FILE:  DFE

Cf:  DG, DGA, DJA, DJED

 

INVESTMENTS

 

 

PURPOSE

 

The purpose of this policy is to set forth the investment objectives and parameters for the management of the funds of the Orleans Parish School Board.  This policy is designed to safeguard the School Board’s funds, ensure the availability of operating and capital funds when needed, and provide for an investment return competitive with comparable funds and financial market indices.

 

SCOPE

 

In accordance with La. Rev. Stat. Ann. §33:2955,  this policy applies to all cash and investments held or controlled by the Orleans Parish School Board with the exception of funds related to the issuance of debt where there are other existing policies or indentures in effect for such funds.  Additionally, this policy does not apply to funds not under investment control of the School Board, including funds held in escrow or custodial funds.

 

Except for cash in certain restricted and special funds, the Orleans Parish School Board may consolidate cash and reserve balances from all funds to maximize investment earnings and to increase efficiencies with regard to investment pricing and administration.  If investments are pooled, investment income will be allocated to the various funds based on their respective participation and in accordance with generally accepted accounting principles.

 

INVESTMENT OBJECTIVES

 

The primary objectives, in priority order, of investment activities shall be safety of principal, maintenance of liquidity, and return on investment:

 

  1. Safety of Principal

    The foremost objective of this investment program is the safety of the principal of those funds within the portfolios.  Investment transactions shall seek to keep capital losses at a minimum, whether they are from securities defaults or erosion of market value.  Diversifying the investment portfolio so that the impact of potential losses from any one type of security or from any one individual issuer will be minimized.

 

  1. Maintenance of Liquidity

    The portfolio shall be managed in such a manner that funds are available to meet reasonably anticipated cash flow requirements in an orderly manner.  Periodic cash flow analyses will be completed in order to ensure that the portfolio is positioned to provide sufficient liquidity.  Furthermore, the portfolio should consist largely of securities with active secondary or resale markets.

 

  1. Return on Investment

    The portfolio shall be designed with the objective of attaining a market rate of return throughout budgetary and economic cycles, taking into account the investment risk constraints and liquidity needs.  Return on investment is of least importance compared to the safety and liquidity objectives described above.  However, return is attempted through active management where the School Board utilizes a total return strategy (which includes both realized and unrealized gains and losses in the portfolio).  This total return strategy seeks to increase the value of the portfolio through reinvestment of income and capital gains.  The core of investments is limited to relatively low-risk securities in anticipation of earning a fair return relative to the risk being assumed.  Despite this, an investment adviser may trade to recognize a loss from time to time to achieve a perceived relative value based on its potential to enhance the total return of the portfolio.

 

STANDARDS OF CARE

 

  1. Delegation of Authority

    Responsibility for the administration of the investment program is vested in the Chief Financial Officer, who may authorize his/her designee (hereinafter referred to as an investment officer) to manage the investment program.  The investment officer shall act in accordance with established written procedures and internal controls for the operation of the investment program consistent with this policy.

    No person may engage in an investment transaction except as provided under the terms of this policy and procedures established by the investment officer.  The School Board may employ one or more investment adviser(s) to assist in managing the School Board’s portfolio.  Any investment adviser must be registered under the Investment Adviser’s Act of 1940.

 

  1. Ethics and Conflicts of Interest

    Employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution and management of the investment program, or which could impair their ability to make impartial investment decisions.  Employees involved in the investment process shall disclose any material interests in financial institutions that conduct business with the School Board, and they shall further disclose any material personal financial/investment positions that could be related to the performance of the School Board’s investment program.  Employees involved in the investment process and School Board members shall refrain from undertaking personal investment transactions with the same individual with whom business is conducted on behalf of the Orleans Parish School Board.

 

  1. Standards of Prudence

    The standard of prudence to be used by investment officials shall be the “Prudent Person” standard and shall be applied in the context of managing the overall investment program.  Investment officers acting in accordance with written procedures and this policy and exercising due diligence shall be relieved of personal responsibility for an individual security’s credit risk or market price changes, provided deviations from expectation are reported to the Chief Financial Officer or designee in a timely fashion and the liquidity and the sale of securities are carried out in accordance with the terms of this policy.  The “Prudent Person” rule state the following:

 

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.

 

While the standard of prudence to be used by investment officials who are officers or employees is the “Prudent Person” standard, any person or firm hired or retained to invest, monitor, or advise concerning these assets shall be held to the higher standard of “Prudent Expert.”  The standard shall be that in investing and reinvesting moneys and in acquiring, retaining, managing, and disposing of investments of these funds, the contractor shall exercise the judgment, care, skill, prudence, and diligence under the circumstances then prevailing, which persons of prudence, discretion, and intelligence, acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of like character and with like aims by diversifying the investments of the funds, so as to minimize the risk, considering the probable income as well as the probable safety of their capital.

