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HomeMy WebLinkAboutResolution No. 91-R46RESOLUTION NO. 91-R46 RESOLUTION OF THE EXECUTIVE BOARD OF THE REDEVELOPMENT AGENCY OF THE CITY OF AZUSA RE -ADOPTING ITS INVESTMENT POLICY WHEREAS the Redevelopment Agency of the City of Azusa receives taxes and other revenues from a variety of sources and uses the funds to pay its bills on a regular basis; and WHEREAS the Agency Treasurer is charged with the duties of handling and maintaining the cash that is taken in or otherwise received by the Agency; and WHEREAS the balance of these funds fluctuates between $3,000,000 and $10,000,000 or more; and WHEREAS the Agency Treasurer is charged with the responsibility of investing idle public funds, doing so on the basis of protecting the safety of the funds, ensuring the liquidity of the investments, and maximizing earnings in that order of importance and based on the "Prudent Man Rule"; and WHEREAS the State of California requires each Agency to adopt an investment policy for its jurisdiction. NOW THEREFORE BE IT RESOLVED that the Executive Board of the Redevelopment Agency of the City of Azusa does hereby re -adopt its Investment Policy attached hereto as Exhibit A and instructs the Agency Treasurer to be guided by it in carrying out the duties of his office for the benefit of the Redevelopment Agency. ADOPTED AND APPROVED this FAF 5th day of AUGUST, 1991. I HEREBY CERTIFY that the foregoing resolution was duly adopted by the Redevelopment Agency of the City of Azusa at a regular meeting thereof on the 5th day of AUGUST, 1991 by the following vote of Board: AYES: BOARD DIRECTORS: STEMRICH, NARANJO, ALEXANDER, MOSES NOES: BOARD DIRECTORS: NONE ABSENT: BOARD DIRECTORS: DANGLEIS Z / SEC TARY % 0 E THE REDEVELOPMENT AGENCY OF THE CITY OF AZUSA I N V E S T M E N T P O L I C Y I. STATEMENT OF OBJECTIVES Temporarily idle or surplus funds of The Redevelopment Agency of the City of Azusa (the "Agency") be invested in accordance with principles of sound treasury management and in accordance with the provisions of California Government Code Sections 53600, et seq., the Municipal Code, guidelines established by the California Municipal Treasurer's Association and the California Society of Municipal Finance Officers, and this Investment Policy ("Policy"). A. Overall Risk Profile The basic objectives of the Agency's Investment Program are, in order of priority: 1. Safety of invested funds; 2. Maintenance of sufficient liquidity to meet cash flow needs; and 3. Attainment of the maximum yield possible consistent with the first two objectives. The achievement of these objectives shall be accomplished in the manner described below: 1. Safety of Invested Funds The Agency shall ensure the safety of its.invested idle funds by limiting credit and interest rate risks. Credit risk is the risk of loss due to the failure of the security issuer or backer. Interest rate risk is the risk that the market value portfolio securities will fall due to an increase in general interest rates. a) Credit risk will be mitigated by: (i) limiting investments to the safest types of securities; (ii) by prequalifying the financial institutions with which it will do business; and 1 2. 0 0 (iii) by diversifying the investment portfolio so that the failure of any one issue or backer will not place an undue financial burden on the Agency. b) Interest rate risk will be mitigated by: (i) structuring the Agency's portfolio so that securities mature to meet the Agency's cash requirements for ongoing operations, thereby avoiding the need to sell securities on the open market prior to their maturation to meet those specific needs; and (ii) investing primarily in shorter term securities. C) The physical security or safekeeping of the Agency's investments is also an important element of safety. Detailed safekeeping requirements are defined in Section III of this policy. Liquidity The Agency's investment portfolio shall be structured in a manner which strives to achieve that securities mature at the same time as cash is needed to meet anticipated demands (Static Liquidity). Additionally, since all possible cash demands cannot be anticipated, the portfolio should consist largely of securities with active secondary or resale markets (Dynamic Liquidity). The specific percentage mix of different investment instruments and maturities is described in Section II of this Policy. 