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CITY OF ALAMO HEIGHTS
ADMINISTRATION AND FINANCE DEPARTMENT
CITY COUNCIL AGENDA MEMORANDUM
TO: Mayor and City Council
FROM: Robert Galindo, Director of Finance
SUBJECT: A Resolution Adopting the City’s Investment Policy
DATE: January 9, 2023
SUMMARY
Adoption of this resolution acknowledges that the investment policy has been reviewed and any
necessary changes have been made to the investment policy.
BACKGROUND INFORMATION
The City’s Investment Policy is reviewed each fiscal year. Texas Government Code, Chapter 2256,
known as the Public Funds Investment Act (PFIA), establishes requirements for local governments
to manage the risks involved in investment of public funds. The PFIA requires:
 a written strategy;
 annual review and adoption of strategy;
 designate an investment officer;
 disclose personal/business relationships;
 provide policy for written certification;
 obtain annual management audit;
 provide for training; and
 report quarterly to management.
Texas Government Code 2256 requires that investments be made with judgment and care, under
prevailing circumstances, that a person of prudence, discretion, and intelligence would exercise in
the management of the person’s own affairs, not for speculation, but for investment, considering
the probable safety of capital and the probable income to be derived. Investment of funds shall be
governed by the following objectives, in order of priority: preservation and safety of principal,
liquidity, and last of all yield.
Texas Government Code requires a written strategy for investment of all financial assets of the
City. It limits investments to government backed securities such as U.S. Treasuries, U.S.
Agencies/Instrumentalities, Money Market Funds, Mutual Funds, Investment Pools and
Certificates of Deposit which are insured by the Federal Deposit Insurance Corporation in order
to protect the safety of principal. To meet the requirement of liquidity, an analysis of the City’s
cash flows to identify needs and deficits must be made. Investments maturity and marketability
must be matched to ensure those needs are met. Yield is the last priority.
POLICY ANALYSIS
The City’s Investment Policy is conservative but allows investing in a manner which will provide
the highest reasonable yield with maximum security while meeting daily cash flow needs and
conforms to all state and local statutes.
Section 2256.005 of the Texas Public Funds Investment Act requires the governing body of an
investing entity to review its investment policy and investment strategies on an annual basis even
if no changes are made. The governing body shall adopt a written instrument by rule, order,
ordinance, or resolution stating that it has reviewed the investment policy and investment strategies
and that the written instrument so adopted shall record any changes made to either the investment
policy or investment strategies. The policy has been reviewed by the Finance Director, City
Manager and CM Savage.
FISCAL IMPACT
Investment strategies create a performing asset by putting money to work, assuring cash efficiency
and security, adding yield while minimizing risk to the City’s portfolio.
ATTACHMENTS
Attachment A – City of Alamo Heights Investment Policy
Attachment B – Resolution
______________________
Robert Galindo
Director of Finance
______________________
Buddy Kuhn
City Manager
City of Alamo Heights, Texas
Investment Policy
January 9, 2023
Attachment A
City of Alamo Heights, Texas
Investment Policy
TABLE OF CONTENTS
I. Purpose............................................................................................................. 1
II Statutory Authority ............................................................................................. 1
III. Policy Scope...................................................................................................... 1
IV. Investment Strategy Statement.......................................................................... 1
V. Investment Objectives ....................................................................................... 2
A. Suitability of Investments
B. Preservation and Safety of Capital
C. Liquidity
D. Marketability of Investments
E. Diversification
F. Yield
VI. Standards of Care.............................................................................................. 4
A. Prudence
B. Ethics and Conflicts of Interest
C. Delegation of Authority
D. Training
VII. Execution of Security Transactions.................................................................... 5
A. Authorized Financial Dealers and Institutions
B. Selection of Investments
C. Delivery vs. Payment
D. Safekeeping
E. Measuring Market Value
VIII. Internal Controls and Annual Audit .................................................................... 7
A. Internal Controls
B. Annual Audit
IX. Suitable and Authorized Investments................................................................. 8
A. Investment Types
B. Collateralization
C. Prohibited Investments
D. Authorized Investments: Mutual Funds
X. Investment Parameters.................................................................................... 11
A. Investment Management Style
B. Diversification
C. Maximum Maturities
Attachment A
City of Alamo Heights, Texas
Investment Policy
TABLE OF CONTENTS (CONTINUED)
XI. Performance Standards................................................................................... 11
XII. Performance Evaluation and Reporting ........................................................... 12
Appendix A: Glossary ............................................................................................. 13
Appendix B: Illustrative Broker/Dealer Certification Form........................................ 17
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 1
I. Purpose
The purpose of this document is to establish the investment policies for the management
of the public funds of the City of Alamo Heights, Texas (City). This policy will be reviewed
on an annual basis by City Council. At such time, the council will adopt a resolution that
(1) states that the investment policy has been reviewed and (2) enumerates the changes
to be made to the policy.
These policies are designed to ensure the prudent management of public funds, the
availability of operating and capital funds when needed, and an investment return
competitive with those of comparable funds and financial market indexes.
A copy of this statement will be provided to all business organizations offering to engage
in investment transactions with the City. A qualified representative of the business
organization must confirm in writing (1) that this policy has been read and thoroughly
reviewed and (2) that reasonable controls have been established to preclude unauthorized
investment transactions. This confirmation must be received by the City prior to the firm
providing any services.
II. Statutory Authority
This policy was adopted in accordance with the Public Funds Investment Act (V.T.C.A.,
Government Code §2256).
III. Policy Scope
This investment policy applies to all of the financial assets (i.e., cash, bank deposits and
securities) of the City. These assets are pooled into a single common investment fund
that incorporates the following accounting fund types:
 Governmental Funds including debt service reserves and sinking funds, to the
extent not required by law or existing contract to be kept segregated and
managed separately;
 Proprietary Funds;
 Fiduciary Funds; and
 To include any new funds created by the City unless specifically exempted by the
City Council and this policy.
Investments in the City’s employee pension and deferred compensation plans are
independently managed and are not covered by this policy.
IV. Investment Strategy Statement
It is the City’s policy to invest public funds in a manner that meets the following objectives:
 Ensure the suitability of the investment to the financial requirements of the City;
 Ensure preservation and safety of capital;
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 2
 Provide sufficient liquidity to meet cash flow needs;
 Ensure the marketability of the investments;
 Provide sufficient diversification; and
 Provide a competitive return on investment.
V. Investment Objectives
The following is a detailed discussion of the City’s investment objectives, in priority order:
A. Suitability of Investments
Investments shall be made with the primary focus of having cash available to meet
the City’s financial requirements. This requires that the City match investment
maturities with anticipated expenditures. Annually, budgeted revenues closely
approximate budgeted expenditures; however, property taxes, the City’s primary
revenue source, are cyclical in nature. This creates large cash balances during the
months of December through March, which must be invested until required later in
the year to finance the City’s operating activities.
B. Preservation and Safety of Capital
Investments shall be undertaken in a manner that seeks to ensure the preservation
of capital in the overall portfolio. To achieve this objective it is necessary to minimize
credit risk and interest rate risk.
Credit risk is the risk of loss due to failure of the security issuer to pay interest and/or
principal in a timely manner. It may be reduced by:
 Limiting investments to the safest types of securities;
 Pre-qualifying the business organizations with which the City will do
business; and
 Requiring that investments not insured or guaranteed by the United
States government be fully collateralized.
Interest rate risk is the risk that the market value of securities in the portfolio will fall
due to changes in general interest rates. The longer the term, the more tendency
there is for rates to fluctuate. Interest rate risk may be reduced by:
 Structuring the investment portfolio so that securities mature to meet
cash requirements for ongoing operations, thereby avoiding the need to
sell securities on the open market prior to maturity; and
 Investing primarily in shorter-term securities, money market mutual
funds, or similar investment pools.
Both types of risk may also be controlled through diversification.
C. Liquidity
It is the City’s objective that the investment portfolio shall remain sufficiently liquid
to meet all operating requirements that may be reasonably anticipated.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 3
Liquidity is the relative ease with which a security may be converted to cash, typically
through sale on the open market. The goals of liquidity and preservation of capital
may conflict at times. While a security may be easily converted to cash, the amount
of cash received may be less than the amount initially paid due to fluctuations in
market value. For that reason, it is important for the portfolio to be structured so that
securities mature concurrent with anticipated cash needs, hereby avoiding the need
to liquidate investments under adverse market conditions.
D. Marketability of Investments
Marketability is the ability to quickly purchase and sell a security at competitive
prices in secondary markets. Some investments, such as Treasury bills, can be
sold at any time. Other more exotic instruments may not be much in demand by
other investors and, consequently, may be much harder to sell.
Since all possible cash demands cannot be anticipated, the portfolio should consist
of securities with active secondary or resale markets. This will ensure that in the
event the City must sell a security, a buyer can be readily found.
At times, selling a security before maturity may produce a loss. With the exception
of the following situations, securities shall not be sold at a loss:
 A security with a declining market value could be sold early to minimize
loss;
 A security swap would improve the quality, yield, or target duration in the
portfolio; or
 Liquidity needs of the portfolio require that a security be sold and all other
sales would result in a larger loss.
