Page 560 - Bedford-FY24-25 Budget

e. Authorized broker/dealers,
f. Independent investment training sources, and
g. Target rate of return on the portfolio.

The Investment Committee shall provide for minutes of its meetings. Any two members of the
Committee may request a special meeting, and three members shall constitute a quorum. The
Committee shall establish its rules of procedure.

6. Investment Training. In order to ensure the quality and capability of Bedford’s investment
officers, Bedford shall provide periodic training in investments through courses and seminars offered
by professional organizations and associations as required by the PFIA, including education in
investment controls, security risks, strategy risks, market risks, diversification of investment portfolio,
and compliance with the PFIA. The Investment Officers shall attend at least one training session
accumulating at least ten (10) hours relating to the Officer's responsibility under the Act within twelve
(12) months after assuming duties, and thereafter, attend investment training session(s) not less than
once every two years (aligned with the City’s fiscal year end), receiving an additional eight (8) hours
of training. The training shall be conducted by independent training sources approved by the
Investment Committee.

7. Investment Policy Certification. Local government investment pools and discretionary
investment management firms shall provide certification of having read Bedford’s Investment Policy
signed by a qualified representative of the organization, acknowledging that the organization has
implemented reasonable procedures and controls in an effort to preclude imprudent investment
activities arising out of investment transactions conducted between the City and the organization in
accordance with the Act.

IV. Broker/Dealers, Internal Controls and Delivery Versus Payment.

1. Authorized Broker/Dealers. A list will be maintained of “primary” dealers or regional dealers
that qualify under Securities and Exchange Commission (SEC) Rule 15C3-1 (uniform net capital rule).
All investment providers, financial institutions and broker/dealers who desire to become qualified for
investment transactions must supply the following as appropriate:

a. Audited financial statements
b. Proof of Financial Industry Regulatory Authority (FINRA) certification
c. Proof of state registration
d. Completed broker/dealer questionnaire

The Investment Committee shall review, revise, and adopt a list of authorized broker/dealers at least
annually.

2. Internal Controls. The Director of Finance is responsible for establishing and maintaining an
internal control structure designed to ensure that the assets of Bedford 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 require estimates
and judgments by management.

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