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transactions with the same individual(s) with whom business is conducted on behalf of the <br />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 engagement <br />would be set forth in a separate Investment Advisory Agreement approved by the Finance <br />Director. No person may engage in an investment transaction except as provided under <br />the terms of this policy. The Finance Director shall be responsible for all transactions <br />undertaken and shall establish a system of controls to regulate the activities of subordinate <br />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 <br />staff or investment managers, or both, as the case may be, shall determine approximate <br />maturity date or dates, analyze and select one or more optimal types of investments, and <br />competitively bid the 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 <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 under <br />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 ensure <br />that the custodian will have the security or money, as appropriate, in hand at the conclusion <br />of the transaction. <br />4. Safekeeping, Custody & Perfection of Interest - Securities shall be held with a third <br />party; and all securities purchased by, and all collateral obtained by, the unit of local <br />4 <br />