" by the Federal Reserve Bank of New York, for purchases and sales of
securities. The firm must have a minimum of $500 million in annual underwriting of U.S. Government
Agency Securities or Instrumentalities for the previous calendar year. The firm must have capital of no less
than $10,000,000.
Bond funds subject to arbitrage rebate shall be invested in accordance with specific bond covenants.
Repurchase agreements shall only be entered into with primary securities dealers and financial institutions that
are state qualified public depositories. All repurchase agreement transactions shall adhere to the requirements
of the Master Repurchase Agreement.
X. Third Party Custodial Agreements
The Finance Director may execute a third party Custodial Safekeeping Agreement with a commercial bank
having trust powers or a trust company which is chartered by the United States Government or the State of
Florida. All securities purchased and/or collateral obtained by the City shall be properly designated as an asset
of the City and held in safekeeping by the trust department or trust company, and no withdrawal of such
securities, in whole or in part, shall be made from safekeeping, except by an authorized City staff member.
The third party Custodial Safekeeping Agreement shall include letters of authority from the City with details
as to responsibilities of parties, notification of security purchases, sales, delivery, repurchase agreements, wire
transfers, safekeeping and transaction costs, procedures in case of wire failure or other unforeseen mishaps,
including liability of each party.
XI. Bid Requirements
When feasible and appropriate, investment purchases will be competitively bid. A minimum of three (3) banks
and/or dealers must be contacted and asked to provide bids on securities in question. Bids will be held in
AGENDA ITEM # 8B
JANUARY 25, 2010
confidence until the best bid is determined and awarded. Due to the cost of safekeeping, one business day
repurchase agreements and overnight sweep repurchase agreements will not be bid.
XII. Internal Controls
The Finance Director shall establish and monitor a set of internal controls designed to prevent loss of funds by
fraud, employee error, misrepresentation by third parties, or imprudent actions by employees of the City and
ensure proper accounting and reporting of the securities transactions. Such internal controls, shall include, but
not be limited to, the following:
A. All securities purchased or sold will be transferred only under the "deliver versus payment" (D.V.P.)
method to ensure that funds or securities are not released until all criteria relating to the specific
transaction are met;
B. The Finance Director is authorized to accept, on behalf of and in the name of the City of Atlantic Beach,
bank trust receipts or confirmations as evidence of actual delivery of the obligations or securities in return
for investment of funds;
C. Trust receipts or confirmations shall fully describe the various obligations or securities held, and the
receipt or confirmation shall state that the investment is held in the name of the City of Atlantic Beach;
D. The actual obligations, or securities, whether in book entry or physical form, on which trust receipts or
confirmations are issued, may be held by a third party custodial bank and/or institution or a designated
correspondent, bank which has a correspondent relationship to the City's third party custodian; and,
E. Other internal controls such as:
1. Written documentation of telephone transactions;
2. Adequate segregation of duties;
3. Custodial safekeeping;
4. Supervisory control of employee actions and operations review;
5. Performance evaluations and interim reporting;
6. Requirement of dual signatures on all investment transactions (except overnight repurchase
agreements and sweep accounts) from the Finance Director and City Manager.
7. Staff in the Finance Department reconciles the City's general depository account on a monthly
basis.
8. Independent auditors as a normal part of the annual financial audit to the City shall conduct a
review of the system of internal controls to ensure compliance with policies and procedures.
XIII. Money Managers
A. The City may utilize an outside money manager to invest up to 25% of the portfolio.
B. The money manager must be a securities dealer that is a member of the New York Stock Exchange having
a physical presence in Florida and having a minimum regulatory capital in excess of fifty million dollars
($50,000,000) or a primary securities dealer as designated by the Federal Reserve Bank of New York or a
bank having trust powers or a trust company which is chartered by the United States Government or the
State of Florida.
C. The City shall select the money manager based upon qualifications and fees, using a Request for Proposal
(RFP) process. At least three proposals must be solicited.
D. Any money manager selected will be required to enter into a money management agreement with the City,
as approved by the City Coimnission.
AGENDA ITEM # 8B
JANUARY 25, 2010
XIV. Continuing Education
The Finance Director and appropriate staff shall annually complete eight (8) hours of continuing education in
subjects or courses of study related to investment practices and products.
