approved_res-05-2026_-_investment_policy-exhibit-a.pdf
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This Exhibit A is the Town of Centreville’s Investment Policy establishing rules for investing the Municipality’s public funds. It sets priorities (safety of principal, liquidity, then yield), scope (General Fund, Special Revenue, Capital Project, Debt Service and other unrestricted funds), and cites compliance with Maryland law, COMAR, and State Treasurer guidelines. The policy delegates investment authority to the Finance Officer, lists authorized institutions and investment types (e.g., U.S. Treasury and federal agency obligations, collateralized repurchase agreements, certificates of deposit, authorized money market funds), and identifies prohibited activities (borrowing to invest, speculation/leveraging, and investments not authorized by law). It requires third‑party custodial safekeeping with delivery versus payment, internal controls reviewed by auditors, quarterly investment reporting to the governing body, benchmarking for performance, and at least annual policy review and formal adoption/amendment procedures with submission to the State Treasurer as required.
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EXHIBIT A 1. Purpose The purpose of this Investment Policy is to establish the parameters for the investment of public funds of The Town of Centreville. in a manner that complies with Maryland law, the regulations and guidelines of the Maryland State Treasurer, and generally accepted public-sector investment practices. This policy is intended to ensure that public funds are invested with a primary emphasis on safety of principal, liquidity, and yield, in that order of priority. 2. Scope This policy applies to all financial assets of the Municipality that are available for investment, including but not limited to: • General Fund • Special Revenue Funds • Capital Project Funds • Debt Service Funds • Any other funds not otherwise restricted by law or trust agreement Funds governed by separate legal or contractual requirements (such as pension or trust funds) are excluded unless specifically incorporated by reference. 3. Governing Authority This policy is adopted pursuant to: • Maryland Local Government Article, Title 17 • State Finance and Procurement Article • Applicable sections of the Code of Maryland Regulations (COMAR) • Investment guidelines issued by the Maryland State Treasurer All investments shall be made in strict conformity with these authorities, as amended from time to time. 4. Objectives The objectives of the Municipality’s investment activities, in priority order, shall be: 4.1 Safety Preservation of capital is the foremost objective. Investments shall be undertaken in a manner that seeks to minimize the risk of loss of principal. EXHIBIT A 4.2 Liquidity The investment portfolio shall be structured to meet all reasonably anticipated operating and capital cash flow requirements. 4.3 Yield The portfolio shall be designed to attain a market rate of return consistent with the objectives of safety and liquidity and within the constraints of this policy. 5. Standard of Care (Prudence) Investments shall be made with judgment and care, under circumstances then prevailing, that people of prudence, discretion, and intelligence exercise in the management of their own affairs, not for speculation, but for investment. Investment officers acting in accordance with this policy and applicable law shall be relieved of personal responsibility for individual investment decisions, provided deviations are reported in a timely manner and corrective action is taken. 6. Ethics and Conflicts of Interest Officers and employees involved in the investment process shall: • Refrain from personal business activity that could conflict with proper execution of the investment program • Disclose any material financial interests in financial institutions with which the Municipality conducts business • Not accepting gifts, favors, or compensation from entities seeking to do business with the Municipality 7. Delegation of Authority Authority to manage the Municipality’s investment program is delegated to the Finance Officer, hereafter referred to as the “Investment Officer.” The Investment Officer shall act in accordance with this policy and applicable law and may not delegate investment authority without formal approval by the governing body. 8. Authorized Financial Institutions and Dealers The Municipality shall only transact investment business with: • Financial institutions authorized to do business in the State of Maryland EXHIBIT A • Institutions that provide written certification of compliance with this policy 9. Authorized Investments Investments shall be limited to those authorized by Maryland law and COMAR, including but not limited to: • Obligations of the United States Treasury • Obligations of U.S. federal agencies or instrumentalities • Repurchase agreements collateralized by U.S. government securities • Certificates of deposit and other bank deposits permitted by law • Money market mutual funds authorized for public funds • Other investments specifically authorized under Maryland law Prohibited Activities: • Borrowing funds for the purpose of investing • Speculation or leveraged investment strategies • Investments not expressly authorized by Maryland law 10. Maturity and Diversification • Investments shall be structured to match projected cash flow needs • The portfolio shall be diversified by maturity, investment type, and issuer to reduce risk • Maturity limits shall comply with Maryland law and State Treasurer guidelines 11. Safekeeping and Custody • All securities shall be held by a third-party custodian in the Municipality’s name • Delivery versus payment (DVP) shall be required for all transactions • Collateral for deposits shall meet Maryland collateralization requirements 12. Internal Controls The Investment Officer shall establish and maintain a system of internal controls designed to prevent loss, fraud, or misuse of public funds. Controls shall be reviewed periodically by independent auditors. 13. Reporting The Investment Officer shall provide periodic investment reports to the governing body, at least quarterly, which shall include: • A listing of current investments EXHIBIT A • Portfolio composition and maturity distribution • Compliance with this policy and applicable law 14. Performance Measurement The investment portfolio shall be evaluated against appropriate benchmarks consistent with the objectives of safety and liquidity. 15. Policy Review and Amendment This policy shall be reviewed at least annually by the governing body. Any amendments shall be adopted by resolution and submitted to the Maryland State Treasurer as required by law. 16. Policy Adoption This Investment Policy was adopted by the [Governing Body Name] of the [Name of Municipality], Maryland, on [Date], and shall remain in effect until amended or rescinded. Certification I hereby certify that this policy complies with Maryland law and the investment guidelines of the Maryland State Treasurer. __________________________________ [Authorized Official] Title Date