Investing Public Funds - Region One ESC · • Emphasizes safety and liquidity • Addresses...
Transcript of Investing Public Funds - Region One ESC · • Emphasizes safety and liquidity • Addresses...
INVESTING SCHOOL FUNDS
Public Funds Investment Act Workshop
Region 1 – Edinburg
October 2013
The Dynamic Act
Initially separated investment from banking
It has responded over the years to: public entity efforts
new market opportunities
financial and investment crises
banks desires
mineral rights funds and hedging needs
brokers looking for income
PFIA Changes Mirror Markets
1980’s Banking and investments were split apart
1990’s Markets accommodative and investors taking
risks
1994 Major crash in Orange County
1995 Major adjustments to law/controls
2000’s Banks go for service not investment and mineral
rights gain strength
1987: Separating Banking and Investing
Local governments – except home rule entities – were bank dependent
Before most entities were restricted to bank accounts and CDs
The PFIA was created and passed initially in 1987
Defined the entities Set collateral at 100% Authorized specific investments
CDs US obligations including agencies/instrumentalities Repurchase agreements Any bond guaranteed by Texas
Required an investment policy (no details)
1989: Pools Created to Aide Small Entities
Pools were added through ILCA
Pools were only generally defined and assumed
to be constant dollar, money market equivalent
Reverse repurchase agreements added
Commercial paper added
Bankers acceptances added
The Public Funds Collateral Act was passed
1991 and 1993: Entities Start Feeling Their Oats
1991
Money market funds limited to specified authorized investment types added
1993 Specific “Collateralized Mortgage-backed Obligations”
(CMOs) were added (as rates were falling)
Pools required to disclose information statement and
provide confirmations and monthly reports
Written strategies now required with governing body
approval
1994: Orange County
Local Government Investment Pool in CA
Guaranteed liquidity
But, bought long mortgage backed securities
Risked the liquidity
And, Leveraged securities 5 to 6 times
Board never questioned high rates
1995 – Reaction to Orange County
Prohibition added for certain MBS/CMOs
Reverse repurchase agreements restricted by term and tied to the reverse term (leverage)
Training for investment officers added
Broker certification requirement added “imprudent investments” original language
Added maximum maturities and WAM
Designation of investment officers added
Written quarterly reports required
Mutual funds added
1995 – Major Reactions State agency training added
TX Higher Ed Coordinating Board to provide
Prior authorized investments not required to be liquidated
Pools must be rated no less than AAA or equivalent
Municipalities with utilities authorized to hedge
State purchase and delivery of securities regulations
Loss of required rating requires prudent liquidation
1997 – More Controls
Investment officer training extended
to 10 hours within 12 months and every two years
Delivery versus payment added as requirement
and required in policy
Officer ethics disclosure added
Broker list creation and approval added
Expansion Years
1999 Investment advisers added Annual compliance audits added Israeli bonds added GICs added Municipal utility section added for sale/distribution of gas/electricity
allowing hedging for supplies
2001 Water code directors training reduced Letters of credit added as collateral in PFCA
2003
Securities lending section added Expansion of investment authority now requires state audit review
2005 – 2009 Responding to Specific Needs
2005 CDARS added with a Texas bank and reciprocity for banks required Decommissioning trust funds investment authority expanded to include
Trust Code For entities with gas or electricity utilities selling to public
2007 Municipal hedging on coal and nuclear fuel expanded to commodity
futures and related transportation costs
2009 Municipalities with mineral rights leases and contracts expanded
investments Includes oil, gas or other mineral rights Establishes a Trustee authority Funds must be separated Investments can be made under Trust Code
2011
Procedures to monitor credit rating must be in policy
Training years now defined as fiscal years
FDIC/FICA insured obligations FICA and CDs and interest bearing accounts
Can invest in FDIC insured CDs outside TX
Conflict within the Act adds danger
CDs from a broker in TX allows broker to custody BUT Act requires you require DVP which this is not
Repurchase Agreements can be collateralized with cash
ISDs with over 50,000 average attendance can buy AA- corporate bonds Gov’t Code 1371 definition based on Ed Code 42.005
Pools may not invest in corporate bonds
2011 Changes for Pools
Pools can now invest 100% in money market funds
Pools must say how yield is calculated in monthly reports
Constant dollar pools must report yield under SEC regulations
Pools’ websites must:
Include disclosures (information statement)
Make audited annual financials available
Must define breakpoints creating rate differentials
2013 Legislative Change
Public Funds Collateral Act Amendment
Custodian need not send trust receipts to public entity
Custodian has choice of recipient Trust receipts to public entity or to bank with directions to
forward
Public entity can request current collateral list
YOU need to tell your bank/custodian that you want reports monthly from the custodian
What is public investing?
Managing risk
Putting money to work.
Creating a performing asset
Building a portfolio to serve the entity
Utilizing markets and products for entity benefit
Adding yield but not risk to the portfolio
Assuring cash efficiency and security
including banking arrangements
A Public Investor
Special fiduciary duties for public funds:
market and internal entity knowledge
to understand risk
to be conservative
to be pro-active and curious
effective communication skills
What is PFIA Designed to Do?
Provide guidelines for safety
Apply to all entities
Allow entities to set their own parameters
WAM and maturities and authorized investments
Define guidelines on investments to direct high credit quality
Provide for flexibility (maturity)
Provide for control on extension risk (WAM)
Allow entities to adjust to changes internally and externally
Standard of Care
Prudent Person Rule Investment shall be made with judgment and care, under prevailing
conditions, 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 and probable income to be derived.
Essentially I am more concerned with the return of my money than
the return on my money
A key point is “circumstances then prevailing” because conditions change internally and in the market
PFIA Specific Requirements (Call it “Audit Risk”)
• Write a Policy which: (2256.005) • Emphasizes safety and liquidity
• Addresses diversification, yield, maturity & capability
• Lists authorized investments
• Includes procedure to monitor credit rating changes
• Set a maximum maturity and WAM
• Tell how market prices are monitored
• Require delivery versus payment (DVP)
• Review and adopt policy annually
PFIA Specific Requirements Entity must write a strategy
Council must review and adopt the strategy annually
Council must designate investment officer(s)
Designate by resolution
Effective until rescinded or terminated from employment
Council must provide for the training of officers
Council has the option to chose officers (no necessary set position)
Officers must disclose personal/business relationships
Refers to personal business relationships
2nd degree of affinity or consanguinity (blood or marriage)
Specific income limits are set but full disclosure is safer/easier
Disclosure to TX Ethics Commission and governing body
Investment Officers
Must be designated by resolution
Officers or employees of entity
Contracted investing entity can be officers
Effective until rescinded or terminated
Regional Planning Commission officer can only serve RPC
Training Specifics
Required training
Required within 12 months of appointment or position
Required every two succeeding fiscal years
Training sources must be approved by governing board or investment committee
Required training for
(a) treasurer,
(b) CFO (if Treasurer is not CFO) and
(c) all designated investment officers
PFIA Specific Requirements
Provide policy for written certification To all firms wishing to sell a transaction must provide certificate
Includes pools, banks, investment advisors as well as broker/dealers
Provides for the review – it is not a guarantee
Counter-parties
All counterparties must certify to the Policy A list of broker/dealers must be approved annually by Council
Or a Council designated Investment Committee
Audits
Annually obtain or complete an annual management audit Assuring compliance with the Policy and the PFIA Audit by independent auditor may be required
if invested in more than CDs and pools
PFIA Specific Requirements
Reporting
Must be prepared jointly by investment officers
Must be signed by each Investment officer
Must be submitted to Board quarterly
On a timely basis
Must contain detail and summary information
Must conform to PFIA report requirements
Must state compliance with Policy and PFIA
PFIA Specific Items
CDs may be bought orally
Prudence is based on the whole portfolio
Prudence to liquidate at loss of rating
Does not constitute an authorized security with lower rating Policy must include procedure for monitoring credit rating and
possible liquidation
No need to liquidate if authorized at purchase Discuss and decide the reasonable action to take
Chapter is sub-cumulative to other law Some Water District variations have been created
Basic Public Objectives
Safety of principal Preservation of capital
Liquidity Assuring that funds are available
Covering known and unexpected expenses
Diversification Avoiding risk of over-concentration
Yield Making all the funds work
How do we achieve the objectives?