E. Diversification
The constraints established by this investment policy minimize the City’s risk
exposure. Through diversification, the City can further limit risk exposure. The City
will address diversification in its portfolio by limiting its exposure to any one type of
investment, staggering investment maturities, and using several investment
providers.
F. Yield
A fundamental rule of investments is that risk equals return. The City has
deliberately established a low risk threshold in order to protect its financial resources
and ensure that cash is available when needed. Return on investment is the least
important objective of the City’s investment program. It is anticipated, however, that
the City will still earn a competitive rate of return given the level of risk assumed.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 4
VI. Standards of Care
A. 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
portfolio, not each investment decision. Investment officers acting in accordance
with this investment policy and exercising due diligence shall be relieved of personal
responsibility for an individual security’s credit risk or market price changes,
provided that the investment decision was consistent with this written policy.
The “prudent person” standard requires 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
capital as well as the probable income to be derived.
B. Ethics and Conflicts of Interest
Employees involved in the investment process shall refrain from personal business
activity that could conflict with the proper execution and management of the
investment program, or that could impair their ability to make impartial decisions.
Employees and investment officials shall disclose any material interests in financial
institutions with which they conduct business. They shall further disclose any
personal investment positions that could be related to the performance of the
investment portfolio. Employees and officers shall refrain from undertaking personal
investment transactions with the same individual with which business is conducted
on behalf of the City.
Any investment officer who is related within the second degree by affinity or
consanguinity as determined under the Tex. Gov’t Code Ann. Ch. 573 to an
individual seeking to sell an investment to the City shall file a statement disclosing
that relationship with the City Council and the Texas Ethics Commission.
C. Delegation of Authority
The City Finance Director and the City Manager are hereby designated Investment
Officers of the City. Authority to manage the investment program is granted to the
City Finance Director.
No person may engage in investment transactions except as provided under the
terms of this policy and the procedures established by the City Finance Director.
The City Finance Director shall be responsible for all transactions undertaken and
shall establish a system of controls to regulate the activities of subordinate officials.
D. Training
The City Finance Director and the City Manager shall attend at least one training
session related to their respective duties within 12 months of assuming office or
duties. This training must include education in investment controls, security risks,
strategy risks, market risks and compliance with the Public Funds Investment Act.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 5
After the initial training session, both the City Finance Director and the City Manager
shall receive a minimum of 8 hours of training as required by state law, which is
designed to ensure the continued proper performance of their duties under this
policy and the Public Funds Investment Act. The training provider must be an
independent provider. For purposes of this policy, an “independent source” from
which investment training shall be obtained shall include a professional
organization, an institute of higher learning or any other sponsor other than a
Business Organization with whom the City of Alamo Heights may engage in an
investment transaction. Thus, these independent sources will be training sessions
sponsored by Government Treasurers Organization of Texas (GTOT), University of
North Texas (UNT), Government Finance Officers Association of Texas (GFOAT),
Governmental Accounting and Finance Institute, Texas Municipal League (TML)
and Texas Association of Assesing Officers.
VII. Execution of Security Transactions
A. Selection of Banks and Authorized Financial Dealers and Institutions
Depository
City Council shall, by ordinance, “select and designate one or more banking
institutions as the depository for the monies and funds of the City” in accordance
with the requirement of Tex. Loc. Gov’t. Code ch. 105. The bank shall be selected
primarily on “solvency and stability” and secondly, on rate of interest available.
The City Finance Director shall conduct a comprehensive review of prospective
depository’s credit characteristics and financial history.
The bank shall be selected through a formalized bidding process in response to the
City’s request for proposal (RFP) outlining all services required. A five-year period
will be the maximum term.
Banks, credit unions or financial institutions seeking to establish eligibility for the
City’s competitive certificate of deposit purchase program shall submit financial
statements, evidence of Federal insurance, and other information as required by the
City Finance Director.
Broker Dealers
A list will be maintained of the business organizations authorized by the City Council
to provide investment services. These may include “primary dealers” or regional
dealers that qualify under Securities and Exchange Commission Rule 15C3 1
(uniform net capital rule).
All business organizations desiring to become qualified bidders for investment
transactions must supply the following, as appropriate:
 Audited financial statements
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 6
 Proof of Financial Industry Regulatory Authority (FINRA) Central Registry
Department (CRD)
 Proof of state registration
 Completed broker/dealer questionnaire
 Certification signed by a qualified representative of the firm, of having
read and thoroughly reviewed the City’s investment policy and having
implemented reasonable procedures and controls in an effort to preclude
unauthorized investment transactions. (See Appendix B for an example)
A qualified representative of a business organization is a person who holds a
position with the organization, is authorized to act on behalf of the organization, and
who is:
 for organizations regulated or registered with a securities commission,
registered under the rules of the Financial Industry Regulatory Authority
(FINRA); or
 for state and national banks and savings banks, a member of the loan
committee or authorized by corporate resolution to act on behalf of and
bind the banking institution.
 for an investment pool, the person authorized by the elected official or
board with authority to administer the activities of the investment pool to
sign the written instrument on behalf of the investment.
The City Finance Director shall conduct a review of the financial condition and
registration of qualified business organizations interested in providing investment
services for the City once the Proposed Investment Policy has been approved. The
City Finance Director shall recommend three or more qualified bidders to the City
Council, which will then select qualified bidders to provide investment services for
the City for the next year.
B. Selection of Investments
It is the policy of the City to require competitive bidding for bank Certificates of
Deposits (C.D.’s), all individual security purchases and sales except for:
a) transactions with money market mutual funds and local government
investment pools (which are deemed to be made at prevailing market rates);
b) treasury and agency securities purchased at issue through an approved
broker/dealer or financial institution; or
c) automatic overnight “sweep” transactions with the City Depository.
At least three bids or offers must be solicited for all other transactions involving
individual securities. In situations where the exact security being offered is not
offered by other dealers, offers on the closest comparable investment may be used
to establish a fair market price for the security.
The City Finance Director shall conduct business with securities dealers approved
by the City Council or with banks selected as outlined in VII.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 7
C. Delivery vs. Payment
With the exception of mutual funds, all investment transactions will be executed by
delivery vs. payment (DVP). This requires that the release of funds and the receipt
of the investment occur simultaneously.
D. Safekeeping
The City will utilize an independent third party as a custodial agent for safekeeping
of the City’s investments. Book entry only securities may be held in the custodial
agent’s account with a Federal Reserve Bank, as long as the custodial agent’s
internal records clearly indicate the City’s ownership of the securities. Any physical
securities will be transferred directly to the custodial agent.
Receipts must be issued by the custodial agent for all property received in physical
or book entry form. Not less than quarterly, the City should be provided with reports
of all assets held in safekeeping.
E. Measuring Market Value
The City shall use The Wall Street Journal or a comparable nationally recognized
business publication to measure the market value of its investments. The price
quote used will be as of the date of market valuation.
VIII. Internal Controls and Compliance Audit
A. Internal Controls
The City Finance Director is responsible for establishing and maintaining an internal
control structure designed to ensure that the assets of the City are protected from
loss, theft or misuse. The internal control structure shall be designed to provide
reasonable assurance that these objectives are met. The concept of reasonable
assurance recognizes that (1) the cost of a control should not exceed the benefits
likely to be derived; and (2) the valuation of costs and benefits requires estimates
and judgments by management.
The internal control structure should address the following points:
 Control of collusion. Collusion is a situation where two or more
employees work in conjunction to defraud their employer.
 Separation of transaction authority from accounting and recordkeeping.
By separating the person who authorizes or performs the transactions
from the people who record or otherwise account for the transaction, a
separation of duties is achieved.
 Custodial safekeeping. Securities purchased from any bank or dealer
including appropriate collateral shall be placed with an independent third
party for custodial safekeeping.
 Avoidance of physical delivery securities. Book entry securities are much
easier to transfer and account for since actual delivery of a document
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 8
never takes place. Delivered securities must be properly safeguarded
against loss or destruction. The potential for fraud and loss increases
with physically delivered securities.
 Clear delegation of authority to subordinate staff members. Subordinate
staff members must have a clear understanding of their authority and
responsibilities to avoid improper actions. Clear delegation of authority
also preserves the internal control structure that is contingent on the
various staff positions and their respective responsibilities.
 Written confirmation of telephone transactions for investments and wire
transfers. Due to the potential for error and improprieties arising from
telephone transactions, all telephone transactions should be supported
by written communications and approved by the appropriate person.
Written communications may be via fax if on letterhead and the
safekeeping institution has a list of authorized signatures.
 Development of a wire transfer agreement with the lead bank or third
party custodial. This agreement should outline the various controls,
security provisions, and delineate responsibilities of each party making
and receiving wire transfers.
B. Annual Audit
The City Finance Director shall establish a process for annual independent review
by an external auditor to:
 assure compliance with policies and procedures, and
 review monthly investment reports.
This review is to be done in conjunction with the annual audit of the City’s financial
statements.
IX. Suitable and Authorized Investments
A. Investment Types
The following investments are permitted under this policy:
 Obligations of the United States government, its agencies and
instrumentalities, and government sponsoring enterprises, not to exceed
two years to stated maturity, excluding collateralized mortgage
obligations (CMOs);
 No-load, SEC registered money market funds, each approved specifically
before use by the City Council as part of the City’s depository contract.
