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Okaloosa County BOCC — October 18, 2016 — County Investment Policy final — reading text
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County Investment Policy final — extracted reading text
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102%
*Securities issued by FNMA, FFCB, FHLB, quoted daily in the financial press.
Collateral must be "marked to market" on a weekly basis by the Clerk or an independent
source. The seller should be notified of any drop in market value and required to
increase the collateral immediately.
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X. INTERNAL CONTROLS AND OTHER
The Clerk to the Board shall establish and monitor a set of written internal controls
designed to protect the Board of County Commissioners assets and ensure proper
accounting and reporting of the transactions related thereto.
1. The Clerk to the Board is authorized to accept, on the behalf of and in the name
of the Board of County Commissioners, bank trust receipts or confirmations from
a third-party custodian (which might be the trust department of the bank) in return
for investment of temporary idle funds as evidence of actual delivery of the
obligations or securities. Any such trust receipt or confirmation shall fully
describe the various obligations or securities held, together with the specific
number of each obligation or security held, and that they are held for the Board of
County Commissioners. The actual obligations or securities, whether in book-
entry or physical form, on which trust receipts or confirmations are issued may be
held by any bank/depository chartered by the United States Government or the
State of Florida.
2. After the Director of Finance, or designee, has determined the approximate
maturity date based on cash flow needs and market conditions and has analyzed
and selected one or more optimal types of investments, a minimum of three (3)
banks and/or dealers must be contacted and asked to provide the Director of
Finance with yields on securities or repo that the County wishes to purchase to a
certain maturity date. The exception to the three-bid rule is conditional upon
signed contracts with the brokers/dealers. All costs (i.e., safekeeping bank
charges) should be considered in analyzing the final yield rate that is given by the
banks or dealers. Overnight repos transacted with brokers/dealers and banks
other than the pooled cash depository bank will be subject to the bid process.
3. The Director of Finance shall generate daily and monthly reports for
management purposes. In addition, the Clerk to the Board will be provided a
monthly report which will include investment activity for the month reported.
Additionally, in conjunction with the presentation of the CAFR, the Clerk will
present to the Board of County Commissioners an annual report which will
include investment summary for the year reported.
4. The investment and portfolio policies are to be reviewed annually and updated as
required.
5. Internal controls will also encompass, at a minimum, the additional issues:
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(a) Transfers of all funds (purchases, sales, etc.)
(b) Separation of functions including transaction authority for accounting and
record keeping.
(c) Custodial safekeeping.
(d) Delegation of authority to subordinate staff members.
(e) Written confirmation of telephone transactions.
(f) Supervisory control of employee actions.
(g) Specific guidelines regarding security losses and remedial action.
(h) Documentation of decisions and transactions.
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