Change Market conditions change constantly
Know the “circumstances then prevailing” The best weapon is information Do not single-source information Have a reasonable process for downgrades Ongoing disclosure to governing boards will help
Internal situations change
Changes in tenured individuals Board proclivities for risk change New or different types of funds may change (bond $$) Weather events may influence need for liquidity
Legislation changes
Use the Act and Your Policy to Address Change
Fundamentals Your objectives
Economic realities
Firm Foundation Controls and plans
Flexibility Policy guidelines which allow change
Securities not usually used (state and municipal debt and CU)
New liquidity alternatives
Extension alternatives (step-ups)
Adapting to Change
Competitive process will keep you on top of the market
Periodic review of policies and procedures will keep policy dynamic
Training will keep you up-to-date
Expecting change allows you to adapt
Today’s Major Change Factor
• Interest rates control you and your strategies
• Know what you can control
• Know the rates generally
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0.50
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1.50
2.00
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4.50
3mo 6mo 1yr 2yr 3yr 5yr 10yr 30yr
Sep-13
Aug-13
Jun-13
Dec-12
Sep-12
Jun-12
Public entities operate primarily in this area of the curve.
A Major Change Factor
• What is driving the rates and markets
currently?
• What factors will change outlooks?
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0.50
1.00
3mo 6mo 1yr 2yr 3yr
Sep-13
Aug-13
May-13
Sep-12
Jun-12
Mar-12
Public entities operate primarily in this area of the curve.
Investment Process/Cycle
The process is cycle to verify circumstances then prevailing have not changed
The process exists for all types of investing
The process requires ongoing systematic review
Step 1: Cash Flow
Identifies when you need money to pay bills
Protects your liquidity
Improves investment returns
Establishes parameters for policy guidelines Maximum maturity Maximum weighted average maturity Risk benchmark
Promotes safe maturity extensions
Defines your portfolio
Cash Flow Analysis What?
Study of how cash moves through an entity
Capture revenues & expenditures for analysis over time
Study of how and when money flows
Problem periods
Opportunities
Basis for cash projections
Cash Flow Analysis Why?
Protects your liquidity
Improves investment returns
Establishes parameters for policy guidelines Maximum maturity
Maximum weighted average maturity
Risk benchmark
Promotes safe maturity extensions
Cash is the gas that makes an entity go
Cash flow analysis makes the portfolio go Defines your portfolio
Cash Flow Sets Time Horizons
Knowing cash flows/horizons allows you to act pro-actively
Provides comfort that necessary funds are available
Allows some extension by recognizing future flows
Yield is not the end-game but an added benefit
Defines the portions of your portfolio
And from that the strategy for each
Debt Service Time Horizons
A $2mm debt payment is scheduled out 6 months
$400,000 is paid in each month to meet debt service
Staying liquid over the 6 months earns $14,000
Investing each successive month at rates shown earns $16,333
Horizon Yield
Overnite 2.0 %
1 month 2.1 %
2 months 2.2 %
3 months 2.3 %
4 months 2.4 %
5 months 2.5 %
Two Approaches
Both approaches have same goal
Present viable information for decision-making
Develop parameters for portfolio structure
Limiting liquidity risk
Traditional approach details Define all variables
Build on extensive historical data
Extensive analytics for forecasting
Expense Orientation approach simplifies Limit the elements being analyzed
Designed to get going faster
Traditional Cash Flow
Capture more detailed information Continue use of 80-20% rule or
add categories
Capture historical data before analysis Total revenues minus total expenses
Multiple years will highlight and smooth aberrations
End result is same cash balance data
Major Category History Revenues Jan Feb Mar Apr May Jun Jul
Taxes 8,500,000 7,000,000 3,500,000 750,000 1,000,000 2,000,000 1,000,000
State $$ 250,000 200,000 200,000 200,000 250,000 300,000 300,000
Svc Fees 150,000 150,000 250,000 275,000 400,000 400,000 400,000
Utility 2,000,000 350,000 433,000 400,500 600,000 700,000 750,000
Total 10,900,000 7,700,000 4,383,000 1,625,500 2,250,000 3,400,000 2,450,000
Expenses
Salaries 2,000,000 2,000,000 2,000,000 2,000,000 2,000,000 2,000,000 2,000,000
Contracts 300,000 300,000 350,000 450,000 645,000 875,000 750,000
Capital 300,000 200,000 400,000 500,000 400,000 450,000 500,000
Debt Svc 2,000,000
Total 2,600,000 2,500,000 4,750,000 2,950,000 3,045,000 3,325,000 3,250,000
Net Cash 8,300,000 5,200,000 -367,000 -1,324,500 -795,000 75,000 -800,000
Multi-year History Smoothes
Layering each year’s history allows an average
Building off history allows you to compute monthly %
Historical % used on new budget creates a forecast
Tie the summary sheet to detail sheets per year
Layering sheets allows for research on aberrations
The 80-20 Rule
Regardless of approach Capturing every detail can be overwhelming in detail Can be difficult to maintain 80% of expenses come from 20% of expense categories
Payroll and fringes probably account for 80%
80% of revenues come from 20% of revenue sources
Taxes, state payments or fees probably account for 80%
Capture the key elements Summarize remaining “other” amounts and focus
Let’s Flow
A key to cash flow analysis is to START Eliminating the need for years of data
Data farming too often an excuse not to act
You can create the basic cash flow now – a base line
How much is your payroll each month?
How much is your accounts payable each month?
When are your debt service payments? How much?
Add a ‘liquidity buffer’ for the unexpected
A Debt Service Example
This entity has two debt service payments: February and August.
Funds for debt service flow in from tax payments first 6 months.
Balances build in these front months.
Keeping funds liquid leaves them at the lowest possible rate.
We need to make these funds work.
Using the Information
An overview of the cash flow needs allows the investor to look ahead.
The flow in Jan. alone covers the February payment.
The net balances of each other month can be invested 11, 9, 8 and 6 months.
A General Fund Sample
We use the excess balances not needed for the next month and extend.
Three excess balances result in 3-month investments.
The cash flow knowledge allows Sept. to be extended to 8-month investment.
Either route gets you to…
0
1,000,000
2,000,000
3,000,000
4,000,000
5,000,000
6,000,000
7,000,000
8,000,000
9,000,000
10,000,000
1 2 3 4 5 6 7 8 9 10 11 12
A view to the balances of cash throughout the year The net cash shows the peaks and valleys on balances Normally there is a minimum balance across the year
On this graph the entity has historically never gone less than
$2,000,000. - this is our ‘core’
Cores can be invested longer knowing that there is little chance of using that cash
Core
Maturity and WAM
The Investment Policy and its controls are often
based on cash flow
The maximum maturity (flexibility)
allows the entity to extend and reflects a core and longer time horizon
The weighted average maturity (control)
controls for over-extension
Information for Maximum Maturity
0
20
40
60
80
Entity A has no core – starting and ending the cycle at zero
They can not invest longer than one year = maximum maturity 1 yr
Entity B has a core so they can invest longer
Possibly B could create a maximum maturity of 2 years
You must understand what the core is made up and if might change
core 0
20
40
60
80
core ?