 Fully insured or collateralized certificates of deposit from a bank or credit
union doing business in the United States State of Texas and under the
terms of a written depository agreement with that bank, not to exceed one
year to stated maturity.
 Demand deposits with state and national banks and savings banks.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 9
 Constant dollar Texas Local Government Investment Pools as defined by
the Public Funds Investment Act; and
If additional types of securities are approved for investment by public funds by state
statute; they will not be eligible for investment by the City until this policy has been
amended and the amended version approved by the City Council.
B. Collateralization
Certificates of deposit and all other deposits with banks and savings banks shall be
1) guaranteed or insured by the Federal Deposit Insurance Corporation or 2) fully
collateralized as required by the Public Funds Investment Act. In order to provide
an appropriate level of protection, the market value of the pledged security will be a
minimum of 102% of the amount on deposit plus accrued interest.
Substitution of collateral must be approved in writing by the City prior to the
substitution taking place.
Collateral will be held by an independent third party. A clearly marked safekeeping
receipt showing the securities pledged in the City’s name must be provided to the
City on a monthly basis.
C. Prohibited Investments
Any investment not specifically authorized by this policy is prohibited. Any
investment that is a derivative in nature, even though the underlying asset may meet
the guidelines established in this policy, is also prohibited.
D. Additional Qualifications by Investment Type:
1. Mutual Funds
As part of its overall cash management program, the City may utilize the
automatic investment sweep program offered by its depository bank. This
program will enable the City to eliminate idle cash balances in its checking
accounts, while ensuring that adequate cash is on hand to meet daily
requirements.
 For this purpose, the City is authorized to invest in a no-load money
market mutual fund, if the mutual fund: Securities and Exchange
Commission;
 Provides the City with a prospectus and any other information required
by the Securities Exchange Act of 1934 or the Investment Company Act
of 1940;
 Invests exclusively in obligations of the U.S. Treasury and/or repurchase
agreements fully collateralized by such obligations;
 Is continuously rated as AAA or its equivalent by at least one nationally
recognized rating service;
 Has a weighted average maturity of 60 days or less; and
 Required to have $1 net asset value per share.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 10
2. State Wide Investment Pools
State wide investment pools are separate legal entities established to invest
the funds of 2 or more other government entities. The investment pool
typically has its own management, and investment staff and provides a highly
liquid investment option. Investment pools are allowed to hold commercial
paper.
In order to be eligible to provide services to the City, investment pools must
meet all the requirements of state law as determined under Chapter 2256 of
the Government Code, as amended and the following requirements:
 Provide the City with an offering circular and other information required by
the Public Funds Investment Act;
 Provide investment transaction confirmations;
 Provide monthly detailed transaction and performance reports as specified
by state statute;
 Establish an advisory board composed of qualified members representing
participants and non-participants;
 Be continuously rated no lower than AAA or AAA-m or at an equivalent
rating by at least one nationally recognized rating service.
In addition to the preceding requirements, investment pools created to
function, as money market mutual funds must mark-to-market daily and must
stabilize at $1.
Investment in a particular pool will be made only after a thorough investigation
of the pool and approval by the City Council. The City Finance Director shall
conduct an annual review of the pools and recommend qualified pools to the
City Council, which will then select and adopt a list of approved pools.
With the exception of mortgage backed securities or any other derivative,
pools are permitted to invest in a broader range of investment instruments
than those authorized under this policy, provided those instruments are
authorized under the Public Funds Investment Act.
3. Broker Dealers – the City can use the following firms as broker dealers:
 Frost Bank including custody/safekeeping of securities
 Hilltop Securities
4. Investment Management Firm - the city does have the option of selecting
an investment management firm to manage a portion of the city’s investments
upon review and approval by the Finance Director, the City Manager and at
least one council member. The selection process will include review and
verification of references, compliance with the Public Funds Investment Act,
the city’s investment policy, review of management fees.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 11
X. Investment Parameters
A. Investment Management Style
Investment maturities are timed to correspond with anticipated cash requirements
and should be purchased at or near par. The City employs a passive management
style in which investments are expected to be held to maturity. This does not
preclude the use of active portfolio management techniques.
B. Diversification
At the time of purchase, investments will be selected to ensure that the City’s
portfolio is diversified by security type and institution as follows:
 No more than 100% in United States treasuries;
 No more than 80% in commercial paper
 No more than 35% in no-load money market mutual funds;
 No more than 100% in certificates of deposit with no more than 25% with
any one financial institution; and
 No more than 80% in savings bank deposits with no more than 50% with
any one financial institution.
 No more than 100% in authorized investment pools
C. Maximum Maturities
To the extent possible, the City will attempt to match its investments with anticipated
cash flow requirements.
Maximum allowable stated maturities are limited by investment type as follows:
 2 years for United States treasuries securities;
 1-year for certificates of deposit; and
 90 days for no-load money market mutual funds
 Maximum allowed maturity per the PFIA for local government pools which
is currently 365 days
The maximum weighted average maturity for the portfolio as a whole will be 365
days.
XI. Performance Standards
During an environment of stable interest rates, the portfolio should obtain a market
average rate of return. Since the City follows a passive investment strategy, the basis
used by the City Finance Director to determine whether market yields are being achieved
shall be the average 90-day Treasury for the month, as quoted in The Wall Street Journal
or comparable nationally recognized business publication.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 12
XII. Performance Evaluation and Reporting
The Finance Director shall submit quarterly reports to the City Council containing sufficient
information to permit an informed outside reader to evaluate the performance of the
investment program and consistent with statutory requirements. All reports shall be in
compliance with the Act. Market prices for market evaluations will be obtained from an
independent source.
The City Finance Director shall monitor on a weekly basis, the credit rating based on
independent information from a nationally recognized rating agency. If the security falls
below the minimum rating, the Director will notify the City Manager of the loss of rating,
the conditions affecting the rating and possible loss of principal along with liquidation
alternatives available for action within two weeks of the loss of rating.
For valuation purposes at year-end, investments with remaining maturities of one year or
less at time of purchase are accounted for at amortized cost. All other investments are
reported on the financial statements at fair value. The City uses market values as quoted
in the Wall Street Journal or a comparable nationally recognized publication to determine
fair value.
XIII. Investment Policy Adoption
The City’s Investment Policy shall be adopted annually by the City Council. The policy
and strategies shall be reviewed on an annual basis by the Finance Director, City Manager
and a member of the City Council as selected by the Mayor. A written resolution approving
the review and changes to the policy from the review will be passed and recorded by the
City Council.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 13
APPENDIX A: GLOSSARY
ACTIVE PORTFOLIO MANAGEMENT:
An approach to investment management
in which the investment officer actively
trades the portfolio to take advantage of
changing market conditions. This style
requires the investment officer to develop
a comprehensive economic outlook and
to take actions based upon that outlook.
Requires relatively technical knowledge
of the investment field.
ASK PRICE: The price at which
securities are offered.
BASIS POINT: A unit of measurement
used in the valuation of fixed-income
securities equal to 1/100 of a percent of
yield. E.g., “1/4” of 1 percent is equal to
25 basis points.
BENCHMARKS: A measure used to
evaluate the effectiveness of the
investment program. Suitable
benchmarks are readily available and
share the characteristics of the portfolio
with respect to legal constraints and
investment policy compliance.
Benchmarks may be published figures or
indexes in publications such as the Wall
Street Journal or they may be specially
created for the entity.
BID: The indicated price at which a
buyer is willing to purchase a security or
commodity.
BOOK VALUE: The value at which a
security is carried on the inventory lists or
financial records of an investor. The
book value may differ significantly from
the security’s current value in the market.
BOOK ENTRY SECURITIES: Securities
that are purchased, sold and held with
only electronic computer entries rather
than the transfer of physical certificates.
Buyers typically receive receipts or
confirmations as evidence of ownership.
BROKER: A party who brings buyers
and sellers together. Brokers do not take
ownership of the property being traded.
They are compensated by commissions.
CALLABLE BOND: A bond issue in
which all or part of its outstanding
principal amount may be redeemed
before maturity by the issuer under
specified conditions.
CALL PRICE: The price at which an
issuer may redeem a bond prior to
maturity. The price is usually at a slight
premium to the bond’s original issue
price to compensate the holder for loss of
income and ownership.
CALL RISK: The risk to a bondholder
that a bond may be redeemed prior to
maturity.
CERTIFICATE OF DEPOSIT (CD): A
time deposit with a specific maturity
evidenced by a certificate. Large-
denomination CD’s are typically
negotiable.
COLLATERAL: Securities that a
borrower pledges to secure repayment of
a loan. Also refers to securities pledged
by a bank to secure deposits of public
monies.
COUPON RATE: The annual rate of
interest received by an investor from the
issuer of certain types of fixed income
securities. Also known as “interest rate”.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 14
CREDIT QUALITY: The measurement
of the financial strength of a bond issuer.
This measurement helps an investor to
understand an issue’s ability to make
timely interest payments and repay the
loan principal upon maturity. Generally,
the higher the credit quality of a bond
issuer, the lower the interest rate paid by
the issuer because the risk of default is
lower. Credit quality ratings are provided
by nationally recognized rating agencies.