3. Yield Yield on the Agency's investment portfolio is of secondary importance compared to the safety and liquidity objectives described above. Investments are limited to relatively low risk securities in anticipation of earning a fair return relative to the risk being assumed. While it may occasionally be necessary or strategically prudent of the Agency to sell a security prior to maturity to either meet unanticipated cash needs or to restructure the portfolio, this policy specifically prohibits trading securities for the sole purpose of speculating on the future direction of interest rates. Specifically, "when" and "if issued" trading and open-ended portfolio restructuring transactions are prohibited. 0 0 B. Time Frame for Investment Decisions The Agency's investment portfolio shall be structured to provide that sufficient funds from investments are available every month to meet the Agency's anticipated cash needs. Subject to the safety provisions outlined above, the choice in investment instruments and maturities shall be based upon an analysis of anticipated cash needs, existing and anticipated revenues, interest rate trends and specific market opportunities. No investment should have a maturity of more than five (5) years from its date of purchase without receiving prior Executive Board approval. C. Definition of Idle or Surplus Funds Idle or surplus funds for the purpose of this policy are all Agency funds which are available for investment at any one time, including the estimated checking account float, excepting those minimum balances required by the Agency's banks to compensate them for the cost of banking services. This policy also applies to the idle or surplus funds of other entities for which the Redevelopment Agency personnel provide financial management services. II INVESTMENTS This section of the Investment Policy identifies the types of instruments in which the Agency will invest its idle funds. A. Eligible Securities The Agency operates its temporary pooled idle cash investments under the Prudent ilan Rule - l/ (Civil Code Section 2261, et seq). See Exhibit A. This affords the Agency a broad spectrum of investment opportunities as long as the investment is deemed prudent and is allowable under current legislation of the State of California (Government Code Section 53600, et. seq). (See Exhibit B for definition of investments.) * Insured Certifications of Deposit (CD's) of California banks and/or savings and loan associations, and/or savings banks which mature in 5 years or less, provided that the Agency's investments shall not exceed One Hundred Thousand Dollars ($100,000.00) per institution. If the 1/ The Prudent Man Rule states, in essence, that "in investing exercise the judgment and care, under the circumstances then prevailing, which men of prudence, discretion and intelligence exercise in the management of their own affairs ......" 9 ME C. D. 0 0 investment exceeds the insured $100,000.00, the funds are to be collateralized at 110% of the deposit in government securities or 150% in mortgages. * Local Agency Investment Fund (State Pool) Demand Deposits * Securities of the U.S. Government, or its agencies * Negotiable Certificates of Deposit placed with Federal and State savings and loan associations and Federal and State chartered banks with an office in the State of California (limited to 30% of portfolio) * Bankers Acceptance (limited to 40% of portfolio) (Not collateralized; emergency use only) * Commercial Paper (limited to 30% of portfolio) (Not collateralized; emergency use only) * Passbook Savings or Money Market Demand Deposits * Repurchase Agreements (limited to 30% of portfolio) * Los Angeles County Treasurer's Investment Pool * Money Market Mutual Fund (with $1 net asset value) Qualification of Brokers Dealers and Financial Institutions United States Treasury issue transactions will be conducted only with primary dealers from the list of Government Security dealers reporting to the Markets Reports Division of the Federal Reserve Bank of New York (Exhibit C). Collateralization Requirements Uninsured Time Deposits with banks and savings and loans shall be collateralized in the manner prescribed by law for depositories accepting municipal investment funds. Pre -formatted Wire Transfers Wherever possible, the Agency will use pre -formatted wire transfers to restrict the transfer of funds to pre -authorized accounts only. When transferring funds to an account not previously approved, the bank is required to call back a second employee for confirmation that the transfer is authorized. 