A. B.
Cash Flowing Capital Projects
A recurring problem: obtaining information
A large nonrecurring expenditure A unique cash flows for some entities
Work with departments for expenditure plans before $$ arrives
Bond document may have draft plan
Get regular updates from departments and engineers to modify plans
Some projects are repetitive and history of old funds shows pattern
Explaining the importance of cash flow helps generate support Impact of additional earnings Verify arbitrage impacts
CIP Trends
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200
400
600
800
1 2 3 4 5 6 7 8 9
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200
400
600
800
1 2 3 4 5 6 7 8 9
Use multiple historical issues
of the same type fund
streets
water mains
land acquisition
Trend often appear over the
time frame of the total project
Use for projections on the
same type projects in the
future
Streets - 2007
Streets - 2009
0
200
400
600
800
1 2 3 4 5 6 7 8 9
Streets Projection 2005 Street Composite – New Funds
Cash Flow Investing
We focus on a monthly expenditure need
Eliminate the need to invest to each liability
Meet the monthly need with one early investment
Place the maturity before the first known liability
Use liquid options or short investments to target each liability in month
Reduces cost of safekeeping but still increases portfolio effectiveness
Translating the Information into Action
S M T W TH F S 1 2 3 4 5 6 7
8 9 10 11 12 13 14
15 16 17 18 19 20 21
22 23 24 25 26 27 28
Payroll
$1mm
Payroll
$1mm
Payables $250,000
Payables
$250,000
Payables
$250,000
Payables
$250,000
Entity needs $3 million a month for A/P and payroll costs.
Investment matures on 2nd and is available for rest of month.
Cash Flow Structure Creates the Portfolio
Maturity Date Amount
Liquid (now to 6 mos.) $3,000,000
6 months $ 500,000
7 months $ 500,000
8 months $ 500,000
9 months $ 500,000
10 months $ 500,000
11 months $ 500,000
12 months $ 500,000
14 months $1,000,000
18 months $1,000,000
24 months $1,000,000
$9,500,000
Summary
Cash flow analysis should be straightforward
Undue maintenance needs will render it cumbersome and un-usable
Cash flow must be done to set policy controls
Cash flow should result in information not statistics
Cash flow will pay for itself in good investing decisions
Maintenance is minimal Perhaps one-half hour every quarter
Cash Flow Questions
A continuing money balance is a ______ .
Cash flow sets my ________ and ______ .
What level of analysis is most productive?
The key action is to _____ .
Multi-year averaging eliminates _____________ .
Step 2: Identify Risks
Risks occur in every investment
Risks occur within the custody area
Risks occur with counter-parties
Identify your risk tolerance level
Risk
Exists in all securities and all markets
You can not avoid risk
You can manage risk
Risk can be used to your advantage
Measured risk will increase yield
Use credit ratings and limitations for control
The Oink Factor
The animals in any marketplace The bull, the bear and the pig
Beware the pig in you A pig keeps his head in the earnings trough and ignores the
circumstances prevailing
The pig goes only for yield
Primary pig controls Maximum maturity limitations
Weighted average maturity limits
Controlled leverage
“Market” Risks
Who is this “market” anyway?
You are the market
Encompasses all investors
Their actions and expectations control actions
Built on investors expectations
General ‘Market’ Risk
Market risk is based on the market price
Diversifying reduces your exposure
Money will flow from one sector to another for safety or yield
High credit quality reduces exposure High quality retains its value (i.e. UD $ as reserve currency)
In fixed income markets When prices go up – rates go down So, a bull market has rates dropping
Credit Risk
Credit risk is the risk of issuer failure Inability to pay interest or principal
Authorized investments normally face little credit risk Most statutes require AAA ratings or equivalents Limit the maturity to further manage risk
Recognize the media loves a scare – don’t react without cause Do your homework on why prices are moving Talk to several sources and reason it through
Measure and control the inherent risk in securities Create diversification limits
Use CP but restrict to dual ratings and stay under 90 days
Understand issuers restraints and strengths For example: FHLMC and FNMA conservatorship raises credit
Measure and monitor bank credit Monitor bank credit on ongoing basis Use independent bank ratings agencies (Veribanc, Prudent Man) Monitor collateral market value
How to Manage Credit Risk
Restrict the portfolio to the highest rating
Diversify Set % of portfolio limits for riskier securities
Limit maximum maturities
Monitor credit ratings regularly
Watch market news Watch for major sector moves or news
Require dual ratings Two views are better than one
Utilize credit rating agencies Understand when they are being political too!
Understand the rating definitions
Credit (Default) Risk
Low Risk Higher Risk
U.S
. T-B
ills
U.S
. T
-No
tes a
nd
Bo
nd
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Re
po
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(1
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VP
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U.S
. G
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Agencie
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U.S
. G
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Ente
rprises
Local G
overn
ment In
vestm
ent P
ools
Money M
ark
et F
unds - A
AA
Co
mm
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ial P
ap
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A-1
/P-1
Bank C
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nsure
d
and C
olla
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lized)
Bankers
’ Accepta
nces
Procedures for Downgrades
Have a procedure for down-grades including: Disclosure to supervisor or governing board
Consider the conditions of the downgrade
Consider your maturity on the security
Immediate sales often do not make sense
Understand what the ratings mean Investment grade goes to BBB- at S&P
Investment grade goes to BBB at Fitch
Investment grade goes to Baa at Moody’s
Monitoring Ratings
Create a control in policy or procedure for downgrades Authorized investments requiring credit rating (such as CP) need to be
monitored constantly
Create your process based on your risk tolerance: The Investment Officer shall monitor, on no less than a monthly basis, the
credit rating on investments in the portfolio requiring a rating based upon information from a nationally recognized rating agency.
THEN EITHER:
If any security falls below the minimum rating required by Policy, the Investment Officer shall notify the ------- of the loss of rating, conditions affecting the rating and possible loss of principal with liquidation options available within two days.
OR: If any security falls below the minimum rating required by Policy, the
Investment Officer shall immediately sell the security, if possible, regardless of a loss of principal.
Know Your Ratings
S&P Moody’s Fitch
Extremely strong capacity – very
low expectation of default AAA Aaa aaa
Very high credit & strong capacity-
low default expectation AA Aa aa
Somewhat susceptible to adverse
conditions – low default risk A A a
Adequate capacity but subject to
adverse conditions BBB Baa bbb
Lowest investment grade BBB- Ba b
Many pools and funds are not rated on these but on ‘volatility’ ratings such as V-1.
Money market instruments (like CP) have similar levels but different ratings (A1/P1).
Liquidity Risk
Liquidity Risk The risk of not having cash when needed
The inability to sell security when needed for cash
Liquidity is reduced with longer maturities
Liquidity is reduced in smaller issues
Some agency paper is sold in small issues and you could own the whole issue – no problem if you can hold to maturity
Public funds’ biggest perceived risk
Danger that it forces many to stay TOO liquid
Liquidity Risk
Cash Illiquid
U.S
. T
-Bill
s
U.S
. T
-Note
s (S
hort
-term
)
U.S
. G
ovt.
Agency B
onds
U.S
. G
ovt.
Ente
rprises
(Sm
alle
r is
sue s
izes a
nd d
erivatives)
Local G
overn
ment In
vestm
ent P
ools
Money M
ark
et F
unds - A
AA
Com
merc
ial P
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-1/P
-1
Non
-negotiable
B
ank C
Ds
U.S
. G
ovt.
IE
nte
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(Larg
e is
sue s
izes)
Overn
ight R
epos
Long
-term
Tre
asury
Bonds
Degree of Liquidity
Bankers
’ Accepta
nces
The Lure of Lazy Liquidity
It is December 2010,
Pools yield 0.16%
6 month CD yields 0.60% ( FDIC 0.85%)
1 year CD yields 0.75% (FDIC 0.85%)
In 6 months $1mm=
Pool = $800 in 6 months
6 Mo CD = $3,000 - $4,250
You just had a $3,450 opportunity loss
Managing Liquidity Risk
Don’t be liquidity dependent
Being totally liquid puts you at the lowest rates
Do your cash flow and invest to it
Stick with the program
Create a liquidity buffer
Be practical and prepare for the unexpected
Use liquid investments
High credit quality always increases liquidity
Watch the size of the issues
On agencies the small issues will not be as liquid
Price and Volatility
Market Risk The risk that market prices will fall Lower prices threatens liquidity
Can you take a loss by policy?
