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and therefore may contract with a federally registered investment advisory firm that specializes in <br />public funds fixed income management. This engagement would be set forth in a separate <br />Investment Advisory Agreement approved by the Finance Director. No person may engage in an <br />investment transaction except as provided under the terms of this policy. The Finance Director <br />shall be responsible for all transactions undertaken and shall establish a system of controls to <br />regulate the activities of subordinate officials. <br />4. Bid Process —The Finance Director or other authorized personnel shall analyze and <br />determine cash flow needs. Using this information and considering market conditions, City staff <br />or investment managers, or both, as the case may be, shall determine approximate maturity date or <br />dates, analyze and select one or more optimal types of investments, and competitively bid the <br />security or securities in question when feasible and appropriate. <br />V. Broker Dealers, Safekeeping and Custody <br />1. Authorized Financial Dealers and Institutions — The City shall maintain a list of qualified <br />financial institutions as follows: <br />a. Qualified public depositories in accordance with Chapter 280, Florida Statutes, <br />b. A primary or regional broker dealer that qualifies under Securities and Exchange <br />Commission (SEC) Rule 15C3-1 (uniform net capital rule) with a minimum net capital of <br />$10 million ($10,000,000) and at least five years of operation; a member of Financial <br />Industry Regulatory Authority (FINRA), and Securities Investors Protection Corporation <br />(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 broker/dealers <br />will be conducted by the Finance Director and/or Investment Advisor under the direction of the <br />City. <br />3. Delivery vs. Payment - Securities transactions between a broker-dealer and the safekeeping <br />agent or custodian involving purchase or sale of securities by transfer of money or securities must <br />be made on a "delivery vs. payment" basis, if applicable, to ensure that the custodian will have the <br />security or money, as appropriate, in hand at the conclusion of the transaction. <br />4. Safekeeping, Custody & Perfection of Interest - Securities shall be held with a third party; <br />and all securities purchased by, and all collateral obtained by, the unit of local government should <br />be properly designated as an asset of the unit of local government. No withdrawal of securities, in <br />whole or in part, shall be made from safekeeping or custody, except by the Finance Director or <br />other designee by the City Manager on an as -needed basis. <br />To protect against potential fraud and embezzlement, the assets of the City shall be secured through <br />third -party custody and safekeeping procedures. Bearer instruments shall be held only through <br />third party institutions. Investment officials shall be bonded to protect the public against possible <br />embezzlement and malfeasance. Collateralized securities such as repurchase agreements shall be <br />purchased using the delivery — vs- payment procedure. Unless prevailing practices or economic <br />4 <br />