4 Fa F G. 0 0 Notice of Dealers The Agency shall annually send a copy of the current edition of the Policy and its enabling Resolution to all institutions which are approved to handle City of Azusa Redevelopment Agency investments. Receipt of the Policy and Resolution, including confirmation that it has been received by persons handling the Agency's account, shall be acknowledged in writing within thirty (30) days. Diversification The portfolio should consist of a mix of various types of securities, issues and maturities. Confirmation Receipts for confirmation of purchase of authorized securities should include the following information: trade date, par value, rate, price, yield, settlement date, description of securities purchase, agency's name, net amount due, 3rd party custodial information. These are minimum information requirements. H. GASB 3 The Governmental Accounting Standards Board issued GASB 3 in April 1986, and the local entity's investments must be categorized into three levels of credit risk as follows: a) securities which the its agent b) securities are held department that are insured or registered, or for securities are held by public units or in the units; C) securities are held by department that are uninsured and unregistered and by the broker's or dealer's trust or agent in the unit's name; that are uninsured and unregistered and the broker or dealer, or by its trust or agent, but not in the unit's name. The carrying amount and market value of all types of investments must be disclosed in total and for each type of investment. Governmental Accounting Standards Board 3 exempts mutual funds and LAIF investments from the mandatory risk categorization. 0 0 III SAFEKEEPING OF SECURITIES A. Safekeeping Agreement The Agency shall contract with a bank or banks for the safekeeping of securities which are owned by the Agency as a part of its investment portfolio or transferred to the Agency under the terms of any repurchase agreements. B. Handling of Agency Owned Securities and Time Deposit Collateral All securities owned by the Agency shall be held by its safekeeping agent, except the collateral for time deposits in banks, savings banks, and savings and loans is held by the Federal Home Loan Bank. The collateral for time deposits in banks is held in the Agency's name in the bank's trust department, (if a safekeeping agreement has been executed) or, alternatively, in the San Francisco Federal Reserve Bank. C. Security Transfers The authorization to release the Agency's securities will be telephoned to the appropriate bank by a finance department member other than the person who initiated the transaction. A written confirmation outlining details for the transaction and confirming the tele- phoned instructions will be sent to the bank within five (5) working days. D. Verification of Security Securities transferred to the Agency as collateral securing time deposits which are being held in safe- keeping for the Agency will be verified in writing and examined on a surprise basis during the year by the Agency's independent auditors as part of the Agency's annual independent audit. IV. STRUCTURE AND RESPONSIBILITY This section of the Policy defines the overall structure of the investment management program. A. Responsibilities of the Agency Treasurer The Agency Treasurer is charged with responsibility for maintaining custody of all public funds and securities belonging to or under the control of the Agency, and for the deposit and investment of those funds in E accordance with principles of sound treasury management and in accordance with applicable laws and ordinances. The Executive Director is responsible for keeping the Executive Board fully advised as to the financial condition of the Agency. C. Responsibilities of the Executive Board The Executive Board shall consider and adopt a written investment policy. As provided in that policy, the Board shall receive, review and accept monthly invest- ment reports. D. Responsibilities of the Investment Committee There shall be an Investment Committee consisting of the Executive Diretor, the Director of Finance and the Agency