Risk that if sold you recognize a loss of principal “Unrealized” loss versus “realized” loss
Volatility Risk (VIX = the risk index)
The risk of significant changes in market prices Higher the volatility = higher risk
Volatility increases with longer maturities, low credit and structured securities
Market Risk
Low Risk Higher Risk
U.S
. T
-Bill
s
U.S
. T
-Note
s (S
hort
-term
)
U.S
. G
ovt.
Agencie
s
U.S
. G
ovt.
EW
nte
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Local G
overn
ment In
vestm
ent P
ools
Money M
ark
et F
unds - A
AA
Bankers
’ Accepta
nces
Bank C
Ds - (
Short
-term
)
U.S
. G
ovt.
Ente
rpri
ses
D
iscount N
ote
s
Tre
asury
Securities (Long-t
erm
)
Com
merc
ial P
aper - A
-1/P
-1
Managing Market & Volatility Risk
To manage these inter-related risks:
Invest to your cash flow needs in the short-end
Purchase high credit quality
Establish maximum maturities suitable to sector
Ex: keep commercial paper under 90 days
Maintain a shorter weighted average maturity
Minimize embedded options
diversify
Event Risk Event Risk
An unforeseen change that affects markets.
Moves markets especially with uncertainty
Event risk is everywhere Lehman, AIG, Stanford, Madoff
Europe
Health care
Weather impacts on commodities
Auto industry
Afghanistan
Political change
Sovereign and local deficits/defaults
Managing Event Risk
Diversification is the key
Not all eggs in one basket
Diversify banks, pools, funds, market sectors
Prepare for the worst
Imagine the worst and have a plan for it
Extension Risk
Extension Risk Risk that securities lengthen in maturity unexpectedly
Primarily found in mortgage backed securities When mortgage rates rise people do not refinance
When people don’t refinance the pay-down horizon extends
Callables can have a short-term extension risk Only if you buy it assuming a call
Always assume your risk is holding to maturity
Reporting must reflect stated maturity to show total risk
Managing Extension Risk
Use mortgage-backed securities only in suitable long portfolios Portfolios always have to be able to hold to maturity
Diversify among market sectors
Report WAM based on stated maturity Maximum risk is if it goes to maturity
Amortize callables to the call Reflects the risk of the call for amortization cost
Reinvestment Risk
Re-Investment Risk Risk that reinvestment will be at lower rates
Primarily in callable securities when they are called as rates fall
Reinvestment of proceeds will be at lower rates
Do not assume a call If not called will it affect your liquidity?
You will be rewarded for the callable risk Using risk to your advantage
Managing Reinvestment Risk
Diversify and use some callables
Consider call risk to add yield
Insure initial yield covers reinvestment risk
Amortize to call
Creates a par bond which is more valuable
If it is called there is not a principal loss
Managing Collateral Risk
FDIC and collateral issues
Bank Collateral Securities pledged to repay a debt
Deposits protected by FDIC and collateral
Covered by Public Funds Collateral Act (Local Government Code, Chapter 2257)
Manage the risk by answering: What is acceptable collateral to me?
Is there enough of it?
Is the collateral mine – can I prove it?
Who is Covered by FDIC Insurance
Based on Tax Identification Number within the entire holding company of the bank
Based on Type of Account FDIC defines only two types of accounts
Non-interest bearing accounts have $250,000 Interest earning accounts are combined for $250,000
Based on Location of city and bank If the bank’s HQ is in your same state
then both type accounts receive FDIC insurance If the bank’s HQ is not in your state
all accounts types together receive only $250,000
FDIC Coverage Only “public units” can have collateral pledged
“Public unit” is a FDIC definition not a state definition Must created under express authority of law Must have some function of government delegated Must execute exclusive control of its funds for exclusive use
Special cases of public “corporations” 4a and 4b corporations Water supply corporations
Dependent on several factors 12 C.F.R. Part 330.15
FDIC Insurance
Exception accounts
“Testamentary Accounts” (I&S accounts)
Funds set aside to discharge a debt
Applies to the debt holders
Coverage is $250,000 for each bond holder
FDIC Coverage
Search on: public unit insurance
Is your collateral report coming from the custodian?
If not how secure is it?
Using a Rating Service
Bank Rating Services:
-Best
-Highline
--Veribanc
Rating services rate ‘CAMELS’
Capital
Assets
Management
Equity
Liquidity
Systems
Managing Collateral Risk
Define the authorized collateral (in policy and RFP) Obligations of the US Government, its agencies and
instrumentalities, including mortgage backed securities with CMOs passing the bank test
Monitored and maintained by the bank at all times.
Choose and understand your options within law Surety bonds
Treasury Notes and Bills
US Agencies
Rated Municipals
Letters of Credit
Custodian Duties
In any event of default
Take control of collateral
Hold the collateral under your instructions
Sell the collateral if applicable
Paying your 100% portion
Return excess to bank
The Fed as Custodian
Perhaps the best custodian
Standard Pledgee Agreement Form is used
The Fed will not sign a collateral agreement
Supplements the Collateral Agreement
Reference the Circular 7 in your agreement
Fed will ask for authority to use e-mail to contact you
Recent Circular 7 Change Notification
Little impact but a good lesson The pledgee is responsible
Contract must require bank to monitor and maintain colalteral levels
Treatment of principal Principal will be held in non-interest bearing account until the earliest of:
New securities are substituted Principal is released by Pledgee (public entity) Principal collected by pledgee on event of default
Treatment of MBS (amortizing book-entry security)
Principal will be held in non-interest bearing account until the earliest of same three conditions
Treatment of interest Interest goes to the Pledgor (bank) unless written notification of event of default
Federal Reserve as custodian
Circular 7 Pledgee Agreement
Authorizing
use of
e-mail for
contact
purposes
Surety Bonds
Surety bonds are insurance policies
Verify:
Company (and its strength)
Recipient (is it the District?)
Terms (tie it to the contract)
Letters of Credit
Initiated for State CD business
LOC normally issued by FHLB
backed by pledged unrestricted securities or bank credit
Created to replace collateral and PFCA
Collateral Pooling
Final Rules Published 10/10
Voluntary – bank and public entity
Not applied to counties or higher education
Exclusion of higher ed. not in 2257
Collateral Pooling Why It Doesn’t Work in Texas
Comptroller controls the contract
Comptroller holds the collateral
Comptroller has set collateral unacceptable to banks
Entity bears more responsibility:
for low level of collateral overall
Entity must report big changes in balances
For monitoring bank reporting on balances
Repurchase Agreement “Collateral”
Differentiating collateral types in your policy
Collateral is a mis-nomer
This must be a buy-sell transaction
The entity owns the securities
The same requirements apply Define the authorized collateral types
Establish the required margin (102%)
Establish 3rd party safekeeping
Managing Risk
Custody and Safekeeping Risk Risk to your proof of ownership
Proving your ownership
Risk of a custodian restricting access
Key safety points Independence Reporting to you directly Custodian should verify authorized collateral and margin
Applies to:
collateral pledged to you (custody) securities you own (safekeeping)
Custodians
Custodian has fiduciary responsibilities Usually you agree to/approve a custodian
Safekeeping agents simply hold securities Usually you chose custodian
Key factors for both: Independence on trades or pledgor
Custodians and agents should report directly to you
What is a Safekeeping Account?
