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RE 03-25-97.2 RESOLUTION NO. 032597.2 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COPPELL, TEXAS, AMENDING WRITTEN INVESTMENT POLICY OF THE CITY OF COPPELL AS PROVIDED BY THE PUBLIC FUNDS INVESTMENT ACT, CHAPTER 2256, TEXAS GOVERNMENT CODE; AND PROVIDING AN EFFECTIVE DATE. WHEREAS, the City Council of the City of Coppell, Texas has heretofore adopted a written investment policy as required by Chapter 2256 of the Texas Government Code; and WltEREAS, it is necessary and in the public interest to make certain amendments to the written investment policy; NOW, TIIEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF COPPELL, TEXAS: SECTION 1. That the written investment policy of the City of Coppell, heretofore adopted as Exhibit "A" to Resolution No. 082295.1 and as hereto for amended is hereby amended in the following respects: A. By amending Section III to designate the Deputy City Manager as a member of the investment committee; B. By amending authorized investments Section V(I)(H) and (I) to read as follows: H. No-load money market mutual funds that are regulated by the Securities and Exchange Commission, that has a dollar weighted average stated maturity of 90 days or fewer and includes in its investment objectives the maintenance ora stable net asset value orS1 for each share. I. No-load money market mutual funds that are registered with the Securities and Exchange Commission, having an average weighted maturity of less than two years and is invested or secured in obligations described in A through D above. The fund must maintain an investment grade rating of AAA, or its equivalent by at least one nationally recognized rating firm. The fund must conform to the requirements relating to the eligibility of investment pools. 1 SS7378 C. By amending Section VII Insurance or Collateral to raise the collateralization level to one hundred five (105%) percent of market value of principal and accrued interest on the deposit or investments less the amount insured by the FDIC or FSLIC. SECTION 2. This resolution shall become effective immediately from and at~er its passage, and it is accordingly so resolved. DULY PASSED and approved by the City Council of the City of Coppell, Texas, on this the '~f'¢/7 day of ,//?/O6: r-C ~/~ ~ 1997. APPROVED: TOM MORTON, MAYOR ATTEST: KATHLEEN ROACH, CITY SECRETARY APPROVED AS TO FORM: PETER G. SMITH, CITY ATTORNEY (PGS/ttl 2/26/97) 2 ss7378 INTRODUCTION The purpose of this document is to set forth specific investment policy and strategy guidelines for the City of Coppell in order to achieve the goals of safety, liquidity, yield, and public trust for all investment activity. The City Council of the City of Coppell shall review its investment strategies and policy not less than annually. This policy serves to satisfy the statutory requirement of Chapter 2256, Texas Government Code as mended, to define, adopt and review a formal investment strategy and policy. INVESTMENT STRATEGY The City of Coppeli maintains portfolios which ufili?e four specific investment strategy considerations designed to address the unique characteristics of the fund groups represented in the portfolios: A. Investment strategies for operating funds and commingled pools containing operating funds have as their primary objective to assure that anticipated cash flows are matched with adequate investment liquidity. The secondary objective is to create a portfolio structure which will experience minimal volatility during economic cycles. This may be accomplished by purchasing high quality, short-to- medium-term securities which will complement each other in a laddered or barbell maturity structure. The dollar weighted average maturity of 365 days or less will be calculated using the stated final maturity date of each security. B. Investment strategies for debt service funds shall have as the primary objective the assurance of investment liquidity adequate to cover the debt service obligation on the required payment date. Securities purchased shall not have a stated final maturity date which exceeds the debt service payment date. C. Investment strategies for debt service reserve funds shall have as the primary objective the ability to generate a dependable revenue stream to the appropriate debt service fund from securities with a low degree of volatility. Securities should be of high quality and, except as may be required by the bond ordinance specific to an individual issue, of short to intermediate-term maturities. Volatility shall be further controlled through maturity and quality range, without paying premium, if at all possible. Such securities will tend to hold their value during economic cycles. D. Investment strategies for special projects or special purpose fund portfolios will have as their primary objective to assure that anticipated cash flows are matched with adequate investment liquidity. These portfolios should include at least 10% in highly liquid securities to allow for flexibility and unanticipated project outlays. The stated final maturity dates of securities held should not exceed the estimated project completion date. INVESTMFNT POLICY I. SCOPE This investment policy applies to all financial assets of the City of Coppell. These funds are accounted for in the City's Comprehensive Annual Financial Report (CAFR) and include: * General Fund * Special Revenue Funds * Debt Service Funds * Capital Projects Funds * Proprietary Funds * Trust and Agency Funds The City of Copper shall manage