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investment transactions with the same individual(s) with whom business is conducted on <br />behalf of the City. <br />3. Delegation of Authority - Authority to manage the investment program is granted <br />to the Finance Director and other authorized personnel. Additional authorized personnel <br />include any other person or position approved by the City Manager. The City may seek <br />professional advice and therefore may contract with a federally registered investment <br />advisory firm that specializes in public funds fixed income management. This <br />engagement would be set forth in a separate Investment Advisory Agreement approved <br />by the Finance Director. No person may engage in an investment transaction except as <br />provided under the terms of this policy. The Finance Director shall be responsible for all <br />transactions undertaken and shall establish a system of controls to regulate the activities <br />of subordinate officials. <br />4. Bid Process —The Finance Director or other authorized personnel shall analyze <br />and determine cash flow needs. Using this information and considering market <br />conditions, City staff or investment managers, or both, as the case may be, shall <br />determine approximate maturity date or dates, analyze and select one or more optimal <br />types of investments, and competitively bid the security or securities in question when <br />feasible and appropriate. <br />V. Broker Dealers, Safekeeping and Custody <br />1. Authorized Financial Dealers and Institutions — The City shall maintain a list of <br />qualified financial institutions as follows: <br />a. Qualified public depositories in accordance with Chapter 280, Florida <br />Statutes, <br />b. A primary or regional broker dealer that qualifies under Securities and <br />Exchange Commission (SEC) Rule 150-1 (uniform net capital rule) with a <br />minimum net capital of $10 million ($10,000,000) and at least five years of <br />operation; a member of Financial Industry Regulatory Authority (FINRA), and <br />Securities Investors Protection Corporation (SIPC); <br />Both lists shall be reviewed by the Finance Director at least annually. <br />2. Annual Review - An annual review of the qualified financial institutions and <br />broker/dealers will be conducted by the Finance Director and/or Investment Advisor <br />under the direction of the City. <br />3. Delivery vs. Payment - Securities transactions between a broker-dealer and the <br />safekeeping agent or custodian involving purchase or sale of securities by transfer of <br />money or securities must be made on a "delivery vs. payment" basis, if applicable, to <br />ensure that the custodian will have the security or money, as appropriate, in hand at the <br />conclusion of the transaction. <br />:] <br />