Not a “bank account” for funds In your entity’s name Totally electronic
Places assets in care of an agent
Used to hold YOUR owned securities
‘Street-name’ safekeeping
Generic ‘nominee’ name to ease transactions/transfers Client is actual owner – nominee holds title
Fees are required
Hard-dollar: Usually not charged through account analysis
Typical Safekeeping Costs
Clearing FRB DTC
Safekeeping
FRB or DTC Par or cusip
Income Distribution Coupons paid Maturities calls
How are they charged?
Why is it important to know?
When do you use this information?
How can you reduce the fees?
Safekeeping Services
Safekeeping need not be at banking services bank Banking services bank is convenient Other banks may be needed or less expensive A second bank requires ongoing transfers and an account
Agreements Depository Agreement covers safekeeping services Includes a collateral agreement if funds are over FDIC Master Agreements are for banking services Safekeeping agreements for safekeeping only
Will probably involve collateral as funds move through account
Controlling Portfolio Risks
Risk of over extension Set a maximum weighted average maturity Set a maximum maturity
Always use competitive transactions
Only way to assure ‘market’ price
Always use delivery versus payment (DVP)
Always diversify to spread risk
Always report on a timely basis with info not just detail
Show asset allocations by maturity and market sector
Non-Market Risks Counterparty risk
Broker background checks FINRA registration Independent safekeeping outside brokerage
Banking risks
Reconciliation within 30 days Verify availability of funds Continuously monitor cost of services with account analysis
Employee risk Separation of duties Oversight and cross training Cash controls like numbered receipts, safes, assigned tills
Technology’s Risks
Employee controls Pin numbers and separation
Limited access to cash and programs
Sole use PC for bank transactions
Bank fraud controls Filters/blocks on ACH
Payee positive pay
Step 3: Set Strategy
Macro strategy
Policy statement from passivity or proactivity
Includes setting WAM and maximum maturity
Requires annual review
Must be flexible enough to adjust to market and internal conditions
Market Strategy
Changes daily and requires market information
How do I achieve Safety?
Document all transactions Use competitive transactions Recognize changes in your and the markets’ situation Learn about the various securities/opportunities Use independent counter-parties Delivery versus Payment (DVP) Settlement Review and report regularly Establish controls and procedures Review contracts
establish equality review for practicality
Establish Collateral Independent safekeeping and reporting
Diversify
How do I achieve Liquidity?
Create and understand your cash flow
Invest to known liabilities
Providing liquidity at appropriate time
Always have a small cash buffer for emergencies
Buy high quality securities
High quality assures a secondary market
How do I achieve Diversification?
Create competition in every transaction Never rely on one institution or broker
Do not allow a broker to do competitive bidding for you
Diversification by type of security Knowledge of the securities
Use securities that make sense for the period
Diversification maturity Create a ladder to meet your liabilities
How do I achieve Yield? Invest to your cash flow needs
Knowing your securities and use appropriate ones
Assure there is always competition
Use time and attention for the portfolio
Know your alternatives and compare them
Use the alternatives available
Commonalities SAFETY LIQUIDITY DIVERSIFICATION YIELD
cash flow cash flow cash flow cash flow
information information information Information
controls controls controls
diversification diversification diversification diversification
documentation
contracts
competition competition competition
documentation
procedures procedures
credit quality credit quality
PFIA Required Strategy
A strategy should be written
And preferably adopted by governing body
Set strategy by portfolio(s)
Or one commingled portfolio
Including in the policy ties the two closely
Should describe how you achieve:
Objective of investments
Suitability of instruments
Safety
Liquidity
Diversification
Yield
Sample Strategy for a Short, Passive Portfolio
The [City] maintains one commingled portfolio for investment purposes which incorporates the specific needs and unique characteristics of the funds grouped represented in the portfolio. Income is distributed to each specific fund based on its participation in the portfolio.
The primary objective is liquidity and reasonable yield. Authorized securities or the pool used will be of the highest credit quality. When not matched to a liability it will be short term and liquid. The portfolio will be diversified to avoid market and credit risk. Diversification requirements can be met through a pool. Maximum WAM is 120 days.
Typical General Fund Strategy
The investment strategy has as it primary objective the assurance that anticipated liabilities are matched and
adequate liquidity provided for unanticipated liabilities. A second objective is to minimize volatility by purchasing high credit quality, short and intermediate
term maturities in a laddered structure and permitting some extension for additional yield.
Sample Debt Service Strategy
The investment strategy for debt service funds shall have as its primary objective the assurance of available
funds adequate to fund debt service obligations on a timely basis. Successive debt service dates will be fully funded before any extension of investments are made.
Successive funding is critical
Too often these funds are kept liquid losing yield
Benefits of Commingling
Think through the portfolio structure
Radically different fund types need a separate policy
Separate portfolios
Require separate accounting
May cause liquidity problems
Can reduce yield by requiring liquidity balances
Commingled portfolios
Can still address unique needs of funds
Smaller liquidity needs may allow more extensions
Reporting is simpler
Addressing More ‘Action’
Pro-active portfolios may change their ladders
Addressing sales and swaps
Securities may be sold before they mature if market conditions present an opportunity to benefit…
The investment officer will continuously monitor market conditions…
Addressing loss
A loss may be taken on a swap of securities if the loss is regained within a three-month horizon on the trade. No realized loss may be taken on a straight sale of a security.
Step 4: Policy Development
Your first line of defense
Single most important element in your program
Pollicies are working dynamic documents
Must be reviewed and adopted annually by Board
Policies show prudence and pro-active management to
Rating agencies, capital markets and citizens
Policy Objectives
Policies combine legal and procedural elements Be concise and clear
Policy is not a manual
Create flexibility with limits for changing conditions Allows you to react to cash flows and markets
Create controls
Creates authorizations and responsibilities Who is authorized to do what?
What must each entity do and when?
Policies are Built on Fundamentals
Not a boilerplate document – tailor to your needs
Cash flow
Sets maximum maturity
Sets maximum weighted average maturity
Sets benchmarks
Risk tolerance identification
Chooses the authorized securities
Sets internal controls
Initial Key Questions Portfolio structure
Commingling all funds or separation by type of funds?
Accounting and Reporting Needs
Separate entities and funds and responsibilities
Scope of authority
Designation of authority by governing body
Training needs and budgets
Brokers and critical competition
Governing body interpretation of risk
What performance do they expect?
Does risk and conservative action mean the same to them??
Steps to Writing the Policy
Internal review
Cash flow
Resources available (tech and personnel)
Accounting needs
Market information systems
Banking arrangements and contracts
Safekeeping
Supervision and oversight
Legal and statutory review
Be aware of different type entities
Being legal doesn’t mean it’s reasonable
Beware of special interests in the law
Input to the Policy
Legal
References for controlling statues/ordinances
Governing body
Prioritizing in their reviews
Internal staff
Accounting staff
Policy: Statement Section
Establish policy as The Policy
Establish as sole policy and reference
Reference procedures but do not include
Establish the strategy approach
Passive or pro-active but always conservative
Establish goals and intent
Protect principal
Provide for reasonable liquidity
Utilize and preserve diversity
Attain reasonable yield
TEA LOCAL
Investment Authority
Approved Instruments
Objectives Safety, Liquidity, Diversity
Monitoring market prices
Monitoring credit changes
Funds/Strategies Operating funds
Agency Funds
Debt Service Funds
Capital Projects
Safekeeping and Custody
Broker/Dealers
Soliciting CDs
Interest rate risk
Internal Controls
Legal and Local Policies
Possible Additions to Local
Scope
Annual review
Investment officers
Standard of Care
Collateral
Broker Requirements
If not policy inclusion – procedural control
Opening Policy Statement
Administration handled as the highest public trust
Receipt of market yield is secondary to safety
All actions in compliance with the laws
Limits are set to provide for diversity and liquidity
Goal is pro-active conservative management
Sample Policy Statement
It is the policy of [x] that the administration of its funds and the investment of those funds shall be handled as its highest public trust.
