6240-R Investments Regulation
- 6000: Fiscal Management Goals
(This policy replaces previously approved Board of Education Policy #9350)
Authorized Investments
- As authorized by General Municipal Law Section 11, the Assistant Superintendent for Finance and Operations is authorized to invest all available District funds, not required for immediate expenditure, including proceeds of obligations and Reserve Funds, in the following types of investment instruments:
- Savings Accounts or Money Market Accounts of designated banks;
- Certificates of Deposit issued by a bank or trust company located in and authorized to do business in New York State;
- Demand Deposit Accounts in a bank or trust company located in and authorized to do business in New York State; Obligations of New York State; Obligations of the United States Government and its agencies (U.S. Treasury Bills and Notes);
- Obligations of public authorities, public housing authorities, urban renewal agencies and industrial development agencies where general State statutes governing such entities authorize such investments.
- All funds except Reserve Funds may be invested in Revenue Anticipation Notes or Tax Anticipation Notes of other school districts and municipalities, with the approval of the State Comptroller.
Direct or Cooperative Investments
Investments may be made either directly from an authorized trading partner or by participation in a cooperative investment agreement.
- Cooperative investment agreements may be made with certain municipal corporations; any New York State County (outside of New York City), city, town, village, BOCES, fire district or school district, pursuant to General Municipal Law Article 5-G.
- Cooperative investment agreements, pursuant to General Municipal Law Article 3-A, must address: the governing board of cooperative, lead participant, proportional interest, the cooperative’s investment policy, contributions and distributions, apportionment of administrative expenses and costs, methodology to determine participant’s interest, determination of market value at least monthly, portfolio interest rate testing at least monthly, irrevocable letter of credit, professional services, contribution confirmations, monthly statements, notification of distribution deferrals or unanticipated losses or material adverse events, annual independent audit, annual information statements, annual investment reports and governing board rating disclosure.
Conditions
All investments made pursuant to this investment policy will comply with the following
conditions:
- Collateral
- Savings accounts, money market accounts, letters of credit, time deposit accounts and certificates of deposit will be fully secured by insurance of the Federal Deposit Insurance Corporation or by obligations of New York State, the United States, New York State school districts and federal agencies whose principal and interest are guaranteed by the United States. The market value of collateral shall at all times exceed, by 5%, the principal amount of the funds on deposit. Collateral will be monitored no less frequently than on a weekly basis.
- Collateral will not be required with respect to the direct purchase of obligations of New York State, the United States and Federal agencies, the principal and interest of which are guaranteed by the United States Government.
- Delivery of Securities
- Payment of funds may only be made upon receipt of collateral or other acceptable form of security, or upon the delivery of government obligations. Written confirmation of delivery shall be obtained from the custodial bank.
- Designation of Custodial Bank
- At their Organization Meeting, the Board will designate commercial banks or trust companies authorized to do business in the State of New York to act as Custodial Bank of the District’s investments.
- When purchasing eligible securities, the seller will be required to transfer the securities to the District’s Custodial Bank(s).
- Written Contracts
Written contracts are required for certificates of deposit and custodial undertakings. With respect to the purchase of direct obligations of the U.S., New York State or other governmental entities in which monies may be invested, the interests of the District will be adequately protected by conditioning payment on the physical delivery of purchased securities to the District or custodian or in the case of book-entry transactions, on the crediting of purchased securities to the Custodian’s Federal Reserve System account. All purchases will be confirmed promptly in writing to the District.- The following written contracts are required:
- Written agreements will be required for the purchase of all certificates of deposit.
- A written contract will be required with Custodial Bank(s).
- Selection of Financial Institutions
The Assistant Superintendent for Finance and Operations will periodically monitor, to the extent practical but not less than annually, the financial strength, creditworthiness, experience, size and any other criteria of importance to the District, of all institutions and trading partners through which the District's investments are made.
Investments in time deposits and certificates of deposit are to be made only with commercial banks or trust companies, as permitted by law.
- Operations, Audit and Reporting
- The Assistant Superintendent for Finance and Operations or their designee will authorize the purchase and sale of all securities and deposits on behalf of the District. Oral directions concerning the purchase or sale of securities will be confirmed in writing. The District will pay for purchased securities upon the simultaneous delivery or book-entry thereof.
- The District will encourage the purchase and sale of securities through a competitive process involving telephone solicitation for at least three (3) quotations.
- The independent auditors may audit the investment proceeds of the District for compliance with the provisions of this Investment Regulation.
- Monthly investment reports will be furnished to the Board of Education.
Ref: Education Law §§1604-a; 1723-a; 3651; 3652
Local Finance Law §24.00; 25.00; 165.00
General Municipal Law 6(d); 6-j; 6(l-n);6(p); 6(r) 10; 11; 39; Article 3-A; Article 5-G
Approved by the Board of Education: 12/17/09
Approved as amended by the Board of Education / annual review: 07/07/11
Revision Approved by the Board of Education: 11/21/19
Approved by the Board of Education: 10/20/22
Revision Approved by the Board of Education: 06/20/24
