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HomeMy WebLinkAboutResolution No. 92-R43RESOLUTION NO 92-R43 RESOLUTION OF THE BOARD OF DIRECTORS 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 $20,000,000 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 City Redevelopment Agency to adopt an investment policy for its jurisdiction. NOW THEREFORE BE IT RESOLVED that the Board of Directors of the Redevelopment Agency of the City of Azusa does hereby re -adopt its Investment Policy attached hereto as Exhibit A and instsructs 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 7th day of July , 1992. I HEREBY CERTIFY that the foregoing resolution was duly adopted by the Board of Directors of the Redevelopment Agency of the City of Azusa at a regular meeting thereof on the 7th day of July 1992 by the following vote of Directors: AYES: BOARD DIRECTORS: DANGLEIS, MADRID, NARANJO, ALEXANDER, MOSES NOES: BOARD DIRECTORS: NONE ABSENT: BOARD DIRECTORS: NONE THE REDEVELOPMENT AGENCY OF THE CITY OF AZUSA INVESTMENT POLICY Temporarily idle or surplus funds of The Redevelopment Agency of the City of Azusa shall 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 fust two objectives. The achievement of these objectives shall be accomplished in the manner described below: The Agency shall ensure the safety of its invested idle fund 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 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. 2. Liquidijy 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.' 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 provided financial management services. L-i.u_ VU .ry 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 Man Rule - V (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 Certificates of Deposit (CD's) of California banks and/or savings and loan associations, and/or savings banks which mature in five years or less, provided that the Agency's investments shall not exceed One Hundred Thousand Dollars ($100,000) per institution. If the investment exceeds the insured $100,000, the funds are to be collateralized at 110% of the deposit in government securities or 150% in mortgages. V 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 ...." • * 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) B. Qualification of Bmkgrs. Dealers and Einancial 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 Q. Uninsured Time Deposits with banks and savings and loans shall be collateralized in the manner prescribed by law for depositories accepting municipal investment funds. i•s:: 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. ►I9 1 lig_ .e 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 the 0 0 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. F. Diversification The portfolio should consist of a mix of various types of securities, issues and maturities. G. 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, third 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 that are insured or registered, or for which the securities are held by public units or its agent in the units; b) securities that are uninsured and unregistered and are held by the broker's or dealer's trust department or agent in the unit's name; c) securities that are uninsured and unregistered and are held by the broker or dealer, or by its trust department 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. O ' t t lUlM.L A. Safekeeping A reement 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. W. Handling D=sit 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. The authorization to release 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 telephoned instructions will be sent to the bank within five (5) working days. W10 L , , .. Securities transferred to the Agency as collateral securing time deposits which are being held in safekeeping 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. � r �t a ►11 ' � ► 1• 1 YY 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 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. The Executive Board shall consider and adopt a written investment policy. As provided in that policy, the Board shall receive, review and accept monthly investment reports. D. RRrWnsibilities of the Investment Committee There shall be an Investment Committee consisting of the Executive Director, the Director of Finance and Agency Treasurer. The Committee shall meet quarterly to discuss cash flow requirements, the monthly investment 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 AgencyTreasurer 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. D. Average rate of return on the Agency's investments. E. Maturity aging by type of investments. 1 t►0 Yu l ►1 a :.: „t . r 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. 