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are protected from loss, theft, or misuse. The concept of reasonable assurance
recognizes that the cost of a control should not exceed the benefits likely to be
derived, and, the valuation of costs and benefits requires ongoing estimates and
judgments by management.

The internal controls shall address the following points at a minimum:
• Control of collusion;
• Separation of transaction authority from accounting and record keeping;
• Custodial safekeeping;
• Clear delegation of authority;
• Written documentation on all transactions; and
• Review, maintenance, and monitoring of security procedures.

In accordance with the Act, a compliance audit of management controls on
investments and adherence to this policy shall be conducted in conjunction with the
City's annual external financial audit.

The Investment Officer(s) will develop and maintain internal procedures,
describing use of bank balances, calculation of the City's liquidity needs, daily
investment procedures, investment transaction documentation, and distribution of
reports, at a minimum.

Competitive Transactions
The Investment Officer(s) or Investment Advisor shall obtain competitive bid
information on all transactions and maintain documentation thereof. A competitive
bid/ offer must involve at least three separate brokers/institutions or use of a
nationally recognized electronic trading platform with three bids/offers.

For transactions involving new issue agencies or securities for which there is no
readily available competitive offering on the same specific issue, then the
Investment Officer(s) or Investment Advisor shall document quotations for
comparable or alternative securities.

Delivery vs. Payment
The Act requires that all trades of marketable securities be executed (cleared and
settled) on a delivery vs. payment (DVP) basis to ensure that securities are deposited
in the City's safekeeping institution prior to the release of funds.

Cash Flow Forecasting
Cash flow forecasting is designed to protect and sustain the City's ability to meet
its cash flow requirements. Supplemental to the financial and budgetary systems,
the Investment Officer(s) will maintain a cash flow forecasting process designed to
monitor and forecast cash positions to assist in determining appropriate laddering

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