XV. Ethics and Conflicts of Interest
The City's staff involved in the investment process shall refrain from personal business activity that could
conflict with proper execution of the investment program, or which could impair their ability to make
impartial investment decisions. Also, employees involved in the investment process shall disclose to the City
any material financial interests in fmancial institutions that conduct business with the City, and they shall
further disclose any material personal fmancial/investmentpnsitions that could be related to the performance
of the City's investment program.
XVI. Derivatives and Reverse Repurchase Agreements
Investment in any derivative products or the use of reverse repurchase agreements is not permitted. A
"derivative" is defined as a fmancial instrument the value of which depends on, or is derived from, the value
of one or more underlying assets or indices or asset values.
AGENDA ITEM # 8B
JANUARY 25, 2010
INVESTIV~ENT POLICY
CITY OF MELBOURNE
Approved: September 24, 2002
AGENDA ITEM # 8B
JANUARY 25, 2010
However, if obtaining bids/offers are not feasible and appropriate, investments may be purchased
utilizing the comparison to current market price method on an exception basis. Acceptable current
market price providers include, but are not limited to:
A. Telerate Information System
B. Bloomberg Information Systems
C. Wall Street Journal or a comparable nationally recognized fmancial publication providing daily
market pricing
D. Daily market pricing provided by the City's custodian or their correspondent institutions
Examples of when this method may be used include:
A. When time constrauits due to unusual circumstances preclude the use of the competitive
bidding process
B. When no active market exists for the issue being traded due to the age or depth of the issue
C. When a security is unique to a single dealer, for example, a private placement
D. When the transaction involves new issues or issues in the "when issued" market
Overnight sweep investments will not be bid, but may be placed with the City's depository bank
relating to the demand account for which the repurchase agreement was purchased.
XII. AUTHORIZED INVESTMENTS AND PORTFOLIO COMPOSITION
Investments should be made subject to the cash flow needs and such cash flows are subject to revisions
as market conditions and the City's needs change. However, when the invested funds are needed in
whole or in part for the purpose originally intended or for more optimal investments, the Director of
Finance or the investment advisor may sell the investment at the then-prevailing market price and place
the proceeds into the proper account.
Investments not listed in this policy are prohibited.
The following are the investment requirements and allocation limits on security types, issuers, and
maturities, as established by the City. The Director of Finance or designee, and the Investment
Committee shall have the option to further restrict investment percentages from time to time based on
market conditions, risk and diversification investment strategies. The percentage allocation
requirements for investment types and issuers are calculated based on the market value of each
investment.
City of Melbourne Investment Policy Page 7
AGENDA ITEM # 8B
JANUARY 25, 2010
A. The Florida Local Government Surplus Funds Trust Fund
1. Purchase Authorization
Invest in the Florida Local Government Surplus Funds Trust Fund
2. Portfolio Composition
A maximum of 100% of available funds may be invested in the Florida Local
Government Surplus Funds Trust Fund.
B. United States Government Securities
Purchase Authorization
Invest in negotiable direct obligations or obligations the principal and interest of which
are unconditionally guaranteed by the United States Government. Such securities will
include, but not be limited to the following:
Cash Management Bills
Treasury Securities -State and Local Government Series ("SLGS")
Treasury Bills
Treasury Notes
Treasury Bonds
Treasury Strips
2. Portfolio Composition
A maximum of 100% of available funds lnay be invested in the United States
Govermnent Securities.
3. Maturity Limitations
The maximum length to maturity of any direct investment in the United States
Government Securities is five (5) years from the date of purchase.
C. United States Government Agencies
1. Purchase Authorization
Invest in bonds, debentures or notes which may be subject to call, issued or guaranteed
as to pruicipal and ilerest by the United States Governments agencies, provided such
obligations are backed by the full faith and credit of the United States Government.