9 _1! � ' 11 This policy was duly adopted by authority of the Executive Board of the Redevelopment Agency of the City of Azusa on the 19th day of February, 1991. February 4, 1992 E"HIBIT A PRUDENT MAN RULE § 2261 TRUSTS FOR THIRD PERSONS Div. 3 § 2261. Investments (a) Degree of care, skill, prudence and diligence. (1) Subject to paragraph (2), when investing, reinvesting, purchasing, acquiring, ex- changing, selling and managing property for the benefit of another, a trustee shall act with the care, skill, prudence, and diligence under the circumstances then prevailing, specifically including, but not by way of limitation, the general economic conditions and the anticipated needs of the trust and its beneficiaries, that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, to attain the goals of the trustor as determined from the trust instrument. Within the limita- tions of the foregoing and considering individual investments as part of an overall investment strategy, a trustee is authorized to acquire every kind of property, real, personal or mixed, and every kind of investment. (2) The trustor may expand or restrict the standards set forth in paragraph (1) by express provisions in a trust instrument. Any trustee acting for the benefit of another under that instrument shall not be liable to anyone whose interests arise from that trust for the trustee's good faith reliance on those express provisions. (b) Retention of property. In the absence of express provisions to the contrary in any trust instrument, a trustee may without liability continue to hold property received into a trust at its inception or subsequently added to it or acquired pursuant to proper authority if and as long as the trustee, in the exercise of good faith and of reasonable prudence, discretion and intelligence, may consider that retention is in the best interests of the trust or in furtherance of the goals of the trustor as determined from any trust instrument. Such property may include stock in the trustee, if a corporation, and stock in any corporation controlling, controlled by, or under common control with such trustee. (c) Deposit of funds. In the absence of express provisions to the contrary in any trust instrument, a deposit of trust funds at interest in any bank (including the trustee, if a bank) shall be a qualified investment to the extent that such deposit is insured under any present or future law of the United States, is collateralized pursuant to any present or future law of this state or the United States, or to such greater extent as a court of competent jurisdiction may authorize. Nothing in this section shall be construed as limiting the right of trustees in proper cases to make deposits of trust moneys in banks, subject, in the case of interest- bearing deposits, to such notice or other conditions respecting withdraw- al as may be prescribed by law or governmental regulation affecting such deposits. (d) Deviations from terms of trust: court order. Nothing in this section shall abrogate or restrict the power of the appropriate court in 320 OBLIGATIONS OF TRUSTEES Pt. 4 § 2261 proper cases to direct or permit the trustee to deviate from the terms of the trust regarding the making or retention of investments. (e) Application of section; construction of investment authoriza- tions. The provisions of this section shall apply to all trusts now existing or hereafter created. The terms "investments permissible by law for investment of trust funds," "authorized by law for investment of trust funds," 'legal investments," "authorized investments," "invest- ments acquired using the judgment and care which men of prudence, discretion and intelligence exercise in the management of their own affairs, not in regard to speculation, but in regard to the permanent disposition of their funds, considering the probable income, as well as the probable safety of their capital," and other words of similar import used in defining the powers of the trustee relative to investments, in the absence of other controlling or modifying provisions of the trust instru- ment, shall be construed as authorizing any investment permitted, and imposing the standard of prudence required, by the terms of subdivision (a) of this section. (f) Property defined. The term "property" as used in this section includes life insurance, endowment, and annuity contracts issued by legal reserve companies authorized to do business in this state. (Enacted 1872. Amended by Stats.1943, c. 811, p. 2602, § 1; Stats.1967, c. 688, p. 2054, § l; Stats.1967, c. 1706, p. 4265, § 1; Stats.1968, c. 161, p. 385, § 1; Stats.1969, c. 259, p. fill, § 1; Stats.1984, c. 1372, § 1.) Ilistorical Note The section, as originally enucted in 1872, provided: ",1 trustee must invest money received by him under the trust, u fast as he col- lects a sufficient amount, in such manner as to afford reasonable security and interest for the sume." The 1943 amendment rewrote the section to read: "(1) In investing, reinvesting, purchasing, acquiring, exchanging, selling and manag- ing property for the benefit of mother, a trustee shall exercise the judgment and care, under the circumstances then prevail- ing, which men of prudence, discretion and intelligence exercise in the management of their own affairs. not in regard to specula- tion, but in regard to the permanent disposi- tion of their funds, considering the probable income, as well an the probable safely of their capital. Within tine limitations of llw foregoing suindanl, and subject to tiny ex- press provisions or limitations contained in any particular Lnlal instrument, a trustee is authorized to acquire every kind of prolmr- ty, real, personal or mixed, and every kind of investment, specifically including, but not by way of limitation, corporate obliga- tions of every kind, and stocks, preferred or common, which men of prudence, discretion and intelligence acquire