Treasurer. The Committee shall meet quarterly to discuss cash flow requirements, the monthly invest- ment reports, investment strategy, investment and banking procedures and significant investment related work projects being undertaken in each department which will affect the cash flow management of the Agency Treasurer. This will require timely reports from the department heads to the Agency Treasurer concerning significant future cash flow requirements. The Committee's meetings will be summarized in minutes that are distributed to the Executive Board. V. REPORTING The Agency Treasurer shall prepare a monthly investment report, including a succinct management summary that provides a clear picture of the status of the. current investment portfolio and transactions made over the past month. This management summary shall be prepared in a manner which will allow the Executive Director and the Executive Board to ascertain whether investment activities during the reporting period have deviated from the Agency's Investment Policy. The monthly report shall include the following: A. A list of individual securities held at the end of the reporting month. B. Unrealized gain or loss resulting from appreciation or depreciation by listing the cost and market value of securities over one year in duration. C. A description of the current investment strategy and the assumptions upon which it is based. 7 0 0 D. Average rate of return on Agency's investments. E. Maturity aging by type of investments. VI. REVIEW OF INVESTMENT MANAGEMENT Policy Review This investment policy shall be reviewed annually by the Executive Board in accordance with State law to ensure its consistency with respect to the overall objectives of safety, liquidity and yield. Proposed amendments to the policy shall be prepared by the Treasurer and after review by the Investment Committee and City Attorney be forwarded to the Executive Board for consideration. VII. AUTHORITY This policy was duly adopted by authority of the Executive Board of the Redevelopment Agency of the City of Azusa on the day of , 1991. invpolcy.cra J PftUOcN ;.AY RULE .Y - - CIVIL CObL .:� :;: •_ _ .fit :.' ail. �. �:,. •I.iY smart: ,.: _�..� _. �._.... .._.� ..._ ...... ... _ .. .� ::51+,avestment Of 13 r� zvest:ag. pu:c�:sin;. i�ulrlr3. eXe!:3nbing. selia, =A c:n3ging prcpery for the tcnt' of inothM .-, s trtstx s;ull ♦ thenr,d cz:a ural: L'.: rrcu.:.stan= then p:_waii- mea of prudcnc: dis_ca sad intelligcr,= ex- se th: T 7 •n: of their own atf3i' . ct .•:3ird to syr_•:lati= but in regard 3� to the ;-e=-'ner: disresitien cf fucds, e:nside:in; the p.'e i.•Ico:ne, u wet u t:,e rrb3bl: ssfm of that up.c_-' Wit in e lir--'-: rs of Lhe fc::gcl-; s' .dud, ind subject to sny exp:cs prcvisiors o: licit3:icrs ccn:='.w its vly pirticul.: L'L. a tt::s:__ is su:.`.o. c-� :o 2c: every i ::d of pr_r 7f' r ' persons! or M;Xe+'. s.d^every k_: cf invest.^.. t. spm c'.'IY ws of liriu.'icn, : rontc ob!i3aticns of cvcy inc'.uc:r.;. but aot �y y ki snd s:cc s, �r::crc-' or c :' which roc of prudcla, is d:s:::::ca hues L^.t:lllgCnc: ie,u sr fL::`e_ (2) Ia the a'ose ce of ex;-,=, p:evisic s to the coninrY in the tragi ins: -_-ca, a t s:c'ciy eo.^.:.nuc to c!d p :ved in= a it or "u tris: a: its or hors.• ur..t y Ad'-� to sc;u:. r r3L• to ^stet suthcrry if =du lcn� is :`: tnat�•, is Lhe eze:c:: cf SOCC had of :ess nab!e p- deer disc:: cn and intellib n^ Cly c.^.. SidesL.�c S: lr.:erests of the Lti.^.. that reser : n s :n p Tray include stccz wn the s: S s r~.ro:scion. and rw� _ inyiny cargo;...~.ca rnL^clir co:..cicl by,-CMor under cca cl with suc : tr=um (3) In the lb!,_ CI ez; r-- s p � .ic-s t0 the gnLzrf s:r:� :n t, a dcpcsit of L'ttst fu^•ds._t intc:cst in hay bink the ;r:s::e, if a bark) shall a qus .` investme.^t to the ext : t,. --t such dei,^- sit is insures un• :T =y pruct -or future lsw of t U i Sures or :o such ,^. eat_• ex as s court of cmpccct cn r; sy se±'?ca shall be e nstr f as 1y i the right of L-'151=LnYrcx cases to m:kc dcpcslts a tr:st ^cutch in balks subjct i t`.: C= of inter�i•bcxrin� d � to such nonoc o: other eenditicrs fe �ng withdrawal as a sy tx p:eac i' by law or govc.-:,.:-tat ::gulsuon srtting such d rte" (4} ti'othir.; in this scc--ca shall sL r;xte or restrict the power of the spp:oprste ecu : in proper cases to di:zz: or permit the Lust.:- to 3ESZF4 h CF -4, 4" "=-:'S Cl ( 1„e Frcns -s oit_s i~ Icn s 3Il:�Zly to all trL.S aoa• etis::; C'G:utr? 