Investments shall provide for maximum security of principal.
Policy limits and diversification of the portfolio are primary and daily cash flow needs.
The receipt of a market yield will be secondary to the requirements for safety and liquidity.
All investments will be made in full compliance with state statutes, bond ordinances and applicable IRS requirements.
Policy: Legal References
State law
Reference PFIA and specific cites
Use Web link to assure timely update
Local ordinances: check the old ones!
IRS Provisions for bond arbitrage
Bond funds should reference arbitrage needs
Policy: Scope Section Scope
This Policy applies to all financial assets Policies usually except pension funds specifically
Definitive list of funds or reference to CAFR Materially or legally different funds may need a separate policy
Decommissioning funds or economic development entities Escrow funds Responsibility for investment of difference funds can vary
One portfolio can be used Commingled funds still recognize differences G/L accounting keeps funds separate Use sub-funds in the portfolio if necessary
Different bond issues Caution on arbitrage requirements
Policy: Objectives
Do more than just state the objectives
Safety, liquidity, diversification and yield
Define objectives at macro level
Tie the investments to the cash flow
Sets the tone for active-passive choice
If safety is your goal
Tight limits, extreme credit limits, etc.
If safety with yield is your goal
Wider security choices and longer terms
Yield versus Rate of Return
Beware of the specificity of the terms
Connotes intent to market participants/brokers
Yield
Buy-and-hold, not a trading portfolio, conservative
“Yield” based on purchase price and remains to maturity
Rate of Return
Market driven, active management, often indexed
“market return” based on the market price as it changes over time
Policy: Assigning Responsibilities
Clarification for each involved party
Concise listing aides comprehension
Summary in one place avoids confusion
Statutory and policy requirements outlined
Designating responsibilities
Governing body
Investment officers
Investment committee
Auditors
Advisers
Sample Responsibilities
The Investment Officer
The [--position----] is designated as the Investment Officer and is responsible for all investment decisions and activities.
The Officer will receive training…
The officer will develop procedures and controls…
The officer will not be personally liable if the policy and procedures are followed.
The officer will prepare monthly and quarterly reports…
The officer will disclose any conflicts…
Sample Responsibilities
Governing body
Retains ultimate fiduciary responsibility for investment of funds…
Will review and adopt the policy annually…
Will receive monthly and quarterly reports…
Will designate investment officers by resolution…
Will provide for officer training…
Will approve broker/dealers at least annually…
Auditors
Will review quarterly reports
Policy: Ethics and Disclosure
Ethics and Conflicts of Interest Standards and Disclosure
Officers will refrain from personal business that would conflict with proper and impartial execution of their duties. All personal and business relationships with entities doing business with the City will be disclosed.
Policy: Authorized Investments
Limit specifically by investment type
Require legal changes require local governing body re-adoption
Set a maximum maturity by type
Set credit requirements
Need not include all legally authorized types
Tailor the list to your entity’s needs
Sample Language
Define the security
Obligations of the US Government, its agencies and instrumentalities, excluding mortgage backed securities, with a stated maturity not to exceed ---- years.
“Stated” maturities are critical in callables, etc.
A1/P1 or equivalent rated commercial paper, rated by two nationally recognized rating agencies not to exceed 90 days to stated maturity.
Set your maximum maturity to recognize market risk
With CP the market risks increases measurably after 90 days
The Special Case for CDs
Special case of the CD
Policy must differentiate types because of risk
Depository certificates of deposit
Relationship with a bank
Usually restricted to the state
FDIC and collateral protection
Brokered/negotiated certificates of deposit
A security which trades on secondary market (cusip)
Needs additional monitoring requirements added to policy
No extended FDIC coverage on merger requires extra precautions
Depository CD
Limitations will differ with state statutes
May be afforded collateral
Define collateral requirements in policy section
On merger or acquisition if bank FDIC will be extended
Coverage will extend to first maturity date
Sample:
Insured or collateralized CD of banks doing business in the state and collateralized in accordance with this policy, not to exceed ---- years.
Brokered CDs This is a security traded like any security
Can be written outside States Often pushed as safe held by broker – contradicts DVP
No collateral is available
Stay under FDIC coverage
On merger or acquisition there is no extension of FDIC coverage Must be monitored weekly (Friday am)
FDIC insured brokered certificates of deposit securities from a bank
in any US state, delivered versus payment to the [City] safekeeping agent, not to exceed one year to maturity. Before purchase, the Investment Officer must verify the FDIC status of the bank on fdic.gov (bankfind) to assure that the bank is FDIC insured.
Brokered CDs need special
attention – mergers and acquisitions can leave you over-
the-limit.
Not the same
as YOU being in two banks that merge or acquired.
Internal Control for Brokered CDs
FDIC handles these two types of CDs differently Protect yourself FDIC provides NO reprieve for mergers and acquisitions
The Investment Officer, or Investment Adviser, shall monitor, on no less
than a weekly basis, the status and ownership of all banks issuing brokered CDs owned by the [City] based upon information from the FDIC.
If any bank has been acquired or merged with another bank in which brokered CDs are owned, the Investment Officer, or Adviser, shall immediately liquidate any brokered CD which places the [City] above the FDIC insurance level.
Are bank accounts authorized?
You make an investment decision with funds in a bank
Should it be an authorized investment for clarity?
Account for low rate environments when a large % may be needed
Account for funds left in the ECR as an investment
Define for use accounts in all state banks
FDIC insured or collateralized interest bearing accounts in any bank in the state, collateralized in accordance with this Policy
Security Diversification Tables An optional control to assure diversification
Security Max % of Ptf.
Treasuries 80 % Agencies/Instrum 70 % Depository CD 25 %
% by bank 10 % CP 20 %
% by issuer 10 % Constant $ Pools 100 %
% of pool 10 % MMMF 40 % Bank Accounts 60 %
These are ‘maximums’ not designations. Allow for changing conditions.
Policy: Internal Controls Section
Internal controls define and assign Responsibility for creating controls
Responsibility for auditing controls
The Investment Officer will create and maintain internal procedures to control fraud, collusion, errors,…
Monitoring Ratings
Authorized investments requiring credit rating (such as CP) need to be monitored
Add to the policy a process and/or action for monitoring the ratings
Two alternatives based on your risk tolerance: The Investment Officer shall monitor, on no less than a weekly basis, the credit
rating on investments in the portfolio requiring a rating based upon information from a nationally recognized rating agency…..
If any security falls below the minimum rating required by Policy, the Investment Officer shall notify the ------- of the loss of rating, conditions affecting the rating and possible loss of principal with liquidation options available within two days.
If any security falls below the minimum rating required by Policy, the Investment Officer shall immediately sell the security, if possible, regardless of a loss of principal.
Policy: Safekeeping
Its criticality merits its own policy section
Total control requires independent safekeeping
Require receipts to be matched and maintained
Securities owned by the [entity] will be safe-kept at the banking services depository or an approved custodian and all securities will be settled delivery versus payment (DVP) to assure proof of ownership. The safekeeping bank will not be used as a broker in order to guarantee DVP settlement.
Policy: Bank Collateral Section
Collateral is pledged – you do not own it
Dictate what can be pledged Your list can restrict legally authorized securities
Dictate margin requirements Industry standard is 102% but states vary considerably
Remember value is market value not par
Dictate independent custody
Dictate reporting requirements Require that custodian – not bank – sends report direct to your entity
Policy: Owned Collateral Section
Repo collateral is owned by the entity
Require the ‘Bond Market Master Repurchase Agreement’
Dictate what will be authorized collateral
You set the requirements
Dictate the margin
Agreement and industry standard is 102%
Dictate independent custody
Policy: Counterparty Section
Counterparties include brokers, banks and pools
Requirements are set because they are selling you a transaction
Covering any body which is selling a transactions
Broker/dealers, banks, pools
Establish qualifications
Establish monitoring
Establish a reasonable number of counterparties
Dependent on your time and need
Policy: Adoption
Investment Policy and Strategy Adoption
Adoption assures that the governing body is on board
Annual adoption by resolution is required
The Policy and strategy shall be reviewed and adopted no less than annually by the [City Council]. A written resolution approving that review and noting any changes to the Policy or strategy will be recorded by the Council.