for their own ac- count - "12) In the absence of express provisions to the contrary in the trust instrumen4 a trustee may continue to hold property re- ceived into a trust at its inception or subse- quently added to it or acquired pursuant to proper authority if and as long as the trus- tee, in the exercise of good faith and of reasonable prudence, discretion and intelli- gence, may consider that retention is in the best interests of the trust. "(3) In the absence of express provisions to the contrary in the trust insurumen4 a deposit of trust funds at interest in any savings bank or the savings department of any bank lincluding the savings department of the trustee, if a bank) shall be a qualified investment ht the exlcut that such deposit 321 0 § 2261 is insured under any present or future law of the United States, or to such greater extent as a court of competent jurisdiction may authorize. Nothing in this section shall be construed as limiting the right of trustees in proper cases to mike deposits of trust moneys in banks, subject, in file me of interest-bearing deposiLs, to such notice or other conditions respecting withdrawal as may be prescribed by law or governmen. tal regulation affecting such deposits. "(4) Nothing in this section shall abro- gnte or restrict the power of the appix l- ate court in proper cases to direct or permit the trustee to deviate from the terms of the trust regarding the making or retention of investments. "(5) The provisions of this section shall apply to all trusts now existing or hereafter created. Where, in trusts now existing or hereafter created, the term 'investments permissible by law for investment of trust funds; or 'nuthorized by law for investment of trust funds,' 'legal investments,' or 'au- thorised investments,' or other words of similar import are used in defining the pow. ers of the trustee relative to investments, such language, in the absence of other win. trolling or modifying provisimmi of tie trust instrument, shill be construed as authoriz. ing any investment permitted by the terms of subdivision (1) of this section." The 1967 amendment by c. 1706 added the concluding sentence to subd. (2), (later amended. see 1969 amendment); and delet. ed references to savings banks and to the savings department of banks from suhti. (S}. Effect of amendment of section by two or more acts at the same session of the legisla. tore, see Government Code 4 9605. The 1968 Amendment added subd. (6). The 1969 Amendment added the words "and stock in any corporation controlling, controlled by, or under common control with such trustee" to the end of solid. (2). The 1984 amendment rewrote the section which as amended in 1969 had read; "M In investing, reinvesting, purchasing, acquiring, exchanging, selling and manag- ing property for the benefit of another, a trustee shall exercise the judgment and care, under tike circumstances then prevail. ing, which men of prudence, discretion and intelligence exercise in the management of their own affairs, not in regard to specula. tion, but in regard to the permanent disponi. tion of their funds, considering the probable 0 TRUSTS FOR THIRD PERSONS Div, 3 income, as well as the probable safety of their capital. Within the limitations of the foregoing standard, and subject to any ex. press provisions or limitations contained in any particular trust instrument, a trustee is authorized to acquire every kind of proper- ty, real, personal or mixeti, nod every kind of investment, specifically including, but not by way of limitation, corporate obliga. tions of every kind. and stocks, preferred or common, which men of prudence, discretion and intelligence acquire for their own ac. count. "(2) In the absence of express provisions to the contrary in the trust instrument a trustee may continue to hold property re- ceived into a trust at its inception or subse- quently added to it or acquired pursuant to proper authority if and as long as the trus- tee, in the exercise of good faith and of reasonable prudence, discretion and intelli- gence, may consider that retention is in the best interests of the trust Such property may include stock in the trustee, if a corpo- ration, and stock in any corporation control. ling, controlled by. or under common con. trill with such trustee. "(3) In the absence of express provisions In the contrary in the trust instrument, a deposit of trust funds at interest in any bank (including the trustee, if a bank) shall be a qualified investment to the extent that such deposit is insured under any present or future law of the United Stales, or to such greater extent as a court of competent jury indiction may authorize. Nothing in this section shall be construed as limiting the right of trumeen in proper cases to make deposi Ls of trust moneys in banks, subject, in the case of interest-bearing deposits, to such notice or other conditions respecting withdrawal as may be prescribed by law or governmental regulation affecting such cl - pc its. "(41 Nothing in this section shall abro. gate or restrict the power of the appropri. ate court in proper cases to direct or permit the trustee to deviate from the terms of the trust regarding the making or retention of investments. "(5) The provisions of this section shall apply to all trusts now existing or hereafter created. Where, in trusts now existing or hereafter creatnl, the term 'investments permissible by law for investment of trust funds,' or 'authorized by law for investment of trust funds,' 'legal investments,' or 'nu. thorized investments,' or other words of similar import are used in defining the pow- ers of the trustee relative to investments, 322 0 OBLIGATIONS OF TRUSTEES PL 4 such language, in the absence of other con- trolling or modifying provisions of the trust instrument, shall be construed as authoriz- ing any investment permitted by the terms of subdivision (1) of this section. See West's California Code Forms, Civil. 