and invest its cash with four objectives, listed in order of priority: Safety, Liquidity, Yield, and Public Trust. The safety oftbe principal invested always remains the primary objective. All investments shall be designed and managed in a manner responsive to the public trust and consistent with State and Local law. The City shall maintain a comprehensive cash management program which includes collection of accounts receivable, vendor payment in accordance with invoice terms, and prudent investment of available cash. Cash management is defined as the process of managing monies in order to insure maximum cash availability and maximum yield on short-term investment of pooled idle cash. Safety_ The primary objective of the City's investment activity is the preservation of capital in the overall portfolio. Each investment transaction shall be conducted in a manner to avoid capital losses, whether they be from securities default or erosion of market value. Liquidity The City's investment portfolio shall be strdcmred such that the City is able to meet all obligations in a timely manner. This shall be achieved by matching investment maturities with forecasted cash flow requirements and by investing in securities with active secondary markets. Yield The City's cash management portfolio shall be designed with the objective of regularly exceeding the average rate of return on three-month U.S. Treasury B'flls. The investment program shall 2 seek to augment returns above this threshold consistent with risk limitations identified herein and prudent investment polices. Public Trust All participants in the City's investment process shall seek to act responsibly as custodians of the public trust. Investment officials shall avoid any transaction which might impair public confidence in the City's ability to govern effectively. Ill. RESPONSIBILITY AND CONTROL Investment Committee An Investment Committee, consisting of the Deputy City Manager, the Director of Finance, Assistant Finance Director and Chairman of the Council Finance Committee, shall meet at least quarterly to determine operational strategies and to monitor results. The Investment Committee shall include in its deliberation such topics as: performance reports, economic outlook, portfolio diversification, maturity structure, potential risk to the City's funds, authorized brokers and dealers, and the target rate of return on the investment portfolio. Delegation of Authority_ and Trainine Authority to manage the City's investment program is derived from a resolution of the City Council. The Director of Finance, the Assistant Finance Director and the Chief Accountant/Budget Officer are designated as the investment officers of the City and are responsible for investment decisions and activities. The Director of Finance shall establish written procedures for the operation of the investment program, consistent with this investment policy. The investment officers shall attend at least one training session relating to the officer's responsibility under the Act within 12 months after assuming duties. Internal Controls The Director of Finance is responsible for establishing and maintaining an internal control structure designed to ensure that the assets of the entity are protected from loss, theft or misuse. The internal control structure shall be designed to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognizes that (1) the cost of a control should not exceed the benefits likely to be derived; and (2) the valuation costs and benefits requires estimates and judgements by management. Accordingly, the Director of Finance shall establish a process for annual independent review by an external auditor to assure compliance with policies and procedures. The internal controls shall address the following points: 3 A. Control of collusion. B. Separation of transaction authority from accounting and record keeping. C. Custodial safekeeping. D. Avoidance of physical delivery securities. E. Clear delegation of authority to subordinate staff members. F. Written confirmation for telephone (voice) transactions for investments and wire transfers. G. Development of a wire transfer agreement with the depository bank or third party custodian. Prudence The standard of prudence to be applied by the investment officer shall be the ~prudent investor" rule, which states: ~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 probable safety of their capital as well as the probable income to be derived.~ In determining whether an investment officer has exercised prudence with respect to an investment decision, the determination shall be made taking into consideration: A. The investment of all funds, or funds under the City's control, over which the officer had responsibility rather than a consideration as to the prudence of a single investment. B. Whether the investment decision was consistent with the written investment policy of the City. The investment officer, acting in accordance with written procedures and exercising due diligence, shall not be held personally responsible for a specific security's credit risk or market price changes, providing that these deviations are reported immediately and that appropriate action is taken to control adverse developments. Ethics and CQnfli~ts of Interest City staff 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 the ability to make impartial investment decisions. City staff shall disclose to the City Manager any material financial interests in financial institutions that conduct business