 

CONTINUING EDUCATION

 

The Chief Financial Officer and any other personnel responsible for overseeing investments or his/her designee shall annually complete 4 hours of continuing education in subjects or courses of study related to investment practices and products.

 

AUTHORIZED FINANCIAL INSTITUTIONS, DEPOSITORIES AND BROKERS/DEALERS

 

The investment officer shall only purchase securities from or enter into repurchase agreements with qualified institutions, as defined in this section, or from investment institutions which are designated as primary dealers by the Federal Reserve Bank of New York and meet the following requirements:

 

  1. Regional dealers that qualify under Securities and Exchange Commission Rule 15C3-1 (uniform net capital rule);

  2. Capital of no less than $10,000,000;

  3. Registered as a dealer under the Securities Exchange Act of 1934;

  4. Member of the Financial Industry Regulatory Authority, Inc. (FINRA);

  5. Registered to sell securities in Louisiana; and

  6. The firm and assigned broker have been engaged in the business of effecting transactions in United States government and agency obligations for at least five (5) consecutive years.

 

CUSTODY

 

  1. Investment Custody

    All security transactions entered into by the Orleans Parish School Board shall be conducted on a book-entry basis.  Securities will be held by a third-party custodian approved by the investment officer and evidenced by monthly statements and trade confirmations.

 

  1. Internal Controls

    The investment officer shall establish a system of internal controls which shall be documented in writing.  The controls shall be designed to prevent the loss of public funds arising from fraud, employee error, misrepresentation by third parties, unanticipated changes in financial markets, or imprudent actions by employees of the Orleans Parish School Board.

 

SUITABLE AND AUTHORIZED INVESTMENTS

 

  1. Investment Types

    Consistent with La. Rev. Stat. Ann. §33:2955, the following investments will be permitted by this policy and are those defined by state law:

 

  1. Direct United States Treasury obligations which carry the full faith and credit guarantee of the United States government and are considered to be the most secure instruments available;

  2. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by federal agencies and provided such obligations are backed by the full faith and credit of the United States of America and have a liquid market with a readily determinable market value;

  3. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by United States government instrumentalities which are federally sponsored and have a liquid market with a readily determinable market value;

  4. Direct security repurchase agreements of any federal book-entry only securities enumerated in (a) through (c) above;

  5. Time certificates of deposit of any bank domiciled or having a branch office in the state of Louisiana, savings accounts or shares of savings and loan associations and savings banks as defined by La. Rev. Stat. Ann. §6:703, or share accounts and share certificate accounts of federally or state-chartered credit unions issuing time certificates of deposit;

  6. Mutual or trust fund institutions which are registered with the Securities and Exchange Commission under the Securities Act of 1933 and the Investment Act of 1940, and which have underlying investments consisting solely of and limited to securities of the United States government or its agencies and consist solely of dollar-denominated securities;

  7. Investment grade commercial paper issued in the United States, traded in the United States markets, and denominated in United States dollars;

  8. Bonds, debentures, notes, or other evidence of indebtedness issued by the State of Louisiana or any of its political subdivisions in accordance La. Rev. Stat. Ann. §33:2955;

  9. Bonds, debentures, notes, or other evidence of indebtedness issued by a state of the United States of America other than Louisiana or any such state’s political subdivisions, in accordance with La. Rev. Stat. Ann. §33:2955;

  10. Bonds, debentures, notes or other indebtedness issued by domestic United States corporations.  Prior to purchase and at all times during which the indebtedness is owned, the School Board must comply with all restrictions listed in La. Rev. Stat. Ann. §33:2955(A)(1); and

  11. Any local governmental investment pool created pursuant to Louisiana statutes, such as the Louisiana Asset Management Pool (LAMP).

 

Sector

 Maximum Sector(%)

Per Issuer Maximum

(%)

Minimum Ratings Requirement1

Maximum Maturity

U.S. Treasury

100%

100%

N/A

5 Years

(5 Years avg. life4

for GNMA)

GNMA

40%

Other U.S. Government Guaranteed

10%

Federal Instrumentalities/GSE:

FNMA, FHLMC, FHLB, FFCB*

80%

40%3

N/A

5 Years

Federal Instrumentalities/GSE

other than those above

10%

Corporates

50%2

5%

Two Highest LT Rating Categories

(AA-/Aa3 or equivalent)

5 Years

Municipals

25%

5%

Highest ST or Three Highest LT Rating Categories

 (SP-1/MIG 1, A-/A3, or equivalent)

5 Years

Agency Mortgage-Backed Securities (MBS)

25%

40%3

N/A

5 Years

Avg. Life4

Non-Negotiable Certificates of Deposit and Savings Accounts

50%2

$250,000 if not fully collateralized

N/A

5 Years

Commercial Paper (CP)