Such securities will include, but not be limited to the following:
Government National Mortgage Association (GNMA)
-GNMA guaranteed mortgage-backed bonds
-GNMA guaranteed pass-through obligations
United States Export -Import Bank
-Direct obligations or fully guaranteed certificates of beneficial
ownership
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AGENDA ITEM # 8B
JANUARY 25, 2010
Farmer Home Admnistration
-Certificates of beneficial ownership
Federal Financing Bank
-Discount notes, notes and bonds
Federal Housing Administration Debentures
General Services Administration
United States Maritime Administration Guaranteed
-Title XI Financing
New Communities Debentures
-United States Government guaranteed debentures
United States Public Housing Notes and Bonds
-United States Government guaranteed public housing notes and bonds
United States Department of Housing and Urban Development
-Project notes and local authority bonds
2. Portfolio Composition
A maximum of 50% of available funds may be invested in United States Government
agencies.
Limits on Individual Issuers
A maximum of 25% of available funds may be invested in individual United States
Government agencies.
4. Maturity Limitations
The maximum length to maturity for an investment in any United States Government
agency security is five (5) years from the date of purchase.
D. Federal Instrumentalities (United States Government sponsored agencies)
Purchase Authorization
Invest in bonds, debentures or notes which may be subject to call, issued or guaranteed
as to principal and interest by United States Government sponsored agencies (Federal
Instrumentalities) which are non-full faith and credit agencies limited to the following:
Federal Farm Credit Bank (FFCB)
Federal Home Loan Bank or its City banks (FHLB)
Federal National Mortgage Association (FNMA)
Federal Home Loan Mortgage Corporation (Freddie-Macs) including Federal -
Holne Loan Mortgage Corporation participation certificates
Student Loan Marketing Association (Sallie-Mae)
Portfolio Composition
A maximum of 80% of available funds may be invested in Federal Instrumentalities.
Limits on hdividual Issuers
City of Melbourne Investment Policy Page 9
AGENDA ITEM # 8B
JANUARY 25, 2010
A maximum of 40% of available funds may be invested in individual Federal
Instrumentalities
4. Maturity Limitations
The maximum length to maturity for an investment in any Federal Instrumentality
security is five (5) years from the date of purchase.
E. Interest Bearing Time Deposit or Saving Accounts
Purchase Authorization
Invest in non-negotiable interest bearing time certificates of deposit or savings accounts
in banks organized under the laws of this state and/or in national banks organized under
the laws of the United States and doing business and situated in the State of Florida,
provided that any such deposits are secured by the Florida Security for Public Deposits
Act, Chapter 280, Florida Statutes. Additionally, the bank shall not be listed with any
recognized credit watch information service.
2. Portfolio Composition
A maximum of 25% of available funds may be invested in non-negotiable interest
bearing time certificates of deposit.
3. Limits on Individual Issuers
A maximum of 15% of available funds may be deposited with any one issuer.
4. Maturity Limitations
The maximum maturity on any certificate shall be no greater than three (3) years from
the date of purchase.
F. Repurchase Agreements
1. Purchase Authorization
a. Invest in repurchase agreements composed of only those investments based on
the requirements set forth by the City's Master Repurchase Agreement. All
fines are required to sign the Master Repurchase Agreement prior to the
execution of a repurchase agreement transaction.
b. A third party custodian with whom the City has a current custodial agreement
shall hold the collateral for all repurchase agreements with a term longer than
one (1) business day. A clearly marked receipt that shows evidence of
ownership must be supplied to the Director of Finance and retained.
c. Securities authorized for collateral are negotiable direct obligations of the
United States Government, Govenzrrlent Agencies, and Federal
Instrumentalities with maturities under five (5) years and must have a market
value for the principal and accrued interest of 102 percent of the value and for
the term of the repurchase agreement. Immaterial short-tern deviations from
City of Melbourne Investment Policy Page 10
AGENDA ITEM # 8B
JANUARY 25, 2010
102 percent requirement are permissible only upon the approval of the Director
of Finance.
2. Portfolio Composition
A maximum of 50% of available funds may be invested in repurchase agreements
excluding one (1) business day agreements and overnight sweep agreements.
3. Limits on Individual Issuers
A maximum of 25% of available funds may be invested with any one institution.
4. Limits on Maturities
The maximum length to maturity of any repurchase agreement is 90 days from the date
of purchase.
G. Commercial Paper
1. Purchase Authorization
Invest in commercial paper of any United States company that is rated, at the time of
purchase, "Prune-1" by Moody's and "A-1" by Standard & Poor's (prime commercial
paper).