with the City and they shall further disclose positions that could be related to the performance of the City's portfolio. City staff shall subordinate their personal financial transactions to those of the City, particularly with regard to timing of purchases and sales. An investment officer of the City who has a personal business relationship with an organization seeking to sell an investment to the City shall file a statement disclosing that personal business interest. An investment officer who is relat~l within the second degree by affinity or 4 consanguinity to an individual seeking to sell an investment to the City shall file a statement disclosing that relationship. A statement required under this subsection must be filed with the Texas Ethics Commission and the governing body of the entity. I1r. REPORTING Quarterly Reporting The Director of Finance shall submit a signed quarterly investment report that summarizes current market conditions, economic developments and anticipated investment conditions. The report shall summarize investment strategies employed in the most recent quarter, and describe the portfolio in terms of investment securities, maturities, risk characteristics, and shall explain the total investment return for the quarter. Annual Report Within 90 days of the end of the fiscal year, the Director of Finance shall present an annual report on the investment program and investment activity. This report may be presented along with the Comprehensive Annual Financial Report to the City Manager and City Council. Methods The quarterly investment report shall include a succinct management summary that provides a clear picture of the status of the current investment portfolio and transactions made over the last quarter. This management summary will be prepared in an manner which will allow the City to ascertain whether investment activities during the reporting period have conformed to the investment policy. The report will be provided to the City Manager and City Council. The report will include the following: A. A listing of individual securities held at the end of the reporting period. B. UnrealiTlxl gains or losses resulting from appreciation or depreciation by listing the beginning and ending book and market value of securities for the period. C. Additions and changes to the market value during the period. D. Average weighted yield to maturity of portfolio on entity investments as compared to applicable benchmark. E. Listing of investment by maturity date. F. The percentage of the total portfolio which each type of investment represents. G. Statement of compliance of the City's investment portfolio with State Law and the investment strategy and policy approved by the City Council. 5 V. INNESTlVH~.NT PORTFOLIO The City shall pursue an active versus a passive portfolio management philosophy. That is, securities may be sold before they mature if market conditions present an opportunity for the City to benefit from the trade. The investment officer will routinely monitor the contents of the portfolio, the available markets, and the relative value of competing instruments, and will adjust the portfolio accordingly. Investments Assets of the City of Coppell may be invested in the following instruments; provided, however, that at no time shall assets of the City be invested in any instrument or security not authorized for investment under the Act, as the Act may from time to time be mended. I. Authorized A. Obligations of the United States of America, its agencies and instrumentalities. B. Direct obligations of the State of Texas or its agencies and instrumentalities. C. Other obligations, the principal of and interest on which are unconditionally guaranteed by the State of Texas or United States of America. D. Obligations of the State, agencies thereof, Counties, Cities, and other political subdivisions of any state having been rated as investment quality by a nationally recognized investment rating firm, and having received a rating of not less than ~A~ or its equivalent. E. Certificates of Deposit of state and national banks domiciled in Texas, guaranteed or insured by the Federal Deposit Insurance or its successor or secured by obligations described in A through D above, which are intended to include all direct agency or instrumentality issued mortgage backed securities rated AAA by a nationally recognized rating agency, or by Article 2529b-1, V.T.C.S., and that have a market value of not less than the principal amount of the certificates. F. Fully collateralized direct repurchase agreements with a defined termination date secured by obligations of the United States or its agencies and instrumentalities pledged with a third party, selected by the Director of Finance, other than an agency for the pledgor. Repurchase agreements must be purchased through a primary government securities dealer, as defined by the Federal Reserve, or a bank domiciled in Texas. G. Joint pools of political subdivisions in the State of Texas which invest in instruments and follow practices allowed by current law. Investment in such pool shall be limited to 15% of the City's entire portfolio. 