Step 5: Procedures and Controls
Procedures support the Policy
Controls are needed to manage risk
Keep them short and practical
Key areas:
Collateral and safekeeping
Trading procedures and counter-parties
Settlement by delivery versus payment
Reporting Procedures
Investment reporting is about performance
Statutes may address reporting – you must address it
Set the standards and requirements
Timing – monthly and/or quarterly
Amortization and accruals required
Pricing by independent entity/service
Especially subjective MBS pricing
Use of a benchmark for risk measurement
Reporting Procedures/Controls
Detail information Detail on each position/investment
Beginning and ending book and market Description, par, maturity, yield, and book and market value
Earnings (accruals plus net amortization)
Summary information Sum of book and market values plus realized gain/loss Total earnings for portfolio Change in market value (to measure volatility) Overall weighted average maturity (WAM)
Performance reporting
Benchmark performance for the period Overall portfolio yield for the period
Counterparty Control Investment officers must monitor the counter-parties
Annual review of registrations
State and FINRA registrations
CRD annual check for any actions taken against the firm/individual
FINRA.org – ‘Broker Check’
Annual review of their usefulness
How many times have they given the best price level
Annual review of financials
Not really necessary because of DVP – no true risk represented
Critical if you allow broker safekeeping (high risk)
Broker/Dealer Controls
Limit the number of broker/dealers for efficiency Minimum activity or a small portfolio rarely need more than 3 Always have three to assure competition More active portfolios in different markets may need 5-7 Don’t let brokers take up your whole day
Certification requirement?
Texas requires counter-parties to read and certify review of the policy
Good control that the counter-party knows your guidelines
Broker/Dealer Requirements
Gather and maintain background information only firm information contact broker information delivery instructions public client references Annual audited financials (if required) Certification of policy
Differentiate between secondary and primary brokers
Non-Primary Brokers
Identify market sector involvement Must sync with your needs
FINRA Broker Check
Finra.org
Self regulatory
Annual check
CRD# or name
Depositories Controls Designation of depository optional
Banking is a key element of investing
By depository law must be competitively bid at least every five years Primary banking services depository
Recognize right to use other depositories for investments
Incorporate right to go outside ETJ
Entity reserves the right to designate a primary banking services depository outside its ETJ.
Satisfies legal requirement for a resolution to so state.
Investing: Part of Cash Management
Invoicing and
Collection Debt Issuance
Cashiering Disbursements
Investments Safekeeping Banking
Various
components of
the cash
management
process.
Are the controls in place for each? Name three for each.
Step 6: Structure a Portfolio
Built on your cash flow
Built around your risk tolerance
Built on alternative securities
Dependent on market and internal conditions
Structures: laddering or otherwise
Rate anticipation ideas
Structuring a Portfolio requires an Economic View
In today’s Economic Landscape what is Going On ?
Major Market Forces - Now
How will these affect the market generally?
Federal Reserve tapering and QE plans A Yellen Fed - focusing on mortgage rates
Employment
Inflation
Global rates
Housing
Step 7: Reporting
Aides your monitoring
Detail on all aspects of portfolio
Summary is critical to spot trends and risk
Measuring risk is a primary functions
Too long?
Too short?
Not diversified?
Reflective of policy objectives?
Banking Impacts Your Treasury
A key element of Treasury Timely receipt of funds Safety of funds Investment alternatives
Structure of accounts
Type and use of accounts
Services
Fraud services and cost efficiencies
Collateral safety
Depository Law
Local Government Code Chapter 105
For cities and school districts
Banks, CU or savings associations
Resolution for ETJ banks required (105.011b2)
Notice required (21 days from deadline)
Allows for more than one depository (105.015)
Term limit of 5 years (105.017)
Deposit of funds in 60 days
Collateral portions superceded by PFCA (Govt Code 2257)
Special Depositories
Local Government Code Chapter 131
In case of a bank failure or business suspension or
regulatory take-over
Local government can name special depository
Special depository is to pay entity all funds due within
three years
TEA Process The TEA process involves either a Bid or RFP. What are the benefits of each?
TEA Contract
Required form.
Ties to RFP/Bid.
Two years plus two year extension.
Key choice of collateral.
Paying for Banking
It all goes back to the cost
It all depends on interest rates
Fee Basis Paying the service fees directly in cash
Compensating Balance Providing a balance which earns interest that then pays the fees
The earnings credit rate (ECR) is used to earn the interest
Compensating Balance
The balance is maintained and earns interest
The interest rate is the ECR
Earnings Credit Rate Applies only to the required balance
The interest is used to pay the fees Fees = (comp balance x ECR)/12
Currently 100% FDIC insured Generates a FDIC fee (varies 0.10-0.13%) Until January 1, 2013 – extension status unknown
Calculating a ‘Comp Balance’
Daily Ledger Balances
- Federal Reserve Requirement (10%)
- Average Daily Float
Average Collected Balance
x Earnings Credit Rate (1.25%) (annualized)
Net Monthly Earnings
Account Analysis Your Invoice
Lists each service used
States cost of each service
States amount of service used in period
Calculates fee basis of service
Calculates compensating balance for service
Based on a reduced ‘earnings credit rate’ (ECR)
Totals all fees
Computes excess/(deficit)
District earned $4,078 but needed only $ 2,569
Left $1,509 behind
Volume * price = Fee or Balance Required
BASED ON FEES SET BY CONTRACT
Mo. Contract Total
Service Description Vol Fee Cost
Master Account Maintenance Fee 8.0000 0.00
Subsidiary Account Maintenance 8.0000 0.00
Money Market Account Maintenance Fee 8.0000 0.00
0.00
Investment Sweep Maintenance 50.0000 0.00
Dr/Cr Sweep Transaction Fee 0.0000 0.00
ZBA Account - Subsidiary 8.0000 0.00
0.00
Checks/Debits Posted 0.0500 0.00
Branch Credits Posted - Electronic 0.1000 0.00
Automated Services - Balance & Detail
Acct Balance Report 0.00
Online Access Maintenance Fee 5.0000 0.00
Online Access Subscription Fee 5.0000 0.00
Previous day Reporting 10.0000 0.00
Previous Day Dr/Cr Items 10.0000 35,210.00
Image Capture Per Item 0.0300 0.00
Image Retention Per Item 0.0200 0.00
Branch Deposits
Commercial Account Maintenance 20.0000 0.00
Branch Credits Posted 0.5000 0.00
Branch Immediate Verification 0.1000 0.00
TOTAL FEES AT CURRENT MONTH VOLUMES
From the
monthly account analysis, input
the volumes for
each service.
Match the total
fees in the spread sheet to
the account analysis.
If they do not
match then a fee is wrong.
Check it!
A critical
monthly responsibility
Create a monthly CHECKLIST for your analysis fees.
ECR Rates Matter
Pool rates are about 0.10%-0.15%
ECR rates are 0.55%-0.70%
Impact on balance and FDIC pass-through
Should comp balance be on your investment report?
Fee $ 1,500 $ 1,500
ECR 0.20% 0.70%
Balance Req. $ 9,000,000 $ 2,500,000
FDIC Fee $ 9,000 $ 2,500
The 3% Threshold
Fed Funds Below 3% Above 3%
ECR 0.07% 2.00%
Fees/Earn. $ 1,500 $ 1,500
Bal. Required
$ 2,500,000 $ 900,000
Outside % 0.15% 4.00%
Outside Earn $ 312 $ 3,000 Above 3%
ECR will be half Fed
Funds
Evaluating Banks
Services Basic versus enhanced services
Does the bank keep up with technology?