2. Portfolio Composition
A lnaximuln of 25% of available funds may be directly invested in prime commercial
paper.
3. Limits on Individual Issuers
A maximum of 10% of available funds may be invested with any one issuer.
4. Maturity Limitations
The maximum length to maturity for prime commercial paper shall be 270 days from
the date of purchase.
H. Corporate Notes
Purchase Authorization
Invest in corporate notes issued by corporations organized and operating within the
United States or by depository institutions licensed by the United States that have a
long term debt rating, at the time or purchase, at a minimum "AA" by Moody's and a
minimum long term debt rating of "AA" by Standard & Poor's.
2. Portfolio Composition
A maximum of 15% of available funds maybe directly invested in corporate notes.
City of Melbourne Investment Policy Page 11
AGENDA ITEM # 8B
JANUARY 25, 2010
3. Limits on Individual Issuers
A maximum of 5% of available funds may be invested with any one issuer.
4. Maturity Limitations
The maximum length to maturity for corporate notes shall be three (3) years from the
date of purchase.
I. Bankers' Acceptances
1. Purchase Authorization
Invest in Bankers' Acceptances issued by a domestic bank or a federally chartered
domestic office of a foreign bank, which are eligible for purchase by the Federal
Reserve System, at the time of purchase, the short-term paper is rated, at a minimum,
"P-1" by Moody's Investors Services and "A-1" Standard & Poor's.
2. Portfolio Composition
A maximum of 25% of available funds may be directly invested in Bankers'
Acceptances
3. Limits on Individual Issuers
A maximum of 10% of available funds may be invested with any one issuer.
4. Maturity Limitations
The maximum length to maturity for Bankers' Acceptances shall be 180 days from the
date of purchase.
J. State and/or Local Government Taxable and/or Tax-Exempt Debt
1. Purchase Authorization
Invest in state and/or local government taxable and/or tax-exempt debt, general
obligation and/or revenue bonds, rated at least "AA" by Moody's and "AA" by
Standard & Poor's for long-term debt, or rated at least "MIG-1" by Moody's and "SP-
1" by Standard & Poor's for short-term debt.
2. Portfolio Composition
A maximum of 20% of available funds may be invested in taxable and tax-exempt
debts.
3. Maturity Limitations
A maximum length to maturity for an investment in any state or local government debt
security is three (3) years from the date of purchase.
K. Registered Investment Companies (Money Market Mutual Funds)
City of Melbourne Investment Policy Page 12
AGENDA TEEM # 8B
JANUARY 25, 2010
1. livestment Authorization
Invest in shares of open-end or no-load money market mutual funds provided such
funds are registered under the Federal Investment Company Act of 1940 and operate in
accordance with 17 C.F.R. § 270.2a-7, which stipulates that money market funds must
have an average weighted maturity of 90 days or less. The prospectus of such funds
must indicate that the share value shall not fluctuate.
2. Portfolio Composition
A maximum of 50% of available funds may be invested in money market funds.
3. Limits of Tiidividual Issuers
A maximum of 25% of available funds may be invested with any one money market
fund.
4. Rating Requirements
The money market funds shall be rated "AAm" or "AAm-G" or better by Standard &
Poor's, or the equivalent by another rating agency.
5. Due Diligence Requirements
A thorough investigation of any money market fund is required prior to investing, and
on a continual basis. There shall be a questionnaire developed by the Director of
Finance or the investment advisor that will contain a list of due diligence
considerations that deal with the major aspects of any investment pooUfund. A current
prospectus must be obtained.
L. hitergovernmental Investment Pool
1. divestment Authorization
Intergovermnental investment pools that are authorized pursuant to the Florida
Interlocal Cooperation Act, as provided in Section 163.01, Florida Statutes.
2. Portfolio Composition
A maximum of 10% of available funds may be invested in intergovernmental
investment pools.
3. Due Diligence Requirements
A thorough investigation of awry pool fund is required prior to uivesting, and on a
continual basis. There shall be a questionnaire developed by the Director of Finance or
the investment advisor that will contain a list of due diligence considerations that deal
with the major aspects of any investment pooUfund. A current prospectus must be
obtained.
City of Melbourne Investment Policy Page 13