CREDIT RISK: The risk to an investor
that an issuer will default in the payment
of interest and/or principal on a security.
CURRENT YIELD (CURRENT
RETURN): A yield calculation
determined by dividing the annual
interest received on a security by the
current market price of that security.
DEALER: A firm or an individual who
buys and sells for his own account.
Dealers have ownership, even if only for
an instant, between a purchase from one
party and a sale to another party. They
are compensated by the spread between
the price they pay and the price they
receive.
DELIVERY VERSUS PAYMENT: There
are two methods of delivery of securities:
delivery versus payment and delivery
versus receipt (also called free). Delivery
versus payment is delivery of securities
with an exchange of money for the
securities. Delivery versus receipt is the
delivery of securities with an exchange of
a signed receipt for the securities.
DERIVATIVES: Financial instruments
whose value depends on the values of
underlying assets or indexes are
registered with and regulated by the
SEC.
DISCOUNT: The amount by which the
par value of a security exceeds the price
paid for the security.
FAIR VALUE: The amount at which an
investment could be exchanged in a
current transaction between willing
parties, other than in a forced or
liquidation sale.
FEDERAL HOME LOAN BANKS
(FHLB): The institutions that regulate
and lend to savings and loan
associations. The Federal Home Loan
Banks play a role analogous to that
played by the Federal Reserve Banks
vis-à-vis member commercial banks.
FEDERAL NATIONAL MORTGAGE
ASSOCIATION (FNMA): FNMA, like
GNMA, was chartered under the Federal
National Mortgage Association Act in
1938. FNMA is a federal corporation
working under the auspices of the
Department of Housing and Urban
Development, HUD. It is the largest
single provider of residential mortgage
funds in the United States. Fannie Mae,
as the corporation is called, is a private
stockholder-owned corporation. The
corporation’s purchases include a variety
of adjustable mortgages and second
loans in addition to fixed-rate mortgages.
FNMA’s securities are also highly liquid
and are widely accepted. FNMA
assumes and guarantees that all security
holders will receive timely payment of
principal and interest.
GOVERNMENT NATIONAL
MORTGAGE ASSOCIATION (GNMA):
Securities guaranteed by GNMA and
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 15
issued by mortgage bankers, commercial
banks, savings and loan associations,
and other institutions. Security holder is
protected by full faith and credit of the
U.S. Government. GNMA securities are
backed by FHA, VA or FMHM
mortgages. The term pass through is
often used to describe GNMA.
GOVERNMENT SECURITIES: An
obligation of the U.S. government,
backed by the full faith and credit of the
government. These securities are
regarded as the highest quality of
investment securities available in the US
securities market.
INTEREST RATE RISK: The risk
associated with declines or rises in
interest rates, which cause an investment
in a fixed-income security to increase or
decrease in value.
LIQUIDITY: A liquid asset is one that
can be converted easily and rapidly into
cash without a substantial loss of value.
In the money market, a security is said to
be liquid if the spread between bid and
asked prices is narrow and reasonable
size can be done at those quotes.
LOCAL GOVERNMENT INVESTMENT
POOL (LGIP): An investment by local
governments in which their money is
pooled as a method for managing local
funds.
MARKET RISK: The risk that the value
of a security will rise or decline as a result
of changes in market conditions.
MARKET VALUE: The price at which a
security is trading and could presumably
be purchased or sold.
MONEY MARKET: The market in which
short-term debt instruments (bills,
commercial paper, bankers’
acceptances, etc.) are issued and traded.
MONEY MARKET MUTUAL FUND:
Mutual funds that invest solely in money
market instruments.
MUTUAL FUND: An investment
company that pools money and can
invest in a variety of securities, including
fixed-income securities and money
market instruments. The Investment
Company Act of 1940 regulates mutual
funds.
NATIONAL ASSOCIATION OF
SECURITIES DEALERS (NASD): A
self-regulatory organization (SRO) of
brokers and dealers in the over-the-
counter securities business. Its
regulatory mandate includes authority
over firms that distribute mutual fund
shares as well as other securities.
NET ASSET VALUE: The market value
of one share of an investment company,
such as a mutual fund. This figure is
calculated by totaling a fund’s assets
which includes securities, cash, and any
accrued earnings, subtracting this from
the fund’s liabilities and dividing this total
by the number of shares outstanding.
This is calculated once a day based on
the closing price for each security in the
fund’s portfolio.
PAR: Face value or principal value of a
bond, typically $1,000 per bond.
PASSIVE INVESTMENT
MANAGEMENT: An approach to
investment management in which the
investment officer adopts a buy and hold
strategy. Some investment techniques
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 16
are used. Requires basic level
investment knowledge.
PREMIUM: The amount by which the
price paid for a security exceeds the
security’s par value.
PRIMARY DEALERS: A group of
securities dealers who are recognized as
major participants in the government
securities markets and who are willing to
market all government securities.
Primary dealers must submit daily
reports of market activity and positions
and monthly financial statements to the
Federal Reserve Bank of New York and
are subject to its oversight.
RATE OF RETURN: The yield
obtainable on a security based on its
purchase price or its current market
price.
REGIONAL DEALERS: The second tier
of broker/dealers (after primary dealers)
composed of brokerage firms that
specialize in certain market niches,
typically on a regional basis.
SAFEKEEPING: Holding of assets (e.g.
securities) by a financial institution.
SAVINGS BANK DEPOSITS: Demand
deposits held in an account at a savings
and loan association.
SECONDARY MARKET: A market
made for the purchase and sale of
outstanding debt issues following the
initial distribution.
TREASURY BILLS: Short term
obligations issued by the United States
Treasury. Bills are issued for maturities
of one year or less. They do not pay
interest but are issued on a discount
basis instead.
TREASURY NOTES: Medium term
obligations issued by the United States
Treasury. Notes are issued for initial
maturities over 1 to 10 years.
WEIGHTED AVERAGE MATURITY
(WAM): The average maturity of all the
securities that comprise a portfolio.
According to SEC rule 2A-7, the WAM for
SEC registered money market mutual
funds may not exceed 90 days and no
one security may have a maturity that
exceeds 397 days.
YIELD: The annual return on an
investment expressed as a percentage.
YIELD TO CALL (YTC): The rate of
return an investor earns from a bond
assuming the bond is redeemed (called
prior to its nominal maturity date. Yield
Curve-A graphic representation that
depicts the relationship at a given point in
time between yields and maturity for
bonds that are identical in every way
except maturity. A normal yield curve
may be alternatively referred to a positive
yield curve.
YIELD TO MATURITY: The rate of
return yielded by a debt security held to
maturity when both interest payments
and the investor’s potential capital gain or
loss is included in the calculation or
return.
Attachment A
City of Alamo Heights, Texas
Investment Policy
Page 17
APPENDIX B: ILLUSTRATIVE BROKER/DEALER
Texas Public Funds Investment Act
Certification by Dealer
This certification is executed on behalf of _____________________________________
(the Investor) and ______________________________________ (the Dealer) pursuant
to the Public Funds Investment Act, Chapter 2256, Government Code, Texas Codes
Annotated (the Act) in connection with investment transactions conducted between the
Investor and Dealer.
The undersigned Qualified Representative of the Dealer hereby certifies on behalf of the
Dealer that:
1. The Dealer Qualified Representative is duly authorized to execute this Certification on
behalf of the Dealer, and
2. The Dealer Qualified Representative has received and reviewed the Investment Policy
furnished by the Investor, and
3. The Dealer has implemented reasonable procedures and controls in an effort to
preclude investment transactions conducted between the Dealer and the Investor that
are not authorized by the entity's investment policy, except to the extent that this
authorization is dependent on an analysis of the makeup of the entity's entire portfolio
or requires an interpretation of subjective investment standards.
Dealer Qualified Representative
Signature
Name (Printed)
Title
Date
Attachment A
Attachment B
RESOLUTION NO. 2023R - 160
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ALAMO
HEIGHTS, TEXAS ADOPTING THE CITY OF ALAMO HEIGHTS
INVESTMENT POLICY AS REQUIRED BY TEXAS PUBLIC FUNDS
INVESTMENT ACT AND DESIGNATING INVESTMENT OFFICERS
FOR THE CITY; AND SETTING AN EFFECTIVE DATE.
WHEREAS, in accordance with the Public Funds Investment Act, Chapter 2256, Texas
Government Code, the City Council of the City of Alamo Heights (City), Texas is required to
adopt an investment policy by resolution and the governing body of an investing entity must
review its investment policy on an annual basis: and
WHEREAS, the Public Funds Investment Act requires certain City officials to be deemed
investment officers to attend investment training; and
WHEREAS, the investment policy must be written and the basic provisions and Texas
Government Code 2256 requires that investments be made with judgment and care, under
prevailing circumstances, that a person of prudence, discretion, and intelligence would exercise
in the management of the person’s own affairs, not for speculation, but for investment,
considering the probable safety of capital and the probable income to be derived; and
WHEREAS, the attached investment policy complies with the Public Funds Investment Act, and
authorizes the investment of city funds in safe and prudent investments;
BE IT RESOLVED BY THE CITY COUNCIL OF ALAMO HEIGHTS, TEXAS:
Section 1. That the Investment Policy attached hereto is hereby adopted as the Investment Policy
of the City of Alamo Heights with Robert Galindo, Finance Director, and Buddy Kuhn, City
Manager, designated as Investment Officers of the City to make investment decisions and execute
needed documents for city investments.
