- Scope
This investment policy applies to all monies and other financial resources available to the Chappaqua CSD Public Library for investment on its own behalf or on behalf of any other entity or individual.
- Objectives
The primary objective of the Chappaqua CSD Public Library’s investment activities are, in order of priority: in order of priority:
- To conform with all applicable federal, state, and other legal requirements (legal);
- To adequately safeguard principal (safety);
- To provide sufficient liquidity to meet all operating requirements (liquidity); and
- To obtain a reasonable rate of return (yield).
- Delegation of Authority
The Board of Trustees delegates responsibility for oversight of the policy to the Finance Officer, or other officer so designated. Administration of the program shall be designated to the Library Director who shall establish written procedures for the operation of the investment program consistent with these investment guidelines. Such procedures shall include an adequate internal control structure to provide a satisfactory level of accountability based on records incorporating description and amounts of investments, transaction dates, and other relevant information, and regulate the activities of subordinate employees.
- Prudence
All participants in the investment process shall seek to act responsibly as custodians of the public trust. 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 speculations, but for investment, considering the safety of the principal as well as the probable income to be derived.
All participants 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 their ability to make impartial investment decisions.
- Diversification
It is the policy of the Chappaqua CSD Public Library to diversity its deposits and investments by financial institution, by investment instrument, and by maturity scheduling.
- Internal Controls
It is the policy of the Chappaqua CSD Public Library for all public monies collected by any officer or employee of the Library to transfer those funds to the Director within the time period specified by law.
The Director is responsible for establishing and maintaining an internal control structure to insure that the assets of the Library are protected from loss, theft, or misuse. The internal control structure shall be designed to provide reasonable assurance that these objectives are met and that transactions are executed in accordance with management’s authorization and recorded properly, and managed in compliance with applicable laws and regulations.
- Designation of Depositaries
The banks and trust companies authorized for the deposit monies are reviewed and approved by the Board at its July meeting.
- Collateralizing of Deposits
In accordance with the provisions of General Municipal Law §10, all deposits of the Chappaqua CSD Public Library, including certificates of deposit and special time deposits, in excess of the amount insured under the provisions of the Federal Deposit Insurance Act shall be secured by a pledge of “eligible securities” with an aggregate “market value” of 102% of the aggregate amount of deposits from the following categories:
- Obligations issued, or fully insured or guaranteed as to the payment of principal and interest, by the United States of America, an agency thereof or a United States government sponsored corporation.
- Obligations partially insured or guaranteed by any agency of the United States of America, at a proportion of the market value of the obligation that represents the amount of the insurance or guaranty.
- Obligations issued or fully insured or guaranteed by the State of New York, obligations issued by a municipal corporation, school district or district corporation of such state or obligations of any public benefit corporation which under a specific state statute may be accepted as security for deposit of public monies
- Such other instruments of securities as may, from time to time, be legally permissible collateral for deposit of municipal corporation monies.
- Safekeeping and Collateralization
In accordance with General Municipal Law §10, all library deposits in excess of those insured by the Federal Deposit Insurance Act shall be secured:
- By eligible securities used for collateralizing deposits shall be held by a third party bank or trust company subject to security and custodial agreements.The security agreement shall provide that eligible securities are being pledged to secure Library deposits together with agreed upon interest, if any, and any costs or expenses arising out of the collection of such deposits upon default. It shall also provide the conditions under which the securities may be sold, presented for payment, substituted or released and the events which will enable the Library to exercise its rights against the pledged securities. In the event that the securities are not registered or inscribed in the name of the Library, such securities shall be delivered in a form suitable for transfer or with an assignment in blank to the Chappaqua CSD Public Library or its custodial bank.