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Inw rst er low isswC try• ta+v Ss sa: bu rtisoej -<Q!s u ktil ijr n - F FL: cC s La t m LW Smx cssorstieet: Fb C i I I :.'Atiar�5 aa-;irt Sssocstim MlnlAt>�t.i� C Fs--= iota kaes• Co. C 161 .. 7ns.:er tract fa&M- C-4w C 3 31:11.1 In•t"1 LA`.CI d lrs.srt ed jir c>fiv rrw-r d tok �!r-,t C 12333• Nor.;srr P+rtx:+r r czn cstn And sr�.!:I: t_a L1:"C t�y Awvtlsjt polios a leru _..ntrnrts C,x trrc furors: Its C { 1:5'• L1' cm & Nun 6r Rac tat +rt 1aSd bJ Cd uc^ •;••: U= { 3•k= of eomnog trvcs try ter-,arxt of Ve+LAHn1LL 'a' A I C [ 7= 11un.c al ►•:r/ dav')O tants. 21.11 Uncal A— 547. EXHIBIT B DESCRIPTION OF INVEST'A_ENTS The Redevelopment Agency of the City of Azusa's (the Agency) investments are placed in those securities as outlined below; the balance between the various investment instruments may change in order to give the Agency the best combination of safety, liquidity and high yield. Surplus funds of local agencies may only be invested in certain eligible securities. The Agency invests only in those allowable securities under the State of California statutes (Government Code Section 53601), et sea). CERTIFICATES OF DEPOSIT Certificates of deposit allow the Agency to select the exact amount and day of maturity as well as the exact depository. Certificates of deposit are issued in any amount for periods of time as short as fourteen days and as long as several years. At any given time, the Agency may have certificates of deposit in numerous financial institutions in the f Lure. The Treasurer may at his discretion waive security for that portion of a deposit which is insured pursuant to federal law. Currently, the first $100,000 of a deposit is federally insured by FSLIC or FDIC. It may be to the Agency's advantage to waive this collateral requirement for the first $100,000 because the Agency may receive a higher interest rate. If funds are to be collateralized, the collateral will be 110% of the deposit in government securities or mortgages of 150%. At purchase, institutions must not show an operating loss. Banks must have an equity to asset ratio of at least 6%. Savings and loan associations and savings banks must have an equity to asset ratio of at least 3%. LOCAL AGENCY INVESTMENT FUND Local Agency Investment Fund of the State of California offers high liquidity because deposits can be wired to the City/Agency checking account in twenty-four hours. Interest is computed on a daily basis. This is a special fund in the State Treasury which local agencies may use to deposit funds for investment. There is no minimum investment period and the minimum transaction is $5,000, in multiples of $1,000 above that, with a -maximum of $10,000,000 for any agency. It offers high liquidity because deposits can be converted to cash in twenty-four hours and no interest is lost. All interest is distributed to those agencies participating on a proportionate share determined by the amounts deposited and the length of time they are deposited. Interest is paid quarterly via a check or warrant. 11 0 0 The State keeps an amount for reasonable costs of making the investments, not to exceed one -carter of one percent of the eu earnings. The interest rates are fairly high because of the pooling of the State surplus cash with the surplus cash deposited by local governments. This creates a multi -billion dollar money pool and allows diversified investments. In a high interest rate market, we do better than LAIF. But in times of low interest rates, LAIF yields are higher. U.S. TREASURY SECURITIES U.S. Treasury securities are highly licuid in addition to being considered the safest of all investments. U.S. TREASURY BILLS are direct obligations of the United States Government. They are issued weekly with maturity dates up to one year. They are issued and traded on a discount basis and the interest is figured on a 360 day basis, actual number of days. They are issued in amounts of $10,000 and up, in multiples of $5,000. They are highly liquid security. U.S. TREASURY NOTES are direct obligations of the United States Government. They are issued throughout the year with maturities of 2, 3, 4, 5, 7, 10 years. Notes are coupon securities paying interest every six months. The Agency will not invest in notes having maturities longer than