Section 2. This Resolution shall become effective as of the date of passage.
PASSED AND APPROVED this 9th day of JANUARY, 2023.
BOBBY ROSENTHAL, MAYOR
ATTEST:
ELSA T. ROBLES, CITY SECRETARY
APPROVED AS TO FORM:
FRANK J. GARZA, CITY ATTORNEY

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Item # 5 - City Investment Policy

  • 1. CITY OF ALAMO HEIGHTS ADMINISTRATION AND FINANCE DEPARTMENT CITY COUNCIL AGENDA MEMORANDUM TO: Mayor and City Council FROM: Robert Galindo, Director of Finance SUBJECT: A Resolution Adopting the City’s Investment Policy DATE: January 9, 2023 SUMMARY Adoption of this resolution acknowledges that the investment policy has been reviewed and any necessary changes have been made to the investment policy. BACKGROUND INFORMATION The City’s Investment Policy is reviewed each fiscal year. Texas Government Code, Chapter 2256, known as the Public Funds Investment Act (PFIA), establishes requirements for local governments to manage the risks involved in investment of public funds. The PFIA requires:  a written strategy;  annual review and adoption of strategy;  designate an investment officer;  disclose personal/business relationships;  provide policy for written certification;  obtain annual management audit;  provide for training; and  report quarterly to management. Texas Government Code 2256 requires that investments be made with judgment and care, under prevailing circumstances, that a person of prudence, discretion, and intelligence would exercise in the management of the person’s own affairs, not for speculation, but for investment, considering the probable safety of capital and the probable income to be derived. Investment of funds shall be governed by the following objectives, in order of priority: preservation and safety of principal, liquidity, and last of all yield. Texas Government Code requires a written strategy for investment of all financial assets of the City. It limits investments to government backed securities such as U.S. Treasuries, U.S. Agencies/Instrumentalities, Money Market Funds, Mutual Funds, Investment Pools and Certificates of Deposit which are insured by the Federal Deposit Insurance Corporation in order to protect the safety of principal. To meet the requirement of liquidity, an analysis of the City’s cash flows to identify needs and deficits must be made. Investments maturity and marketability must be matched to ensure those needs are met. Yield is the last priority.
  • 2. POLICY ANALYSIS The City’s Investment Policy is conservative but allows investing in a manner which will provide the highest reasonable yield with maximum security while meeting daily cash flow needs and conforms to all state and local statutes. Section 2256.005 of the Texas Public Funds Investment Act requires the governing body of an investing entity to review its investment policy and investment strategies on an annual basis even if no changes are made. The governing body shall adopt a written instrument by rule, order, ordinance, or resolution stating that it has reviewed the investment policy and investment strategies and that the written instrument so adopted shall record any changes made to either the investment policy or investment strategies. The policy has been reviewed by the Finance Director, City Manager and CM Savage. FISCAL IMPACT Investment strategies create a performing asset by putting money to work, assuring cash efficiency and security, adding yield while minimizing risk to the City’s portfolio. ATTACHMENTS Attachment A – City of Alamo Heights Investment Policy Attachment B – Resolution ______________________ Robert Galindo Director of Finance ______________________ Buddy Kuhn City Manager
  • 3. City of Alamo Heights, Texas Investment Policy January 9, 2023 Attachment A
  • 4. City of Alamo Heights, Texas Investment Policy TABLE OF CONTENTS I. Purpose............................................................................................................. 1 II Statutory Authority ............................................................................................. 1 III. Policy Scope...................................................................................................... 1 IV. Investment Strategy Statement.......................................................................... 1 V. Investment Objectives ....................................................................................... 2 A. Suitability of Investments B. Preservation and Safety of Capital C. Liquidity D. Marketability of Investments E. Diversification F. Yield VI. Standards of Care.............................................................................................. 4 A. Prudence B. Ethics and Conflicts of Interest C. Delegation of Authority D. Training VII. Execution of Security Transactions.................................................................... 5 A. Authorized Financial Dealers and Institutions B. Selection of Investments C. Delivery vs. Payment D. Safekeeping E. Measuring Market Value VIII. Internal Controls and Annual Audit .................................................................... 7 A. Internal Controls B. Annual Audit IX. Suitable and Authorized Investments................................................................. 8 A. Investment Types B. Collateralization C. Prohibited Investments D. Authorized Investments: Mutual Funds X. Investment Parameters.................................................................................... 11 A. Investment Management Style B. Diversification C. Maximum Maturities Attachment A
  • 5. City of Alamo Heights, Texas Investment Policy TABLE OF CONTENTS (CONTINUED) XI. Performance Standards................................................................................... 11 XII. Performance Evaluation and Reporting ........................................................... 12 Appendix A: Glossary ............................................................................................. 13 Appendix B: Illustrative Broker/Dealer Certification Form........................................ 17 Attachment A
  • 6. City of Alamo Heights, Texas Investment Policy Page 1 I. Purpose The purpose of this document is to establish the investment policies for the management of the public funds of the City of Alamo Heights, Texas (City). This policy will be reviewed on an annual basis by City Council. At such time, the council will adopt a resolution that (1) states that the investment policy has been reviewed and (2) enumerates the changes to be made to the policy. These policies are designed to ensure the prudent management of public funds, the availability of operating and capital funds when needed, and an investment return competitive with those of comparable funds and financial market indexes. A copy of this statement will be provided to all business organizations offering to engage in investment transactions with the City. A qualified representative of the business organization must confirm in writing (1) that this policy has been read and thoroughly reviewed and (2) that reasonable controls have been established to preclude unauthorized investment transactions. This confirmation must be received by the City prior to the firm providing any services. II. Statutory Authority This policy was adopted in accordance with the Public Funds Investment Act (V.T.C.A., Government Code §2256). III. Policy Scope This investment policy applies to all of the financial assets (i.e., cash, bank deposits and securities) of the City. These assets are pooled into a single common investment fund that incorporates the following accounting fund types:  Governmental Funds including debt service reserves and sinking funds, to the extent not required by law or existing contract to be kept segregated and managed separately;  Proprietary Funds;  Fiduciary Funds; and  To include any new funds created by the City unless specifically exempted by the City Council and this policy. Investments in the City’s employee pension and deferred compensation plans are independently managed and are not covered by this policy. IV. Investment Strategy Statement It is the City’s policy to invest public funds in a manner that meets the following objectives:  Ensure the suitability of the investment to the financial requirements of the City;  Ensure preservation and safety of capital; Attachment A
  • 7. City of Alamo Heights, Texas Investment Policy Page 2  Provide sufficient liquidity to meet cash flow needs;  Ensure the marketability of the investments;  Provide sufficient diversification; and  Provide a competitive return on investment. V. Investment Objectives The following is a detailed discussion of the City’s investment objectives, in priority order: A. Suitability of Investments Investments shall be made with the primary focus of having cash available to meet the City’s financial requirements. This requires that the City match investment maturities with anticipated expenditures. Annually, budgeted revenues closely approximate budgeted expenditures; however, property taxes, the City’s primary revenue source, are cyclical in nature. This creates large cash balances during the months of December through March, which must be invested until required later in the year to finance the City’s operating activities. B. Preservation and Safety of Capital Investments shall be undertaken in a manner that seeks to ensure the preservation of capital in the overall portfolio. To achieve this objective it is necessary to minimize credit risk and interest rate risk. Credit risk is the risk of loss due to failure of the security issuer to pay interest and/or principal in a timely manner. It may be reduced by:  Limiting investments to the safest types of securities;  Pre-qualifying the business organizations with which the City will do business; and  Requiring that investments not insured or guaranteed by the United States government be fully collateralized. Interest rate risk is the risk that the market value of securities in the portfolio will fall due to changes in general interest rates. The longer the term, the more tendency there is for rates to fluctuate. Interest rate risk may be reduced by:  Structuring the investment portfolio so that securities mature to meet cash requirements for ongoing operations, thereby avoiding the need to sell securities on the open market prior to maturity; and  Investing primarily in shorter-term securities, money market mutual funds, or similar investment pools. Both types of risk may also be controlled through diversification. C. Liquidity It is the City’s objective that the investment portfolio shall remain sufficiently liquid to meet all operating requirements that may be reasonably anticipated. Attachment A
  • 8. City of Alamo Heights, Texas Investment Policy Page 3 Liquidity is the relative ease with which a security may be converted to cash, typically through sale on the open market. The goals of liquidity and preservation of capital may conflict at times. While a security may be easily converted to cash, the amount of cash received may be less than the amount initially paid due to fluctuations in market value. For that reason, it is important for the portfolio to be structured so that securities mature concurrent with anticipated cash needs, hereby avoiding the need to liquidate investments under adverse market conditions. D. Marketability of Investments Marketability is the ability to quickly purchase and sell a security at competitive prices in secondary markets. Some investments, such as Treasury bills, can be sold at any time. Other more exotic instruments may not be much in demand by other investors and, consequently, may be much harder to sell. Since all possible cash demands cannot be anticipated, the portfolio should consist of securities with active secondary or resale markets. This will ensure that in the event the City must sell a security, a buyer can be readily found. At times, selling a security before maturity may produce a loss. With the exception of the following situations, securities shall not be sold at a loss:  A security with a declining market value could be sold early to minimize loss;  A security swap would improve the quality, yield, or target duration in the portfolio; or  Liquidity needs of the portfolio require that a security be sold and all other sales would result in a larger loss. E. Diversification The constraints established by this investment policy minimize the City’s risk exposure. Through diversification, the City can further limit risk exposure. The City will address diversification in its portfolio by limiting its exposure to any one type of investment, staggering investment maturities, and using several investment providers. F. Yield A fundamental rule of investments is that risk equals return. The City has deliberately established a low risk threshold in order to protect its financial resources and ensure that cash is available when needed. Return on investment is the least important objective of the City’s investment program. It is anticipated, however, that the City will still earn a competitive rate of return given the level of risk assumed. Attachment A