6 H. No-load money market mutual funds that are regulated by the Securities and Exchange Commission, that has a dollar weighted average stated maturity of 90 days or fewer and includes in its investment objectives the maintenance of a stable net asset value of $1 for each share. I. No-load money market mutual funds that are registered with the Securities and Exchange Commission, having an average weighted maturity of less than two years and is invested or secured in obligations described in A through D above. The fund must maintain an investment grade rating of AAA, or its equivalent by at least one nationally recognized rating firm. The fund must conform to the requirements relating to the eligibility of investment pools. Investments in money market mutual funds shall be limited to 10% of the City's monthly fund balance, excluding bond proceeds and reserves and other funds held for debt II. Not AuthQrized The City's authorized investments options are more restrictive than those allowed by State law. State law specifically prohibits investment in the following investment securities. A. Obligations whose payment represents the coupon payments on the outstanding principal balance of the underlying mortgage backed security collateral and pays no principal. B. Obligations whose payment represents the principal stream of cash flow from the underlying mortgage-backed security collateral and bears no interest. C. Collateralized mortgage obligations that have a stated final maturity date of greater than l0 years. D. Collateralized mortgage obligations the interest rate of which is determined by an index that adjusts opposite to the changes in a market index. Holdin~ Period The City of Coppell intends to match the holding periods of investment funds with liquidity needs of the City. In no case will the average maturity of investments of the City's operating funds exceed one year. The maximum final stated maturity of any investment shall not exceed five years. Investments in all funds shall be managed in such a way that the market price losses resulting from interest rate volatility would be offset by coupon income and current income received from the volume of the portfolio during a twelve month period. 7 Risk and Diversification The City of Coppell recognizes that investment risks can result from issuer defaults, market price changes or various technical complications leading to temporary illiquidity. Risk is controlled through portfolio diversification which shall be achieved by the following general guidelines; A. Risk of issuer default is controlled by limiting investments to those instruments allowed by the Act, which are described herein. B. Risk of market price changes shall be controlled by avoiding over- concentration of assets in a specific maturity sector, limitation of average maturity of operating funds investments to one year, and avoidance of over-concentration of assets in specific instruments other than U.S. Treasury Securities and insured or Collateralized Certificates of Deposits. C. Risk of illiquidity due to technical complications shall be controlled by the selection of securities dealers as described herein. VI. SELECTION OF BANKS AND DEALERS De~osito~ At least every three years a Depository shall be selected through the City's banking services procurement process, which shall include a formal request for proposal (RFP). In selecting a depository, the credit worthiness of institutions shall be considered, and the Director of Finance shall conduct a comprehensive review of prospective depositories credit characteristics and financial history. Certificates of Deposit Banks seeking to establish eligibility for the City's competitive certificate of deposit purchase program shall submit for review annual financial statements, evidence of federal insurance and other information as required by the Director of Finance. Securities Dealers For brokers and dealers of government securities, the City shall select only those dealers reporting to the Market Reports Division of the Federal Reserve Board of New York also know as the "Primary Government Security Dealers*, unless a comprehensive credit and capitaliTafion analysis reveals that other firms are adequately financed to conduct public business. Investment officials shall not knowingly conduct business with any firm with whom public entities have sustained losses on investments. All Securities dealers shall provide the City with references from Public entities which they are currently serving. 8 All financial institutions and broker/dealers who desire to become qualified bidders for investment transactions must supply the following as appropriate: audited financial statements proof of National Assoc'mtion of Securities Dealers (NASD) certification proof of state registration completed broker/dealer questionnaire certification of having read the City's investment policy signed by a registered principal of the organization Acknowledgement that the organization has implemented reasonable procedures and controls in an effort to preclude imprudent investment activities arising out of investment transactions conducted between the City and the organization An annual review of the financial condition and registration of qualified bidders will be conducted by the Director of Finance. VH. SAFEKEEPING AND CUSTODY Insur0nc~ 0r Collateral All deposits and investments of City funds other than direct purchases of U.S. Treasuries or Agencies shall be secured by pledged collateral. In order to anticipate market changes and provide a level of security for all funds, the collateraliTation level will be 105 % of market value of principal and accrued interest on the deposits or investments less an amount insured by the FDIC or FSLIC. Evidence of the pledged collateral shall be maintained by the Director of Finance or a third party financial institution. Repurchase agreements shall be