50%2

5%

Highest ST Rating Category

(A-1/P-1, or equivalent)

270 Days

Repurchase Agreements (Repo or RP)

40%

20%

Counterparty (or if the counterparty is not rated by an NRSRO, then the counterparty’s parent) must be rated in the Highest ST Rating Category

(A-1/P-1, or equivalent)

If the counterparty is a Federal Reserve Bank, no rating is required

1 Year

Money Market Funds (MMFs)

25%

25%

Highest Fund Rating by all NRSROs who rate the fund (AAAm/Aaa-mf, or equivalent)

N/A

Local Government Investment Pools (LGIP)

25%

25%

Highest Fund Quality and Volatility Rating Categories by all NRSROs who rate the LGIP,

(AAAm/AAAf, S1, or equivalent)

N/A

Notes:

1 Rating by at least one SEC-registered Nationally Recognized Statistical Rating Organization (“NRSRO”), unless otherwise noted.  ST=Short-term; LT=Long-term.

2 Maximum allocation to all corporate and bank credit instruments is 50% combined.

3 Maximum exposure to any one Federal agency, including the combined holdings of Agency debt and Agency MBS, is 40%.

4 The maturity limit for MBS is based on the expected average life at time of settlement, measured using Bloomberg or other industry standard methods.

* Federal National Mortgage Association (FNMA); Federal Home Loan Mortgage Corporation (FHLMC); Federal Home Loan Bank or its District banks (FHLB); Federal Farm Credit Bank (FFCB).

 

 

  1. Collateralization

    Where allowed by state law, full collateralization will be required on all demand deposit accounts, including checking accounts and non-negotiable certificates of deposit.

 

PROHIBITED TRANSACTIONS

 

The following arrangements are expressly prohibited:

 

  1. Any transactions not specifically authorized by this policy.

  2. The purchase of securities on margin.

  3. Direct purchases of single family or commercial mortgages.

  4. Purchases of foreign bonds.

  5. Collateralized mortgage obligations that have been stripped into interest only or principal only obligations.

  6. Inverse floaters or structured notes.  For purposes of this section, structured notes shall mean securities of United States government agencies, instrumentalities, or government-sponsored enterprises which have been restructured, modified, and/or reissued by private entities.

  7. Investment products that include the use of derivatives, financial instruments, the value of which depends on, or is derived from, the value of one or more underlying assets or indices or asset values.

  8. Reverse repurchase agreements.

 

INVESTMENT PARAMETERS

 

  1. Diversification

    It is the policy of the Orleans Parish School Board to diversify its investment portfolios.  To eliminate risk of loss resulting from overconcentration of assets in a specific maturity, issuer, or class of securities, all cash and cash equivalent assets in all the School Board’s funds shall be diversified by maturity, issuer and/or class of securities.

 

  1. Maximum Maturities

    To the extent possible, the Orleans Parish School Board shall attempt to match its investments with anticipated cash flow requirements.  Unless matched to a specific cash flow, the School Board will not directly invest in securities maturing more than five (5) years from the date of settlement or in accordance with state statutes.  The School Board’s portfolio weighted average effective duration shall not exceed three (3) years, consistent with the investment objectives.

    Reserve funds and other funds with longer-term investment horizons may be invested in securities exceeding five (5) years if the maturities of such investments are made to coincide as nearly as practicable with the expected use of funds.  The intent to invest in securities with longer maturities shall be disclosed in writing to the School Board.

 

REPORTING

 

  1. Quarterly Investment Report

    The Chief Financial Officer, investment officer, or investment adviser shall provide written quarterly investment reports to the School Board which should include, but are not limited to, the following:

 

 

  1. Annual Investment Report

    On an annual basis, the Chief Financial Officer, investment officer, or investment adviser shall submit to the School Board a written report on all invested funds.  The annual report will show performance on both a book value and total rate of return basis and will compare the results to performance benchmarks for short-term and long-term portfolios.

 

INTEREST EARNINGS

 

The interest earned on any such investment shall be credited to the fund from which the investment was acquired or it may be applied to the payment of the principal and interest of the outstanding bonded indebtedness of that fund.

 

LIQUIDATION OF INVESTMENTS

 

At any time that may be advisable, the School Board may cash or liquidate any of the investments authorized herein which are purchased for any particular fund.  The proceeds of any such liquidation shall be credited to the fund from which the authorized investments were originally purchased.

 

Revised:  November 21, 2019

Revised:  September 23, 2021

 

 

Ref:    La. Rev. Stat. Ann. §§17:99, 33:2955, 39:1241, 39:1242, 39:1243, 39:1244, 39:1245, 39:1272

Board minutes, 11-21-19, 9-23-21

 

Orleans Parish School Board