10 § 2261 "(6) The term 'property' as used in this section includes life insurance, endowment, and annuity contracts issued by legal re- serve companies authorized to do Illusions in this stale." Forms Cross References Common trust funds of trust companies, see Financial Cade § 1564. Common trusts, establishment for investment of funds of Department of Mental Health held as trustee, see Welfare and Institutions Code § 7286. Corporate shares, liability of fiduciary for subscription price, see Corporations Code § 413. Deposit of trust company funds awaiting investment, see Financial Cale § 1562. Investments authorized, provisions not altering degree of etre required, see 4 2269.1. Investments of trust company trust funds, see Financial Code § 1561. Mortgage participation certificates and securities guaranteed by mortgage policies as legal investments, see Insurance Code § 12528. Registration of stock held in trust in name of nominee of trust company, see Financial Code § 1563. Savings accounts of savings associations as legal investments for funds of trustees, see Financial Cale § 7000. Trustee to manage proceeds of sale of property subject to life estate upon partition, see Code of Civil Procedure § 873.840. law Review Commentaries Application of SEC Rule X -10B-5 to pre- vent nondisclosure in sale of corporate secu- rities. (1151) 39 C.L.R. 429. Beneficiary's other resources as affecting necessity of invasion of trust corpus. (1953) 1 U.C.LA.Law Rev. 119. Common stock as a prudent trust invest- ment (1951) :19 C.L.R. :180. Construction and application of the Uni. form Principal and Income Act. (1939) 28 C.L.R. 34. Delay causing estoppel to object to pur. chase in breach of fiduciary duty. (1941) 14 So.CaI.I.R. 355. History of supervision of charitable trusts and corloratiuns in California. Wal. lace Huwl;uad (1966) 1:1 U.C.LA. Law Rev. I0'^J. Liability of trustee for improper invest- ments. (1951) :19 C.L.R. :180. Prudence, information and trust invest- ment law. .John A. Humbach and Stephen P. ])resell (197(1) fit A.B.AJ. 11109. Prudent man investment of trust funds during inflation. (1951) 39 C.L.R. 380. Prudent mull investment rule in the law relating to trusts. (1943) 18 S.Bar J. 283. Representation of adverse parties in trust administration. (19117) 55 C.L.R. 948. Revolution in trust investment law. (1976) 62 A.B.A.J. 887. Trust participation in partnership ven- tures. (1951) 3 Stan.f.R. 467. Trustee's power. lower to sell as includ- ing lower to option. Michael H. Dessent (1970) 7 San Diego I.Rev. 22. Toasts—Corlorate executor/trustee. (1975) 2 West SLII.I.Rev. 295. Liability of the trustee for appreciation of properly (1957) 4 U_C.L.A. law Rev. 314. Violation of duty by corporate trustee by Planning for incompetency. Louis M. investing in its own stock. (1949) 37 C.LR. Brown (1104). _ 3'J S. Bar J. 268. 539, &il Planning for incmniktency and practices War conditions as presenting new prob- under the conservatorship buy. George E. lems for investment of funds by trustees. Zillgitt 11964) 37 Su.Cal.I.R. 181. (11142) 17 S.Bar J. 36. 323 §2261 TRUSTS FOR THIRD PERSONS Div. 3 Library References Trusts 1-216 to 217.5. Probate Court Practice, Goddard, C.J.S. Trusts §§ 320, 322. 324 to 329, 331. §§ 1823, 1825, 2207, 2208. Notes of Decisions Borrowing funds 7 Charges agninst trust for beneficiary 8 Cnilccting judgments, not". rents, etc. 10 Construction and application 1 Corpornle trustees 6 Court orders for devintlon from trust 23 Declaration of trust 9 Deposit of funds 11 Discretion of trustee I Interest charges ngninel trustee 25 Investing property 12. 13 In general 12 Prudent investor standard 13 Liability of trustee 21 Lnening property 14 Mortgages 25 Possession of prnpertv 15 Preserving properly 15 Prudent investor standard. investing prop- erty 13 Record of trust funds 22 Retention of property 17 Selling property 18 Speculating with properly 19 Strndnrd of care 5 Surrendering property 20 Trust funds 2 Use of funds in general 3 Value of use and occupation by trustee 21 1. Construction and application This section does not supersede trustee's were given inadequate directions for con- trolling tmst property. Estate of Berges (1977) 142 Cal,Rptr. 685, 76 C.A.3d 100. In determining date of breach of trust by trustee who negligently failed to invest in- come within reasonable time, factors to be considered include purpose of trust, amount of munev on hnnd and amount deemed nec. essary to meet possible contingencies or emergencies in light of role that trustee, in investing and managing property for bene- fit of another, should exercise such core under circumstances as prudent man would exercise in management of his own affairs. Lynch v. John M. Redfield Foundation (1970) 88 Cal.Rptr. 86, 9 C.A.3d 293, 51 A.LR.3d 1284. Provision of former subd. 09) of this sec- tion, that where term "investments permis- sible by law for investment of Gust funds," or other words of similar import are used in defining (rowers of trustee relative to in- vestments, such language, in absence of other controlling or modifying provisions of trust instrument, shall he construed as au. thorizing any investment permitted by for- mer subd. f of this section, establishing the Prudent Man Rude of investment, is only applicable where testator limits investments to statutory approved investments. and has no npplication where .settlor himself speci- fies particular investments that are prr tr ited. Stanton v. Wells Fnrgo Bank k Union Trust Co. (1057) 310 P.2d 1010. 