documented by a specific agreement noting the collateral pledge in each agreement. Collateral shall be reviewed monthly to assure that the market value of the pledged securities is adequate. Saf~k~ine Agreement Collateral pledged to secure deposits of the City shall be held by a safekeeping institution in accordance with a Safekeep'mg Agreement which clearly defines the procedural steps for gaining access to the collateral should the City of Coppoll determine that the City's funds are in jeopardy. The safekeeping institution, or Trustee, shall be the Federal Reserve Bank or an institution not affiliated with the firm pledging the collateral. The safekeeping agreement shall include the signatures of authorized representatives of the City of Coppell, the firm pledging the collateral, and the Trustee. Collateral Defined The City of Coppell shall accept only the following securities as collateral: 9 A. FDIC and FSLIC insurance coverage. B. A bond, certificate of indebtedness, or Treasury Note of the United States, or other evidence of indebtedness of the United States that is guaranteed as to principal and interest by the United States. C. Obligations, the principal and interest on which, are unconditionally guaranteed or insured by the State of Texas. D. A bond of the State of Texas or of a county, city or other political subdivision of the State of Texas having been rated as investment grade (investment rating no less than 'A' or its equivalent) by a nationally recognized rating agency with a remaining maturity of ten (10) years or less. Sub_iect to Audit ALI collateral shall be subject to inspection and audit by the Director of Finance or the City's independent auditors. D~livery_ vs. Payment Treasury Bills, Notes, Bonds and Government Agencies' securities shall be purchased using the delivery vs. payment method. That is, funds shall not be wired or paid until verification has been made that the correct security was received by the Trustee. The security shall be held in the name of the City or held on behalf of the City. The Trustee's records shall assure the notation of the City's ownership of or explicit claim on the securities. The original copy of all safekeeping receipts shall be delivered to the City. VH. INVESTMENT POLICY ADOPTION The City of Coppell investment policy shall be adopted by resolution of the City Council The policy shall be reviewed for effectiveness on an annual basis by the Investment Committee and any modifications will be recommended for approval to the City Council. 10 GLOSSARY of COMMON TREASURY TERMINOLOGY Agencies: Federal agency securities, bondholder on the bond's face value. Co) A certificate attached to a bond evidencing Ask: The price at which securities are interest due on a payment date. offered. Dealer: A dealer, as opposed to a broker, Bid: The price offered for securities, acts as a principal in all transactions, buying and selling for his own account. Broker: A broker brings buyers and sellers together for a commission paid by the Debenture: A bond secured only by the initiator of the transaction or by both sides; general credit of the issuer. he does not position. In the money market, brokers are active in markets in which banks Delivery versus Payment: There are two buy and sell money and in interdealer methods of delivery of securities: delivery markets, versus payment and delivery versus r~ipt (also called free). Delivery versus payment Certificate of Deposit (CD): A time is delivery of securities with an exchange of deposit with a specific maturity evidenced money for the securities. Delivery versus by a certificate. Large-denomination CD's receipt is delivery of securities with an are typically negotiable, exchange of a signed receipt for the securities. Collateral: Securities, evidence of deposit or other property which a borrower pledges Discount Securities: Non-interest bearing to secure repayment of loan. Also refers to money market instruments that are issued at securities pledged by a bank to secure a discount and redeemed at maturity for full deposits of public monies, face value, e.g., U.S. Treasury bills. Comprehensive Annual Financial Report Diversification: Dividing investment funds (CAFR): The official annual report for the among a variety of securities offering City of Coppell. It includes five combined independent returns. statements and basic financial statements for each individual fund and account group Federal Credit Agencies: Agencies of the prepared in conformity with GAAP. It also Federal government set up to supply credit includes supporting schedules necessary to to various classes of institutions and demonstrate compliance with finance-related individuals, e.g., S&L's, small business legal and contractual provisions, extensive firms, students, farmers, farm cooperatives, introductory material, and a detailed and exporters. Statistical Section. Federal Deposit Insurance Corporation Coupon: (a) The annual rate of interest (FDIC): A federal agency that insures bank that a bond's issuer promises to pay the 11 deposits, currently up to $100,000 per purchases and sales of Government deposit. Securities in the open-market as a means of influencing the volume of bank credit and Federal Funds Rate: The rate of interest at money. which Fed funds are traded. This rate is currently pegged by the Federal Reserve Federal Reserve Syste~n: The central bank through open-market operations, of the United States created by Congress and consisting of a seven member Board of Federal Home Loan Banks OVFILB): The