Fees Transition or retention incentives?
Adjust for bundled services
Compare apples to apples
Earnings Look at ECR, interest bearing, MMA and sweeps
Carry-Over Management
Managed by you monthly
Insist on quarterly/semi-annual carry-over
Adjust your balances monthly before close
Managed by an automatic sweep
Sweep excess funds to a money market fund or account
Have the sweep set at either:
Compensating balance amount
Zero
The Value of a “Carry-over”
Daily ledger $ 550,000
- Federal Reserve $ 66,000-
-Daily Float $ 35,000-
Average Collected $ 449,000
x ECR 3.25%/12
Earnings on ECR $ 1,216
Fees $ 1,000
Excess Paid $ 216
Excess earnings are retained by the bank - with
“carry-over there is no settlement monthly
The Value of a “Carry-over”
Daily ledger $ 396,384
- Federal Reserve $ 66,000-
-Daily Float $ 35,000-
Average Collected $ 295,384
x ECR 3.25%/12
Earnings from ECR $ 1,000
Fees to be Paid $ 800
Deficit $ 200-
With a carry-over to the next month balance is
reduced and a deficit balances prior month excess.
Bank Focus #1: Safety & Fraud
Same old issues: safety and service Collateral and margins FDIC coverage Bank credit Delivery versus payment settlement Independent transactions and parties
New approaches Electronic processing Payee positive pay Courier options Pooling of collateral Security sign-ons (PINS and secure-cards) Online investment access
Positive Pay
A requirement for safety
Relieves liability for fraudulent checks received Add payee positive pay for double fraud protection
City sends bank the check register
Data base of valid checks screens all checks received Check number and amount standard New developments on payee and signatures
City gets option to review and approve
Without positive pay City retains liability
Stored Value Cards
Originally for payroll alternative (“pay card”)
Creates a debit card for employees
Internal Payroll Processed as direct deposit
Funds go to the card
Point of sale, bank or ATM use
Stops liability for lost checks
Cuts cost of checks
$0.06 versus $0.03
Reconciliation (ARP)
Serial Sort physical checks returned in order Phasing out with Check 21
Partial Reconciliation
paid check report
Full Reconciliation matches issued and paid outstanding items, voids & cancels
Deposit Reconciliation
Location identification
Combining with Positive Pay
Price savings Staff time savings
Mobile Access
Smart phone applications
Retrieve balance and transaction detail
Positive pay exceptions
Event messaging
Usually no cost
Security considerations
Bank Focus #2: Expediting funds
Move funds and documents
as expeditiously and efficiently as possible
Use technology to minimize cost
Use technology to increase access to funds
for longer earning period
Use physical and electronic services
May require changing internal processes
Truncated Checks
Key to eliminating paper documents
Replaces checks with digital images
“substitute checks”
IRD (image replacement documents)
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Your Tools for Expediting
Physical Minimization Moving away from documents Capturing documents electronically Minimizing physical handling
Electronic Maximization Imaging Wires ACH Sweeps Remote Deposit Payment/receivable processing Smart safes
Monetary Rewards
Availability schedules and policies Staff time
Sweeps
Account A
Account B
Account C
Account D
Master Account
Money Market Fund
O/Nite Sweep
Sweeps expedite funds plus allow you to automatically drill down to a comp balance or to zero balance
Remote Check Acceptance
On-site scanning of checks received
Transmission of scanned image: check and coupons Customization of fields Imaged and archived information
Scan and send from cashier or back office
Savings Float savings on deposit speed Courier (or staff transit) savings Liability savings Extended deposit times (9:00pm)
Remote Deposit
New delivery system Minimal internal disruption
Usually less costly clearing
Process Your cashiers total checks
Cashiers scan checks
Checks retained (7 days) then shredded
Transmit to bank
Same day deposit and clearing
Clearing reported on next day reports
Smart Safes
Available through banks or courier services
Deposit directly into smart safe
Sealed bags created
Deposit slip created on-site
Electronic transmission to courier
Courier periodic pick-up
Daily credit
RCK – Represented Check
Transforming NSF consumer checks to ACH
NSF checks are not represented next day
NSF checks converted to ACH
ACH direct debits are processed on a specific
date
Increased collections benefit
Image Lockboxes
Image lockbox consolidates
High volume, low dollar payments (retail lockbox)
Utility payments or tax payments
Low volume, high dollar payments (wholesale lockbox)
Image lockboxes truncate and speed receipts
Checks received at unique post office box
Box cleared up to 8 times a day
Processing 24/6
All transactions are imaged
Images/Records sent to you electronically
Records post directly to general ledger
Vaults and Deposits
Vault services are expensive Reduce through internal planning
Check rolling and strapping alternatives/discounts
Online vault provide for coin/currency orders
Deposit location tracking groups info, aides recon
Analyze your own coin/currency flows and ‘orders’
Service List Alerts
Research and confirmations
Signature control
Creation versus retrieval
Intra-day versus prior day
Maintenance charges
Module charges
Fax and phone charges
Deposit corrections
Standard versus optional reports
File versus detail transmissions
Tech Drives Future Services ACH key to many services
Banks move to service providers
Consolidation of transactions
Consolidating Payments E-Payables
Then
Invoice preparation and mailing
Manual sorts, opening and extracting
Manual batching and balancing
Armored car delivery
Check clearing availability
Now
Generate payables file for ACH/wire/print/mail service
Receive a file of bills paid
Virtual Payables
Single Use Accounts (SUA)
Non-plastic card electronic payment (virtual card)
Expiration date control
Can increase rebate potential
Supplier receives payment immediately – payor pays on statement date
Steps Checks Virtual Card
1 Receive invoice Receive invoice
2 Approve invoice Approve invoice
3 Cut check Generate single use account online
4 Mail check to vendor Email payment info to vendor
5 Vendor cashes check Vendor swipes virtual card online
6 Manual reconciliation Automatic reconciliation
Check Outsourcing
Industry cost to print check = $5-12
Print to mail services: bank prints and mails at bulk rate
Send file of checks to bank
Instead of to the printer in-house
Bank prints checks with your logo/specs
Bank utilizes sort for postage discount
Eventually move to ACH payments
E-checks
Electronic checks
Electronic version if paper check
Check payor provides
ABA routing #
Account number
Name on account
E-Receivables
Tied to an image lockbox
Scan the check and the document at bank site
Checks and documents imaged and captured
Combines with all receivables
Transmitted to your g/l with detail
Info archived at bank
ACH e-Lockbox
Collects payments from third-party
bill pay services and PC banking
Captured prior to posting to DDA
Captures vendor info and addenda
Consolidates in ACH receiver system
Sent to you for direct application to A/R
E-Commerce and E-Funding
E-Payables and E-Receivables
Converting paper to electronic transactions
EDI: Not a technology – a change in process
Electronic data interchange
Extending bank operations
Major cost-savings developments
Purchasing Cards
Limits purchases on SCI product types
Limits use by day or week
Agreement issues
Liability for unauthorized use
Billing disputes and chargebacks
Credit limits
Proprietary information
Arbitration
Termination and revocation
Controlled Disbursement
Outdated? Use of alternatives limit use
Sweeps eliminate usefulness
Cost is lower to sweep
Using remote bank to clear checks
Cash management purposes - not delay
Elimination with electronic capture
Additional costs make it less than worthwhile
Merchant Card Processing
Processing Visa, MC, Discover
Access to funds
Key element is PCI Compliance
Compare to State Contract
Training
Information
Credit and debit cards
Merchant Services Fees
Merchant Service Providers Can be banks or other providers
Payment Company Fees Differ by type “merchant”
Merchant Service Provider Fees Set $ fee and % fee
Dependent on your size/volume of payments