five years. FEDERAL AGENCY SECURITIES Federal Agency securities are highly liquid and considered riskless. Federal Agency issues are guaranteed directly or indirectly by the United States Government. All agency obligations qualify as legal investments and are acceptable as security for public deposits. They usually provide hia-er yields than regular Treasury issues with all of the same advantages. Examples are: Ft7MA's (Federal National Mortgage Association) are used to assist the home mortgage market by purchasing mortgages insured by the Federal Housing Administration and the Farmers Home Administration, as well as those guaranteed by the Veterans Administration. FHLB's (Federal Home Loan Bank Notes and Bonds) are issued by the Federal Home Loan Bank System to help finance the housing industry. The notes and bonds provide liquidity and home mortgage credit to savings and loan associations, mutual savings banks, cooperative banks, insurance companies and mortgage -lending institutions. 2 Some other federal agency issues are Federal Intermediate Credit Banks Debentures (FICB), Federal Farm Credit Bank (FFCB), Federal Land Bank Bonds (FLB), Small Business Administration notes (SBA's), Government National Mortgage Association notes (GNMA's), Tennessee Valley Authority notes (TVA's), and Student Loan Association notes (SALLIE MAE's). These investments will occasionally be used. NEGOTIABLE CERTIFICATES OF DEPOSIT Negotiable certificates of deposit are high grade instruments, paying a higher interest rate than regular certificates of deposit. They are liquid because they can be traded in the secondary market. Negotiable Certificates of Deposit (NCD's) are unsecured obligations of the financial instituticn, bank or savings and loan, bought at par value with promise to pay face value plus accrued interest at maturity. The primary market issuance is in multiples of $1 million, the secondary market usually trades in denominations of $500,000 although smaller lots are occasionally available. Local agencies may not invest more than 30% of their surplus money in negotiable certificates of deposit. NCD's will only be placed with the largest and most financially sound institutions. BANKERS ACCEPTANCES Bankers Acceptances are frequently the highest in yield, are safe investments and are highly liquid. Bankers acceptances are a short-term credit arrangement to enable businesses to obtain funds to finance commercial transactions. They are time drafts drawn on a bank by an exporter or importer to obtain funds to pay for specific merchandise. By its acceptance, the bank becomes primarily liable for the payment of the draft at its maturity. An acceptance is a high grade negotiable instrument. Acceptances are purchases in various denominations for 30, 60 or 90 days but no longer than 270 days. The interest is calculated on a 360 day discount basis similar to Treasury Bills. Local agencies may not invest more than forty -percent of their surplus money in bankers acceptances. CO101ERCIAL PAPER Commercial paper allows the investment of large amounts of money for one to seven days at rates higher than we can earn from our savings account. Commercial paper is a short-term unsecured promissory note issued by a corporation to raise working capital. These negotiable instruments are purchased at a discount to par value. Commercial paper is issued by corporations such as Shearson -American Express, International Business Machines (IBM) and Pacific Gas and Electric Company, etc. 3 Local agencies are permitted by state law to invest in commercial paper of "prime" quality of the highest ranking or of the highest letter and numerical rating as provided by Moody's Investor's Service, Inc. or Standard and Poor's Corporation. Purchases of eligible commercial paper may not exceed 180 days maturity nor exceed thirty percent of the local agency's surplus funds. PASSBOOK SAVINGS OR MONEY MARKET ACCOUNT Passbook savings account allows us to transfer money from checking to savings and earn short-term on odd amounts of money which are not available for longer investment. The savings account is similar to an inactive deposit except not for a fixed term. The interest rate is much lower than CD's, but the savings account allows flexibility. Funds can be deposited and withdrawn according to daily needs. LOS ANGELES COUNTY POOLED FUND Los Angeles County Pooled Fund