RE 08-22-95.1 A RESOLUTION OF THE CITY OF COPPELL, TEXAS
RESOLUTION NO. 082295.1
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COPPELL, TEXAS,
ADOPTING A POLICY FOR THE INVESTMENT OF MUNICIPAL FUNDS, REVISED
AS REQUIRED BY HOUSE BILL NO. 2459; ESTABLISHING THE MAXIMUM
ALLOWABLE STATED MATURITY OF ANY INDIVIDUAL INVESTMENT;
DESIGNATING AN INVESTMENT OFFICER; PROVIDING FOR REVIEW OF THE
INVESTMENT POLICY; CONTAINING OTHER PROVISIONS; AND PROVIDING AN
EFFECTIVE DATE.
WHEREAS, House Bill No. 2459 of the 73rd Legislature has amended Chapter 2256
of the Texas Government Code to establish certain requirements for the investment of
public funds; and
WHEREAS, such legislation is applicable to the City of Coppell and requires
adoption of a new written Investment Policy;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF COPPELL, TEXAS:
SECTION 1. That the written Investment Policy attached hereto as Exhibit "A" and
made a part hereof for all purposes, be, and the same is hereby, adopted as the Investment
Policy of the City of Coppell regarding the investment of the City's funds and funds under
its control as required by Chapter 2256 of the Texas Government Code, as amended by
House Bill No. 2459, effective September 1, 1995.
SECTION 2. That from and after the adoption of this resolution and the attached
Investment Policy, the City of Coppell may only purchase, sell, and invest its funds and funds
under its control in investments authorized hereby in compliance with this policy and the
standard of care prescribed by Chapter 2256 of the Texas Government Code.
AGG07375
SECTION 3. This resolution shall take effect immediately from and after its passage
as the law and charter in such cases provide, and it is accordingly so resolved.
DULY PASSED AND APPROVED by the City Council of the City of Coppell, Texas,
on the ~2~ Jday of (~'~x~ , 1995.
d APPROVED:
TOM MORTON, MAYOR
ATTEST:
LINDA GRAU, CITY SECRETARY
APPROVED AS TO FORM:
(RLD/ct 8/18/95)
AGGO7375
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 amended, to define, adopt and review
a formal investment strategy and policy.
INVESTMF, NT STRATEGY
The City of Coppell maintains portfolios which utilize 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
shouId 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.
INVESTMENT 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
H. OBJECTIVES
The City of Coppell shall manage and invest its cash with four objectives, listed in order of
priority: Safety, Liquidity, Yield, and Public Trust. The safety of the 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 structured 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 Bills. The investment program shall
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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 an Assistant 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 Training
Authority to manage the City's investment program is derived from a resolution of the City
Council. The Director of Finance is designated as investment officer of the City and is
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 officer shall attend at least one training session relating to the officer's
responsibility under the Act within 12 months after assuming duties.
Internal ¢0nlrols
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 ~rom 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:
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.H 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 Conflicts of Interest
City staff involved in the investment process shall refrain from personal business activity that
could conflict with proper executiun 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 fmancial 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 related within the second degree by affinity or
consanguinity to an individual seeking to sell an investment to the City shall file a statement
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disclosing that relationship. A statement required under this subsection must be filed with the
Texas Ethics Commission and the governing body of the entity.
IV, REPORTING
Quarterly R _eporting
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. Unrealized 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 matiurity 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.
¥. INVESTMENT 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.
Investment~
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 amended.
I. A~thorized
A. Obligations of the United States of America, its agencies and
instrumentalities.
B.Direct obligations of the State of Texas and agencies thereof.
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.
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II. Not Authorized
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 10 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.
Holding Period
Thc 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.
Ri~k 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 CollateraliTed 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
Depository
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 capi~ali~,ation
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.
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 Asseeiation 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.
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VH. SAFEKEEPING AND CUSTODY
In~uranc~ or 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 ail funds, the collateralization level will be 102% of market vaiue
of principal and accrued interest on the deposits or investments less an amount insured by the
FDIC or FSLIC. Evidence of the pledged collateral shail 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 vaiue of the pledged securities is adequate.
Safekeeping Agreement
Collateral pledged to secure deposits of the City shall be held by a safekeeping institution in
accordance with a Safekeeping Agreement which clearly defines the procedural steps for gaining
access to the collateral should the City of Coppell 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 fu-m pledging the collateral. The safekeeping agreement shall
include the signatures of authorized representatives of the City of Coppell, the fhnn pledging the
collateral, and the Trustee.
C911ateral Defined
The City of Coppell shall accept only the following securities as collateral:
A. FDIC and FSLIC insurance coverage.
B. A bond, certificate of indebtedness, or Treasury Note of the United $tat~s,
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 Texa~ 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 equivaient) by a nationally
recognized rating agency with a remaining maturity of ten (10) years or
less.
Subject to Audit
All collateral shall be subject to inspection and audit by the Director of Finance or the City's
independent auditors.
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Delivery 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 Tmstee'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.
VII. INVESTMFNT 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.
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GLOSSARY
of
COMMON TREASURY TERMINOLOGY
Agencies: Federal agency securities, bondholder on the bond's face value. 0a) A
certificate attached to a bond evidencing
Asked: 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 m~rket,
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 receipt
(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 F'mancial 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 indepenent 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
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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 System: 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 (FItLB): 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-ram 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 sola.
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,
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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 theft 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 appwved 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 01P of REIN)): 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
Prlma~ 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 RI>
market activity and positions and monthly extensively to f'mance 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)
~ws~t~rr.~oL v.~ws£r~alags
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