  • 9. City of Alamo Heights, Texas Investment Policy Page 4 VI. Standards of Care A. 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 portfolio, not each investment decision. Investment officers acting in accordance with this investment policy and exercising due diligence shall be relieved of personal responsibility for an individual security’s credit risk or market price changes, provided that the investment decision was consistent with this written policy. The “prudent person” standard requires 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 capital as well as the probable income to be derived. B. Ethics and Conflicts of Interest Employees involved in the investment process shall refrain from personal business activity that could conflict with the proper execution and management of the investment program, or that could impair their ability to make impartial decisions. Employees and investment officials shall disclose any material interests in financial institutions with which they conduct business. They shall further disclose any personal investment positions that could be related to the performance of the investment portfolio. Employees and officers shall refrain from undertaking personal investment transactions with the same individual with which business is conducted on behalf of the City. Any investment officer who is related within the second degree by affinity or consanguinity as determined under the Tex. Gov’t Code Ann. Ch. 573 to an individual seeking to sell an investment to the City shall file a statement disclosing that relationship with the City Council and the Texas Ethics Commission. C. Delegation of Authority The City Finance Director and the City Manager are hereby designated Investment Officers of the City. Authority to manage the investment program is granted to the City Finance Director. No person may engage in investment transactions except as provided under the terms of this policy and the procedures established by the City Finance Director. The City Finance Director shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. D. Training The City Finance Director and the City Manager shall attend at least one training session related to their respective duties within 12 months of assuming office or duties. This training must include education in investment controls, security risks, strategy risks, market risks and compliance with the Public Funds Investment Act. Attachment A
  • 10. City of Alamo Heights, Texas Investment Policy Page 5 After the initial training session, both the City Finance Director and the City Manager shall receive a minimum of 8 hours of training as required by state law, which is designed to ensure the continued proper performance of their duties under this policy and the Public Funds Investment Act. The training provider must be an independent provider. For purposes of this policy, an “independent source” from which investment training shall be obtained shall include a professional organization, an institute of higher learning or any other sponsor other than a Business Organization with whom the City of Alamo Heights may engage in an investment transaction. Thus, these independent sources will be training sessions sponsored by Government Treasurers Organization of Texas (GTOT), University of North Texas (UNT), Government Finance Officers Association of Texas (GFOAT), Governmental Accounting and Finance Institute, Texas Municipal League (TML) and Texas Association of Assesing Officers. VII. Execution of Security Transactions A. Selection of Banks and Authorized Financial Dealers and Institutions Depository City Council shall, by ordinance, “select and designate one or more banking institutions as the depository for the monies and funds of the City” in accordance with the requirement of Tex. Loc. Gov’t. Code ch. 105. The bank shall be selected primarily on “solvency and stability” and secondly, on rate of interest available. The City Finance Director shall conduct a comprehensive review of prospective depository’s credit characteristics and financial history. The bank shall be selected through a formalized bidding process in response to the City’s request for proposal (RFP) outlining all services required. A five-year period will be the maximum term. Banks, credit unions or financial institutions seeking to establish eligibility for the City’s competitive certificate of deposit purchase program shall submit financial statements, evidence of Federal insurance, and other information as required by the City Finance Director. Broker Dealers A list will be maintained of the business organizations authorized by the City Council to provide investment services. These may include “primary dealers” or regional dealers that qualify under Securities and Exchange Commission Rule 15C3 1 (uniform net capital rule). All business organizations desiring to become qualified bidders for investment transactions must supply the following, as appropriate:  Audited financial statements Attachment A
  • 11. City of Alamo Heights, Texas Investment Policy Page 6  Proof of Financial Industry Regulatory Authority (FINRA) Central Registry Department (CRD)  Proof of state registration  Completed broker/dealer questionnaire  Certification signed by a qualified representative of the firm, of having read and thoroughly reviewed the City’s investment policy and having implemented reasonable procedures and controls in an effort to preclude unauthorized investment transactions. (See Appendix B for an example) A qualified representative of a business organization is a person who holds a position with the organization, is authorized to act on behalf of the organization, and who is:  for organizations regulated or registered with a securities commission, registered under the rules of the Financial Industry Regulatory Authority (FINRA); or  for state and national banks and savings banks, a member of the loan committee or authorized by corporate resolution to act on behalf of and bind the banking institution.  for an investment pool, the person authorized by the elected official or board with authority to administer the activities of the investment pool to sign the written instrument on behalf of the investment. The City Finance Director shall conduct a review of the financial condition and registration of qualified business organizations interested in providing investment services for the City once the Proposed Investment Policy has been approved. The City Finance Director shall recommend three or more qualified bidders to the City Council, which will then select qualified bidders to provide investment services for the City for the next year. B. Selection of Investments It is the policy of the City to require competitive bidding for bank Certificates of Deposits (C.D.’s), all individual security purchases and sales except for: a) transactions with money market mutual funds and local government investment pools (which are deemed to be made at prevailing market rates); b) treasury and agency securities purchased at issue through an approved broker/dealer or financial institution; or c) automatic overnight “sweep” transactions with the City Depository. At least three bids or offers must be solicited for all other transactions involving individual securities. In situations where the exact security being offered is not offered by other dealers, offers on the closest comparable investment may be used to establish a fair market price for the security. The City Finance Director shall conduct business with securities dealers approved by the City Council or with banks selected as outlined in VII. Attachment A
  • 12. City of Alamo Heights, Texas Investment Policy Page 7 C. Delivery vs. Payment With the exception of mutual funds, all investment transactions will be executed by delivery vs. payment (DVP). This requires that the release of funds and the receipt of the investment occur simultaneously. D. Safekeeping The City will utilize an independent third party as a custodial agent for safekeeping of the City’s investments. Book entry only securities may be held in the custodial agent’s account with a Federal Reserve Bank, as long as the custodial agent’s internal records clearly indicate the City’s ownership of the securities. Any physical securities will be transferred directly to the custodial agent. Receipts must be issued by the custodial agent for all property received in physical or book entry form. Not less than quarterly, the City should be provided with reports of all assets held in safekeeping. E. Measuring Market Value The City shall use The Wall Street Journal or a comparable nationally recognized business publication to measure the market value of its investments. The price quote used will be as of the date of market valuation. VIII. Internal Controls and Compliance Audit A. Internal Controls The City Finance Director is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the City are protected from loss, theft or misuse. The internal control structure shall be designed to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognizes that (1) the cost of a control should not exceed the benefits likely to be derived; and (2) the valuation of costs and benefits requires estimates and judgments by management. The internal control structure should address the following points:  Control of collusion. Collusion is a situation where two or more employees work in conjunction to defraud their employer.  Separation of transaction authority from accounting and recordkeeping. By separating the person who authorizes or performs the transactions from the people who record or otherwise account for the transaction, a separation of duties is achieved.  Custodial safekeeping. Securities purchased from any bank or dealer including appropriate collateral shall be placed with an independent third party for custodial safekeeping.  Avoidance of physical delivery securities. Book entry securities are much easier to transfer and account for since actual delivery of a document Attachment A
