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Section II - Policy No 3 - Investment

Chenango Valley Central School District · Section II · Policy No. 3

Investment

Adopted
January 19, 1994
Reviewed
May 17, 2000; March 21, 2001; April 28, 2003; April 26, 2004; January 18, 2006; March 21, 2007; June 18, 2008; October 19, 2010; January 18, 2012; October 24, 2018; July 2, 2019; July 7, 2020; July 6, 2021; July 5, 2023; July 1, 2025; July 15, 2026
Revised
November 20, 1996; March 17, 1999; June 17, 2009; November 20, 2013; January 21, 2015; October 18, 2017; July 5, 2022; July 2, 2024

I. Scope This investment policy applies to all monies and other financial resources available for investment on behalf of Chenango Valley Central School District.

II. Objectives The primary objectives of Chenango Valley Central School District’s investment activities are, in priority order:
  • To conform with all applicable federal, state and other legal requirements (legal);
  • To adequately safeguard principal (safety);
  • To provide sufficient liquidity to meet all operating requirements (liquidity); and
  • To obtain a reasonable rate of return (yield).
III. Delegation of Authority The Board of Education’s responsibility for administration of the investment program is delegated to the Treasurer, School Business ExecutiveandDeputy Treasurer, who shall establish written procedures for the operation of the investment program consistent with these investment guidelines. Such procedures shall include an adequate internal control structure to provide a satisfactory level of accountability based on a database or records incorporating description and amounts of investments, transaction dates, and other relevant information and regulate the activities of subordinate employees.

IV. Prudence All participants in the investment process shall seek to act responsibly as custodians of the public trust and shall avoid any transaction that might impair public confidence in the Chenango Valley Central School to govern effectively. 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 safety of the principal as well as the probable outcome to be derived.

All participants involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions.

V. Diversification It is the policy of the Chenango Valley Central School District to diversify its deposits and investments by financial institution, by investment instrument, and by maturity scheduling.

VI. Internal Controls It is the policy of the Chenango Valley Central School District for all monies collected by any officer or employee of the school district to transfer those funds to the District Business Office as soon as possible for expedient transport to CBO for deposit. District Business Office and CBO are both responsible for establishing and maintaining an internal control structure to provide reasonable, but not absolute, assurance that deposits and investments are safeguarded against loss from unauthorized use or disposition, that transactions are executed in accordance with management’s authorization and recorded properly, and are managed in compliance with applicable laws and regulations.

VII. Designation of Depositories The banks and trust companies authorized for the deposit of monies up to the maximum amounts are to be designated at the Reorganization Meeting annually. General Municipal Law Section 10 defines “bank” as a bank as defined by the New York Banking Law or a national banking association located and authorized to do business in New York. General Municipal Law Section 10 defines “trust company” as a trust company as defined by the New York Banking Law and located and authorized to do business in New York.

VIII. Collateral of Deposits In accordance with the provisions of General Municipal Law, §10, all deposits of Chenango Valley Central School District including certificates of deposit and special time deposits, in excess of the amount insured under the provisions of the Federal Deposit Insurance Act shall be secured:
  1. By a pledge of “eligible securities” with an aggregate “market value” as provided by General Municipal Law §10, equal to the aggregate amount of deposits from the categories designated in Appendix A to the policy.
  2. By an eligible “irrevocable letter of credit” issued by a qualified bank other than the bank with the deposits in favor of the Chenango Valley Central School District for a term not to exceed 90 days with an aggregate value equal to 140% of the aggregate amount of deposits and the agreed upon interest, if any. A qualified bank is one whose commercial paper and other unsecured short-term debt obligations are rated in one of the three highest rating categories by at least one nationally recognized statistical rating organization or by a bank that is in compliance with applicable federal minimum risk-based capital requirements.
  3. By an eligible surety bond payable to the Chenango Valley Central School District for an amount at least equal to 100% of the aggregate amount of deposits and the agreed upon interest, if any, executed by an insurance company authorized to do business in New York State, whose claims – paying ability is rated in the highest rating category by at least two nationally recognized statistical rating organizations.
IX. Safekeeping and Collateralization Eligible securities used for collateralizing deposits shall be held by (the depository and/or a third party) bank or trust company subject to security and custodial agreements. The security agreement shall provide that eligible securities are being pledged to secure Chenango Valley Central School District deposits together with agreed upon interest, if any, and any costs or expenses arising out of the collection of such deposits upon default. It shall also provide the conditions under which the securities may be sold, presented for payment, substituted or released and the events, including the events of default, which will enable the Chenango Valley Central School District to exercise its rights against the pledged securities. In the event that such securities are not registered or inscribed in the name of the Chenango Valley Central School District, such securities shall be delivered in a form suitable for transfer or with an assignment in blank to the Chenango Valley Central School District or its custodial bank. The custodial agreement shall provide that securities held by the bank or trust company, as agent of and custodian for, the Chenango Valley Central School District, will be kept separate and apart from the general assets of the custodial bank or trust company and will not, in any circumstances, be commingled with or become part of the backing for any other deposit or other liabilities. The agreement shall provide for the manner in which the custodian shall confirm the receipt, substitution or release of the securities. The agreement shall provide for the frequency of revaluation of eligible securities for the substitution of securities when a change in the rating of a security may cause ineligibility. Such agreement shall include all provisions necessary to provide the Chenango Valley Central School District a perfected interest in the securities.