The custodial agreement shall provide that securities held by the bank or trust company, or agent of and custodian for, the Library, will be kept separate and apart from the general assets of the custodial bank or trust company and will not, in any circumstances, be commingled with or become part of the backing for any other deposit or other liabilities. The agreement should also describe that the custodian shall confirm the receipt, substitution or release of securities. The agreement shall provide for the frequency of revaluation of eligible securities and for the substitutions of securities when a change in the rating of a security may cause ineligibility. Such agreement shall include all provisions necessary to provide the Library a perfected interest in the securities; or
- By a bond executed by an insurance company authorized to do business in New York, the claims-paying ability of which is rated in the highest rating category by at least two nationally recognized statistical rating organizations; or
- By an irrevocable letter of credit issued in favor of the local government for a term not to exceed ninety days by a bank (other than the bank with which the money is being deposited or invested) whose commercial paper and other unsecured short-term debt obligations (or, in the case of a bank which is the principal subsidiary of a holding company, whose holding company’s commercial paper and other unsecured short-term debt obligations ) are rated in one of the three highest rating categories (based on the credit bank or holding company) by at least one nationally recognized statistical rating organization or by a bank (other than the bank with which the money is being deposited or invested) that is in compliance with applicable federal minimum risk-based capital requirements.
- Permitted Investments
As authorized by General Municipal Law § 11, the Chappaqua CSD Public Library authorizes the Finance Officer and one other Board member to invest moneys not required for immediate expenditure for terms not to exceed its projected cash flow needs in the following types of investments:
- Special time deposit accounts authorized to do business in New York State;
- Certificates of deposit;
- Obligations backed by the full faith and credit of the United States of America;
- Obligations guaranteed by agencies of the United States of America where payment or principal and interest are guaranteed by the United States of America;
- Obligations backed by the full faith and credit of the State of New York;
- Obligations issued pursuant to LFL §24.00 or 25.00 (with approval of the State Comptroller) by any municipality, school district or district corporation other than the Chappaqua CSD Public Library.
- Obligations of public authorities, public housing authorities, urban renewal agencies and industrial development agencies where the general State statutes governing such entities or whose specific enabling legislations authorizes such investments,
All investment obligations shall be payable or redeemable at the option of the Chappaqua CSD Public Library within such times as the proceeds will be needed to meet expenditures for purposes for which the moneys were provided.
- Authorized Financial Institutions
The Chappaqua CSD Public Library shall maintain a list of financial institutions approved for investment purposes and establish appropriate limits to the amount of investments which can be made with each financial institution. This listing will be evaluated annually. All financial institutions with which the Library conducts business must be credit worthy. Banks shall provide their most recent Consolidated Report of Condition (Call Report) at the request of the Chappaqua CSD Public Library. The Treasurer and one Board member are responsible for evaluating the financial position and maintaining a listing of proposed depositories and custodians.
- Purchase of Investments
The Director, or other designee, is authorized to contract for the purchase of investments: categories:
- Directly, including through a repurchase agreement, from an authorized trading partner.
- By participation in cooperative investment program with another authorized governmental entity pursuant to Article 5G of the General Municipal Law where such program meets all the requirement set forth in the Office of the State Comptroller Opinion No. 88-46, and the specific program has been authorized by the governing board.
- By utilizing an ongoing investment program with an authorized trading partner pursuant to a contract authorized by the Chappaqua CSD Public Library Board of Trustees.
All purchased obligations, unless registered or inscribed in the name of the Chappaqua CSD Public Library, shall be purchased through, delivered to and held in the custody of a bank or trust company. Such obligations shall be purchased, sold or presented for redemption or payment by such bank, or trust company only in accordance with prior written authorization from the persons authorized to make the investment. All such transactions shall be confirmed in writing to the Chappaqua CSD Public Library by the bank or trust company. Any obligation held in the custody of a bank or trusts company shall be held pursuant to a written custodial agreement as described in General Municipal Law §10.
The custodial agreement shall provide that securities held by the bank or trust company, as agent of and custodian for, the Chappaqua CSD Public Library, will be kept separate and apart from the general assets of the custodial bank or trust company and will not, in any circumstances, be commingled with or become part of the backing for any other deposits or other liabilities. The agreement shall describe how the custodian shall confirm the receipt and release of securities. Such agreement shall include all provisions necessary to provide the Chappaqua CSD Public Library a perfected interest in the securities.
- Review of Adopted Policy
In accordance with General Municipal Law §39, this policy shall be reviewed at least annually. It should be reviewed more frequently as circumstances and/or laws change, and amended as appropriate by resolution of the Board of Trustees.
Adopted by the Library Board of Trustees - December 2015
Revised (to include General Municipal Law guidelines on additional securities) and approved by the Library Board of Trustees - February 26, 2019