  • 13. City of Alamo Heights, Texas Investment Policy Page 8 never takes place. Delivered securities must be properly safeguarded against loss or destruction. The potential for fraud and loss increases with physically delivered securities.  Clear delegation of authority to subordinate staff members. Subordinate staff members must have a clear understanding of their authority and responsibilities to avoid improper actions. Clear delegation of authority also preserves the internal control structure that is contingent on the various staff positions and their respective responsibilities.  Written confirmation of telephone transactions for investments and wire transfers. Due to the potential for error and improprieties arising from telephone transactions, all telephone transactions should be supported by written communications and approved by the appropriate person. Written communications may be via fax if on letterhead and the safekeeping institution has a list of authorized signatures.  Development of a wire transfer agreement with the lead bank or third party custodial. This agreement should outline the various controls, security provisions, and delineate responsibilities of each party making and receiving wire transfers. B. Annual Audit The City Finance Director shall establish a process for annual independent review by an external auditor to:  assure compliance with policies and procedures, and  review monthly investment reports. This review is to be done in conjunction with the annual audit of the City’s financial statements. IX. Suitable and Authorized Investments A. Investment Types The following investments are permitted under this policy:  Obligations of the United States government, its agencies and instrumentalities, and government sponsoring enterprises, not to exceed two years to stated maturity, excluding collateralized mortgage obligations (CMOs);  No-load, SEC registered money market funds, each approved specifically before use by the City Council as part of the City’s depository contract.  Fully insured or collateralized certificates of deposit from a bank or credit union doing business in the United States State of Texas and under the terms of a written depository agreement with that bank, not to exceed one year to stated maturity.  Demand deposits with state and national banks and savings banks. Attachment A
  • 14. City of Alamo Heights, Texas Investment Policy Page 9  Constant dollar Texas Local Government Investment Pools as defined by the Public Funds Investment Act; and If additional types of securities are approved for investment by public funds by state statute; they will not be eligible for investment by the City until this policy has been amended and the amended version approved by the City Council. B. Collateralization Certificates of deposit and all other deposits with banks and savings banks shall be 1) guaranteed or insured by the Federal Deposit Insurance Corporation or 2) fully collateralized as required by the Public Funds Investment Act. In order to provide an appropriate level of protection, the market value of the pledged security will be a minimum of 102% of the amount on deposit plus accrued interest. Substitution of collateral must be approved in writing by the City prior to the substitution taking place. Collateral will be held by an independent third party. A clearly marked safekeeping receipt showing the securities pledged in the City’s name must be provided to the City on a monthly basis. C. Prohibited Investments Any investment not specifically authorized by this policy is prohibited. Any investment that is a derivative in nature, even though the underlying asset may meet the guidelines established in this policy, is also prohibited. D. Additional Qualifications by Investment Type: 1. Mutual Funds As part of its overall cash management program, the City may utilize the automatic investment sweep program offered by its depository bank. This program will enable the City to eliminate idle cash balances in its checking accounts, while ensuring that adequate cash is on hand to meet daily requirements.  For this purpose, the City is authorized to invest in a no-load money market mutual fund, if the mutual fund: Securities and Exchange Commission;  Provides the City with a prospectus and any other information required by the Securities Exchange Act of 1934 or the Investment Company Act of 1940;  Invests exclusively in obligations of the U.S. Treasury and/or repurchase agreements fully collateralized by such obligations;  Is continuously rated as AAA or its equivalent by at least one nationally recognized rating service;  Has a weighted average maturity of 60 days or less; and  Required to have $1 net asset value per share. Attachment A
  • 15. City of Alamo Heights, Texas Investment Policy Page 10 2. State Wide Investment Pools State wide investment pools are separate legal entities established to invest the funds of 2 or more other government entities. The investment pool typically has its own management, and investment staff and provides a highly liquid investment option. Investment pools are allowed to hold commercial paper. In order to be eligible to provide services to the City, investment pools must meet all the requirements of state law as determined under Chapter 2256 of the Government Code, as amended and the following requirements:  Provide the City with an offering circular and other information required by the Public Funds Investment Act;  Provide investment transaction confirmations;  Provide monthly detailed transaction and performance reports as specified by state statute;  Establish an advisory board composed of qualified members representing participants and non-participants;  Be continuously rated no lower than AAA or AAA-m or at an equivalent rating by at least one nationally recognized rating service. In addition to the preceding requirements, investment pools created to function, as money market mutual funds must mark-to-market daily and must stabilize at $1. Investment in a particular pool will be made only after a thorough investigation of the pool and approval by the City Council. The City Finance Director shall conduct an annual review of the pools and recommend qualified pools to the City Council, which will then select and adopt a list of approved pools. With the exception of mortgage backed securities or any other derivative, pools are permitted to invest in a broader range of investment instruments than those authorized under this policy, provided those instruments are authorized under the Public Funds Investment Act. 3. Broker Dealers – the City can use the following firms as broker dealers:  Frost Bank including custody/safekeeping of securities  Hilltop Securities 4. Investment Management Firm - the city does have the option of selecting an investment management firm to manage a portion of the city’s investments upon review and approval by the Finance Director, the City Manager and at least one council member. The selection process will include review and verification of references, compliance with the Public Funds Investment Act, the city’s investment policy, review of management fees. Attachment A
  • 16. City of Alamo Heights, Texas Investment Policy Page 11 X. Investment Parameters A. Investment Management Style Investment maturities are timed to correspond with anticipated cash requirements and should be purchased at or near par. The City employs a passive management style in which investments are expected to be held to maturity. This does not preclude the use of active portfolio management techniques. B. Diversification At the time of purchase, investments will be selected to ensure that the City’s portfolio is diversified by security type and institution as follows:  No more than 100% in United States treasuries;  No more than 80% in commercial paper  No more than 35% in no-load money market mutual funds;  No more than 100% in certificates of deposit with no more than 25% with any one financial institution; and  No more than 80% in savings bank deposits with no more than 50% with any one financial institution.  No more than 100% in authorized investment pools C. Maximum Maturities To the extent possible, the City will attempt to match its investments with anticipated cash flow requirements. Maximum allowable stated maturities are limited by investment type as follows:  2 years for United States treasuries securities;  1-year for certificates of deposit; and  90 days for no-load money market mutual funds  Maximum allowed maturity per the PFIA for local government pools which is currently 365 days The maximum weighted average maturity for the portfolio as a whole will be 365 days. XI. Performance Standards During an environment of stable interest rates, the portfolio should obtain a market average rate of return. Since the City follows a passive investment strategy, the basis used by the City Finance Director to determine whether market yields are being achieved shall be the average 90-day Treasury for the month, as quoted in The Wall Street Journal or comparable nationally recognized business publication. Attachment A
  • 17. City of Alamo Heights, Texas Investment Policy Page 12 XII. Performance Evaluation and Reporting The Finance Director shall submit quarterly reports to the City Council containing sufficient information to permit an informed outside reader to evaluate the performance of the investment program and consistent with statutory requirements. All reports shall be in compliance with the Act. Market prices for market evaluations will be obtained from an independent source. The City Finance Director shall monitor on a weekly basis, the credit rating based on independent information from a nationally recognized rating agency. If the security falls below the minimum rating, the Director will notify the City Manager of the loss of rating, the conditions affecting the rating and possible loss of principal along with liquidation alternatives available for action within two weeks of the loss of rating. For valuation purposes at year-end, investments with remaining maturities of one year or less at time of purchase are accounted for at amortized cost. All other investments are reported on the financial statements at fair value. The City uses market values as quoted in the Wall Street Journal or a comparable nationally recognized publication to determine fair value. XIII. Investment Policy Adoption The City’s Investment Policy shall be adopted annually by the City Council. The policy and strategies shall be reviewed on an annual basis by the Finance Director, City Manager and a member of the City Council as selected by the Mayor. A written resolution approving the review and changes to the policy from the review will be passed and recorded by the City Council. Attachment A
  • 18. City of Alamo Heights, Texas Investment Policy Page 13 APPENDIX A: GLOSSARY ACTIVE PORTFOLIO MANAGEMENT: An approach to investment management in which the investment officer actively trades the portfolio to take advantage of changing market conditions. This style requires the investment officer to develop a comprehensive economic outlook and to take actions based upon that outlook. Requires relatively technical knowledge of the investment field. ASK PRICE: The price at which securities are offered. BASIS POINT: A unit of measurement used in the valuation of fixed-income securities equal to 1/100 of a percent of yield. E.g., “1/4” of 1 percent is equal to 25 basis points. BENCHMARKS: A measure used to evaluate the effectiveness of the investment program. Suitable benchmarks are readily available and share the characteristics of the portfolio with respect to legal constraints and investment policy compliance. Benchmarks may be published figures or indexes in publications such as the Wall Street Journal or they may be specially created for the entity. BID: The indicated price at which a buyer is willing to purchase a security or commodity. BOOK VALUE: The value at which a security is carried on the inventory lists or financial records of an investor. The book value may differ significantly from the security’s current value in the market. BOOK ENTRY SECURITIES: Securities that are purchased, sold and held with only electronic computer entries rather than the transfer of physical certificates. Buyers typically receive receipts or confirmations as evidence of ownership. BROKER: A party who brings buyers and sellers together. Brokers do not take ownership of the property being traded. They are compensated by commissions. CALLABLE BOND: A bond issue in which all or part of its outstanding principal amount may be redeemed before maturity by the issuer under specified conditions. CALL PRICE: The price at which an issuer may redeem a bond prior to maturity. The price is usually at a slight premium to the bond’s original issue price to compensate the holder for loss of income and ownership. CALL RISK: The risk to a bondholder that a bond may be redeemed prior to maturity. CERTIFICATE OF DEPOSIT (CD): A time deposit with a specific maturity evidenced by a certificate. Large- denomination CD’s are typically negotiable. COLLATERAL: Securities that a borrower pledges to secure repayment of a loan. Also refers to securities pledged by a bank to secure deposits of public monies. COUPON RATE: The annual rate of interest received by an investor from the issuer of certain types of fixed income securities. Also known as “interest rate”. Attachment A