Governors in Washington, D.C., 12 regional institutions that regulate and lend to savings banks and about 5,700 commercial banks and loan associations. The Federal Home that are members of the system. Loan Banks play a role analogous to that played by the Federal Reserve Banks vis-a- Government National Mortgage vis member commercial banks. Association (GNMA or Ginnie Mae): Securities guaranteed by GNMA and issued Federal National Mortgage Association by mortgage bankers, commercial banks, (FNMA): FNMA, like GNMA, was savings and loan associations, and other chartered under the Federal National institutions. Security holder is protected by Mortgage Association Act in 1938. FNMA full faith and credit of the U.S. is a federal corporation working under the Government. Ginnie Mae securities are auspices of the Department of Housing and backed by FHA, VA or FMHM mortgages. Urban Development, H.U.D. It is the The term pass-throughs is often used to largest single provider of residential describe Ginnie Maes. mortgage funds in the United States. Fannie Mae, as the corporation is called, is a Liquidity: A liquid asset is one that can be private stockholder-ownedcorporation. The converted easily and rapidly into cash corporations's purchases include a variety of without a substantial loss of value. In the adjustable mortgage an second loans in money market, a security is said to be liquid addition to fixed-rate mortgages. FNMA's if the spread between bid and asked prices is securities are also highly liquid and are narrow and reasonable size can be done at widely accepted. FNMA assumes and those quotes. guarantees that all security holders will receive timely payment of principal and Market Value: The price at which a interest, security is trading and could presumably be purchased or sold. Federal Open Market Committee (FOMC): Consists of seven members of Master Repurchase Agreement: To the Federal Reserve Board and five of the protect investors, many public investors will twelve Federal Reserve Bank Presidents. request that repurchase agreements be The President of the New York Federal preceded by a master repurchase agreement Reserve Bank is a permanent member while between the investor and the financial the other Presidents serve on a rotating institution or dealer. The master agreement basis. The Committee periodically meets to should define the nature of the transaction, set Federal Reserve guidelines regarding identify the relationship between the parties, 12 establish normal practices regarding registered securities broker-dealers banks ownership and custody of the collateral and a few unregulated firms. securities during the term of the investment, provide remedies in the case of default by Prudent Person Rule: An investment either party and clarify issues of ownership, standard. Investments shall be made with The master repurchase agreement protects judgment and care, under circumstances then the investor by eliminating the uncertainty of prevailing, which persons of prudence, ownership and hence, allowing investors to discretion and intelligence exercise in the liquidate collateral if a bank or dealer management of their own affairs, not for defaults during the term of the agreement, speculation, but for investment, considering the probable safety of their capital as well as Maturity: The date upon which the the probable income to be derived. principal or stated value of an investment becomes due and payable. Qualified Public Depositories: A financial institution which does not claim exemption Money Market: The market in which from the payment of any sales or short-term debt instruments (bills, compensating use or ad valorem taxes under commercial paper, bankers' acceptances, the laws of this state, which has segregated etc.) are issued and traded, for the benefit of the commission eligible collateral having a value of not less than its Open Market Operations: Purchases and maximum liability and which has been sales of government and certain other approved by the Public Deposit Protection securities in the open market by the New Commission to hold public deposits. York Federal Reserve Bank as directed by the FOMC in order to influence the volume Rate of Return: The yield obtainable on a of money and credit in the economy, security based on its purchase price or its Purchases inject reserves into the bank current market price. This may be the system and stimulate growth of money and amortized yield to maturity on a bond or the credit; sales have the opposite effect. Open current income return. market operations are the Federal Reserve's most important and most flexible monetary Repurchase Agreement (RP ofREPO): A policy tool. holder of securities sells these securities to an investor with an agreement to repurchase Portfolio: Collection of securities held by them at a fixed price on a fixed date. The an investor, security 'buyer' in effect lends the 'seller' money for the period of the agreement, and Prhnary Dealer: A group of government their terms of the agreement are structured securities dealers that submit daily reports of to compensate him for this. Dealers use RP market activity and positions and monthly extensively to finance their positions. financial statements to the Federal Reserve Exception: When the Fed is said to be Bank of New York and are subject to its doing RP, it is lending money, that is, informal oversight. Primary dealers include increasing bank reserves. Securities and Exchange Commission (SEC) INVb'TMNT. POL REVISED021097 13