is similar to the State of California Local Agency Investment Funds. The County fund provides protection, liquidity and higher than market rates for short-term securities. The County Pooled Fund is similar to the State of California Local Agency Investment Fund (LAIF). Los Angeles County has an existing pooled fund with current assets of $3.5 billion serving school districts and other special districts. This pooled fund is managed by the County Treasurer and interest is competitive to money market rates. There are no restrictions to number of transactions or dollar amount of deposits. The funds deposited by a local agency in the County Pooled Fund cannot be attached by the County.. All interest is distributed to those agencies participating on a proportionate share determined by the amounts deposited and the length of time they are deposited. Interest is credited to the account and reinvested. The County keeps an amount for reason- able administrative costs of the pool. The Los Angeles County Treasurer has stated the range of administrative costs is 14 to 18 basis points (approximately 0.14% to 0.18% of the pool fund average daily balance). MUTUAL FUND Mutual fund is another authorized investment allowing the Agency to maintain liquidity and receive money :market rates. Mutual Funds are referred to in the Government Code, Section 53601,L, as "shares of beneficial interests issued by diversified management companies". The Mutual Fund must be restricted by its by-laws to the same investments as the local agency. These investments are Treasury issues, agency issues, Bankers 4 l Acceptance, Commercial Paper, Certificates of Deposit, and Negotiable Certificates of Deposit. The quality rating and percentage restrictions in each investment category applicable to the local agency also applies to the Mutual Fund. A further restriction is that the purchase price of shares of the mutual funds shall not include any sales commission. Investments in mutual funds shall not exceed fifteen percent of the local agency's surplus money. REPURCHASE AGREE74ENTS Another authorized investment for cities is repurchase agree- ments. Repurchase agreements are purchases of securities by the Agency under an agreement with a term of one (1) year or less whereby the seller will "repurchase" the same securities on or before a specified date or on demand of either party and for a specified amount. The underlying securities must be delivered to the Agency by book entry, physical delivery or a third -party custodial agreement. Transfer of the underlying securities to the counterparty may be used for book entry delivery. 5 • EXHIBIT C LIST OF THE PRIMARY GOVERN'dENT SECURITIES DEALERS RETORTING TO THE MARKET REPORTS DIVISION OF THE FEDERAL RESERVE BANK OF NEW YORK Bank of America NT & SA Bankers Trust Company Bear, Stearns & Co., Inc. Carroll McEntee & McGinley Incorporated Chase Manhattan Government Securities, Inc. Chemical Bank Citibank, N.A. Continental Illinois National Bank and Trust Company of Chicago Daiwa Securities America Inc. Dean Witter Reynolds Inc. Discount Corporation of New York Donaldson, Lufxin & Jenrette Securities Corporation Drexel Burnham Lambert Government Securities Inc. The First Boston Corporation First Interstate Capital Markets, Inc. First :rational Bank of Chicago Goldman, Sachs & Co. Greenwich Capital Markets, Inc. Harris Trust and Savings Bank E.F. Hutton & Company, Inc. Irving Securities, Inc. Kidder, Peabody & Co., Incorporated Kleinwort Benson Government Securities, Inc. Aubrey G. Lanston & Co., Inc. Manufacturers Hanover Trust Company Merrill Lynch Government Securities Inc. Midland -Montagu Government Securities, Inc. J.P. Morgan Securities, Inc. Morgan Stanley & Co., Incorporated Nomura Securities International, Inc. Paine Webber Incorporated Wm. E. Pollock Government Securities, Inc. Prudential-Bache Securities, Inc. Refco Partners L.A. Rothschild, Unterberg, Towbin, Inc. Salomon Brothers Inc. Security Pacific National Bank NOTE: This list has been ccnpiled and made available for statistical purposes only and has no significance with respect to other relationships between dealers and the Federal Reserve Bank of New York. Qualification for the reporting list is based on the achievement and maintenance of reasonable standards of activity. Market Reperts Division Federal Reserve Bank of New York December 11, 1986