  • 19. City of Alamo Heights, Texas Investment Policy Page 14 CREDIT QUALITY: The measurement of the financial strength of a bond issuer. This measurement helps an investor to understand an issue’s ability to make timely interest payments and repay the loan principal upon maturity. Generally, the higher the credit quality of a bond issuer, the lower the interest rate paid by the issuer because the risk of default is lower. Credit quality ratings are provided by nationally recognized rating agencies. CREDIT RISK: The risk to an investor that an issuer will default in the payment of interest and/or principal on a security. CURRENT YIELD (CURRENT RETURN): A yield calculation determined by dividing the annual interest received on a security by the current market price of that security. DEALER: A firm or an individual who buys and sells for his own account. Dealers have ownership, even if only for an instant, between a purchase from one party and a sale to another party. They are compensated by the spread between the price they pay and the price they receive. DELIVERY VERSUS PAYMENT: There are two methods of delivery of securities: delivery versus payment and delivery versus receipt (also called free). Delivery versus payment is delivery of securities with an exchange of money for the securities. Delivery versus receipt is the delivery of securities with an exchange of a signed receipt for the securities. DERIVATIVES: Financial instruments whose value depends on the values of underlying assets or indexes are registered with and regulated by the SEC. DISCOUNT: The amount by which the par value of a security exceeds the price paid for the security. FAIR VALUE: The amount at which an investment could be exchanged in a current transaction between willing parties, other than in a forced or liquidation sale. FEDERAL HOME LOAN BANKS (FHLB): The institutions that regulate and lend to savings and loan associations. The Federal Home Loan Banks play a role analogous to that played by the Federal Reserve Banks vis-à-vis member commercial banks. FEDERAL NATIONAL MORTGAGE ASSOCIATION (FNMA): FNMA, like GNMA, was chartered under the Federal National Mortgage Association Act in 1938. FNMA is a federal corporation working under the auspices of the Department of Housing and Urban Development, HUD. It is the largest single provider of residential mortgage funds in the United States. Fannie Mae, as the corporation is called, is a private stockholder-owned corporation. The corporation’s purchases include a variety of adjustable mortgages and second loans in addition to fixed-rate mortgages. FNMA’s securities are also highly liquid and are widely accepted. FNMA assumes and guarantees that all security holders will receive timely payment of principal and interest. GOVERNMENT NATIONAL MORTGAGE ASSOCIATION (GNMA): Securities guaranteed by GNMA and Attachment A
  • 20. City of Alamo Heights, Texas Investment Policy Page 15 issued by mortgage bankers, commercial banks, savings and loan associations, and other institutions. Security holder is protected by full faith and credit of the U.S. Government. GNMA securities are backed by FHA, VA or FMHM mortgages. The term pass through is often used to describe GNMA. GOVERNMENT SECURITIES: An obligation of the U.S. government, backed by the full faith and credit of the government. These securities are regarded as the highest quality of investment securities available in the US securities market. INTEREST RATE RISK: The risk associated with declines or rises in interest rates, which cause an investment in a fixed-income security to increase or decrease in value. LIQUIDITY: A liquid asset is one that can be converted easily and rapidly into cash without a substantial loss of value. In the money market, a security is said to be liquid if the spread between bid and asked prices is narrow and reasonable size can be done at those quotes. LOCAL GOVERNMENT INVESTMENT POOL (LGIP): An investment by local governments in which their money is pooled as a method for managing local funds. MARKET RISK: The risk that the value of a security will rise or decline as a result of changes in market conditions. MARKET VALUE: The price at which a security is trading and could presumably be purchased or sold. MONEY MARKET: The market in which short-term debt instruments (bills, commercial paper, bankers’ acceptances, etc.) are issued and traded. MONEY MARKET MUTUAL FUND: Mutual funds that invest solely in money market instruments. MUTUAL FUND: An investment company that pools money and can invest in a variety of securities, including fixed-income securities and money market instruments. The Investment Company Act of 1940 regulates mutual funds. NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD): A self-regulatory organization (SRO) of brokers and dealers in the over-the- counter securities business. Its regulatory mandate includes authority over firms that distribute mutual fund shares as well as other securities. NET ASSET VALUE: The market value of one share of an investment company, such as a mutual fund. This figure is calculated by totaling a fund’s assets which includes securities, cash, and any accrued earnings, subtracting this from the fund’s liabilities and dividing this total by the number of shares outstanding. This is calculated once a day based on the closing price for each security in the fund’s portfolio. PAR: Face value or principal value of a bond, typically $1,000 per bond. PASSIVE INVESTMENT MANAGEMENT: An approach to investment management in which the investment officer adopts a buy and hold strategy. Some investment techniques Attachment A
  • 21. City of Alamo Heights, Texas Investment Policy Page 16 are used. Requires basic level investment knowledge. PREMIUM: The amount by which the price paid for a security exceeds the security’s par value. PRIMARY DEALERS: A group of securities dealers who are recognized as major participants in the government securities markets and who are willing to market all government securities. Primary dealers must submit daily reports of market activity and positions and monthly financial statements to the Federal Reserve Bank of New York and are subject to its oversight. RATE OF RETURN: The yield obtainable on a security based on its purchase price or its current market price. REGIONAL DEALERS: The second tier of broker/dealers (after primary dealers) composed of brokerage firms that specialize in certain market niches, typically on a regional basis. SAFEKEEPING: Holding of assets (e.g. securities) by a financial institution. SAVINGS BANK DEPOSITS: Demand deposits held in an account at a savings and loan association. SECONDARY MARKET: A market made for the purchase and sale of outstanding debt issues following the initial distribution. TREASURY BILLS: Short term obligations issued by the United States Treasury. Bills are issued for maturities of one year or less. They do not pay interest but are issued on a discount basis instead. TREASURY NOTES: Medium term obligations issued by the United States Treasury. Notes are issued for initial maturities over 1 to 10 years. WEIGHTED AVERAGE MATURITY (WAM): The average maturity of all the securities that comprise a portfolio. According to SEC rule 2A-7, the WAM for SEC registered money market mutual funds may not exceed 90 days and no one security may have a maturity that exceeds 397 days. YIELD: The annual return on an investment expressed as a percentage. YIELD TO CALL (YTC): The rate of return an investor earns from a bond assuming the bond is redeemed (called prior to its nominal maturity date. Yield Curve-A graphic representation that depicts the relationship at a given point in time between yields and maturity for bonds that are identical in every way except maturity. A normal yield curve may be alternatively referred to a positive yield curve. YIELD TO MATURITY: The rate of return yielded by a debt security held to maturity when both interest payments and the investor’s potential capital gain or loss is included in the calculation or return. Attachment A
  • 22. City of Alamo Heights, Texas Investment Policy Page 17 APPENDIX B: ILLUSTRATIVE BROKER/DEALER Texas Public Funds Investment Act Certification by Dealer This certification is executed on behalf of _____________________________________ (the Investor) and ______________________________________ (the Dealer) pursuant to the Public Funds Investment Act, Chapter 2256, Government Code, Texas Codes Annotated (the Act) in connection with investment transactions conducted between the Investor and Dealer. The undersigned Qualified Representative of the Dealer hereby certifies on behalf of the Dealer that: 1. The Dealer Qualified Representative is duly authorized to execute this Certification on behalf of the Dealer, and 2. The Dealer Qualified Representative has received and reviewed the Investment Policy furnished by the Investor, and 3. The Dealer has implemented reasonable procedures and controls in an effort to preclude investment transactions conducted between the Dealer and the Investor that are not authorized by the entity's investment policy, except to the extent that this authorization is dependent on an analysis of the makeup of the entity's entire portfolio or requires an interpretation of subjective investment standards. Dealer Qualified Representative Signature Name (Printed) Title Date Attachment A
  • 23. Attachment B RESOLUTION NO. 2023R - 160 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ALAMO HEIGHTS, TEXAS ADOPTING THE CITY OF ALAMO HEIGHTS INVESTMENT POLICY AS REQUIRED BY TEXAS PUBLIC FUNDS INVESTMENT ACT AND DESIGNATING INVESTMENT OFFICERS FOR THE CITY; AND SETTING AN EFFECTIVE DATE. WHEREAS, in accordance with the Public Funds Investment Act, Chapter 2256, Texas Government Code, the City Council of the City of Alamo Heights (City), Texas is required to adopt an investment policy by resolution and the governing body of an investing entity must review its investment policy on an annual basis: and WHEREAS, the Public Funds Investment Act requires certain City officials to be deemed investment officers to attend investment training; and WHEREAS, the investment policy must be written and the basic provisions and Texas Government Code 2256 requires that investments be made with judgment and care, under prevailing circumstances, that a person of prudence, discretion, and intelligence would exercise in the management of the person’s own affairs, not for speculation, but for investment, considering the probable safety of capital and the probable income to be derived; and WHEREAS, the attached investment policy complies with the Public Funds Investment Act, and authorizes the investment of city funds in safe and prudent investments; BE IT RESOLVED BY THE CITY COUNCIL OF ALAMO HEIGHTS, TEXAS: Section 1. That the Investment Policy attached hereto is hereby adopted as the Investment Policy of the City of Alamo Heights with Robert Galindo, Finance Director, and Buddy Kuhn, City Manager, designated as Investment Officers of the City to make investment decisions and execute needed documents for city investments. Section 2. This Resolution shall become effective as of the date of passage. PASSED AND APPROVED this 9th day of JANUARY, 2023. BOBBY ROSENTHAL, MAYOR ATTEST: ELSA T. ROBLES, CITY SECRETARY APPROVED AS TO FORM: FRANK J. GARZA, CITY ATTORNEY