X. Permitted Investments As authorized by General Municipal Law, §11, the Chenango Valley Central School District authorizes the investment of monies not required for immediate expenditure for terms not to exceed its projected cash flow needs in the following types of investments:
  • Special time deposit accounts in a bank or trust company as defined by Genera Municipal Law §10;
  • Certificates of deposit in a bank or trust company as defined by General Municipal Law §10;
  • Obligations of the United States of America;
  • Obligations guaranteed by agencies of the United States of America where the payment of principle and interest are guaranteed by the United States of America;
  • Obligations of the State of New York;
  • Obligations issued pursuant to LFL §24.00 or 25.00 (with approval of the State Comptroller) by any municipality, school district or district corporation other than the Chenango Valley Central School District.
  • Obligations of public authorities, public housing authorities, urban renewal agencies and industrial development agencies where the general State statutes governing such entities or whose specific enabling legislation authorizes such investments.
  • Certificates of Participation (COPs) issued pursuant to General Municipal Law §109-b.
  • Obligations of Chenango Valley Central School District, but only with any monies in a reserve fund established pursuant to General Municipal Law §§6-c, 6-d, 6-e, 6-h, 6-j, 6-k, 6-l, 6-m, or 6-n. All investment obligations shall be payable or redeemable at the option of the Chenango Valley Central School District within such times as the proceeds will be needed to meet expenditures for purposes for which the moneys were provided and, in the case of obligations purchased with the proceeds of bonds or notes, shall be payable or redeemable at the option of the Chenango Valley Central School District within two years of the date of purchase.
XI. Authorized Financial Institutions and Dealers The Chenango Valley Central School District shall maintain a list of financial institutions and dealers approved for investment purposes and establish appropriate limits to the amount of investments, which can be made with each financial institution or dealer. All financial institutions with which the Chenango Valley Central School District conducts business must be credit worthy. Banks shall provide their most recent Consolidated Report of Condition (Call Report) at the request of the Chenango Valley Central School District. Security deals not affiliated with a bank shall be required to be classified as reporting dealers affiliated with the New York Federal Reserve Bank, as primary dealers. The School District Business Executive and Treasurer, jointly, are responsible for evaluating the financial position and maintaining a listing of proposed depositaries, trading partners and custodians.

XII. Purchase of Investments The Treasurer or Deputy Treasurer are authorized to contract for the purchase of investments:
  1. Directly, including through a repurchase agreement, from an authorized trading partner.

  2. By participation in a cooperative investment program with another authorized governmental entity pursuant to Article 5G of the General Municipal Law where such program meets all the requirements set forth in the Office of the State Comptroller Opinion No. 88-46, and the specific program has been authorized by the Board of Education.

  3. By utilizing an ongoing investment program with an authorized trading partner pursuant to a contract authorized by the Board of Education. All purchased obligations, unless registered or inscribed in the name of Chenango Valley Central School District, shall be purchased through, delivered to and held in the custody of a bank or trust company. Such obligations shall be purchased, sold or presented for redemption or payment by such bank or trust company only in accordance with prior written authorization from the officer authorized to make the investment. All such transactions shall be confirmed in writing to the Chenango Valley Central School District by the bank or trust company. Any obligation held in the custody of a bank or trust company shall be held pursuant to a written custodial agreement as described in General Municipal Law, §10. The custodial agreement shall provide that securities held by the bank or trust company, as agent of and custodian for, the Chenango Valley Central School District, will be kept separate and apart from the general assets of the custodial bank or trust company and will not, in any circumstances, be commingled with or become part of the backing for any other deposit or other liabilities. The agreement shall provide for the manner in which the custodian shall confirm the receipt, substitution or release of the securities. Such agreement shall include all provisions necessary to provide the local government a perfected interest in the securities. The agreement shall provide for the frequency of revaluation of eligible securities and for the substitution of securities when a change in the rating of a security may cause ineligibility.