Page 416 - FY 2026-2027 Adopted Budget Book

b. An investment swap would improve the quality, yield, or target duration in the
portfolio.

c. Liquidity needs of the portfolio require that the investment be sold or redeemed.
III. Standards of Care.

1. Prudence. The standard to be used by Investment Officers shall be the “prudent
person” rule, which states, “investments shall 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 Officers acting in accordance with written policies and
procedures, and exercis ing due diligence, shall be relieved of personal responsibility
for an individual investment's credit risk or market price changes, provided deviations
from expectations are reported in a timely fashion.

2. Ethics and Conflicts of Interest . Investment Officers 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.
Investment Officers shall disclose any material interests in financial institutions with
which they conduct business. They shall further disclose any personal
financial/investment positions that could be related to the performance of the
investment portfolio. Investment Officers shall refrain from undertaking personal
investment transactions with the same individual with whom business is conducted on
behalf of Bedford.

An Investment Officer who has a personal business relationship, as defined by the
PFIA, with a depository bank or with any entity seeking to sell an investment to
Bedford shall file a statement disclosing that personal business interest. An Investment
Officer who is related within the second degree of affinity or consanguinity to an
individual seeking to sell an investment to Bedford shall file a statement disclosing that
relationship. A statement required under this subsection must be filed with the Texas
Ethics Commission and the City Council.

3. Delegation of Authority . Authority to manage and operate the investment program is
granted to the Director of Finance. The Director of Finance shall establish written
procedures and internal controls for the operation of the investment program
consistent with this Investment Policy. Procedures should include, but not be limited
to: account management procedures, cash flow estimation procedures, investment
transaction procedures, authorized broker/dealer selection process, and investment
portfolio reporting requirements. No person may engage in an investment transaction
except as provided under the terms of this Policy and the procedures established by
the Director of Finance. The Director of Finance shall be responsible for all transactions
undertaken and shall establish a system of controls to regulate the activities of the
Authorized Investment Officers and subordinate officials.

4. Authorized Investment Officers.
Assistant City Manager
Director of Finance

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