150 C.A.2d 70. general duty to maximize trust assets can. sistent with safety and other relevant con- 2. Troll funds siderations: a slalulodip authorized invest- Land acquired by irrigntion district Be- ment may or may not be the prudent course cause of delinquencies in assessments in of conduct for the trustee to pursue. Mut- trust property, held for the uses and pur- ter of Pelton 11982) 183 Cai.Rptr. 188, 132 lmses of Gen.Laws 1931, Act 3854, govern- C.A.3d 4%. ing irrigation districts, and proceeds of Where testator's will after making a spe- Tense thereof have Lhe same character. cific hequest of tush and any automobile to Provident Land Corp. v- Zumwalt (1939) 85 designated individual. bequentbed to his P.2d 116, 12 C.2d 365. brother and sister as trustees the sum of $600 for each of their respective children 3. Use of funds In general with pmvision that each trust terminates Probate court's factual findings were in - when the child attains 19 years of age. ade.luate hh permit court or appeal to deter - trusts were valid over cnnlentinn of benefi. mine whether bank/conservator breached ciary that the purlwses or terms of trust its fiducinry duty by keeping approximately could not be ascertnined and that trustees $2M.W1 in eslnte's assets in bank's WW. 324 • OBLIGATIONS OF TRUSTEES PL d passbook account for 17 months, during which substitution of conservators wits be- ing arranged, at a time when amounts in excess of $100,000 were earning V.'A inter- est in 30 -day accounts at various banks; a remand for further proceedings was re- quired. Matter of Pelton (1982) 183 Cal. Rptr. 188. 102 C.A.3d 496. Trustee, who is directed by terms of trust to pay income to beneficiary during desig- nated period and on expiration of that peri- od to pay principal to another beneficiary, owes duty to former beaefciury to take care not merely to preserve trust property but to make it productive so that reasonable income will be avuilable for him. and trus- tee is under duty to latter beneficiary to take rare to preserve trust pruporty for him. In re Bissinger's Estate (190.9) 28 Cal.Rptr. 217, 212 C.A.2d 831. Manner in which charter city effectuates purposes of tidelands trust, including man- ner in which it conducts negotiations fur leasing of lands, is municipal affair. Silver Y. City of I.os Angeles 11!1621 17 CaLl it 379, 366 P.2d 651, 57 C.2d 39, certiorari denied 82 S.CL 11,13, 369 U.S. 873, 8 L.Ed.2d 2n0. Under trust principles and applicable pro- visions of the Health and Safety- Code, it is not legally proper to use endowment care funds of private cemeteries to purchase in- terment plots located in the cemetery, for which the fund was established. or to loan such funds to the cemetery, its subsidiary, or affiliate, on the security of a trust deed on such interment plots, or to invest such funds in the stock of such cemetery, its subsidiary, or affiliate. 28 Ops.Alty.Gen. 321. 4. Discretion of trustee A trustee occupies a fiduciary position with duly to exercise its independent judg- ment ;and may not ahtnnatically accede to demands of trust beneficiary. 6forsu v. Crocker Not. Bunk 11!18:1) 1911 CaLlItAr. 8:19, 142 C.A.3d 228. An absolute discretion does not permit a trustee to neglnst his trust or abdicate his judgment. Matter of Collins' Estate (1977) I39 Cal.ltptr. 644, 72 C.A.3d 66:1. Absolute discretion given defeod:nt trus- W�,s of tcsutowutvy trust of wlnicln plain- tiffs were boneficiuries was specifically Ba- ited by requirement in trust instrument that trustees be subject always to discharge of their fiduciary obligations. Ill. § 2261 Note 7 Provision of testamentary trust that "all discretions conferred upon the Trustee shall be ubsolule," viewed as an exculpatory clause, nvus subject to rule of strict con- struction. Id. :Absolute discretion conferred by provi- sion of testamentary trust that "all discre- tions conferred upon the Trustee shall be absolute" was specifically limited by re- quirement that trustee by "subject always to the discharge of its fiduciary obliga- tions." Id. 5. Standard of cure Standard imposed upon trustees is that they exercise that judgment and care which men of prudence, discretion and intelligence would exercise in management of their own afLhirs. Matter of Collins' Estate (1977) 139 CulAtplr. 1144, 72 C.A.3d 663. Trustee is alder a duty to beneficiary to distribute risk of loss by reasonable diversi- fication of investments unless under circum- stances it is prudent not to do so. Id. A trustee with absolute discretion may not neglect its trust or abdicate its judg- ment. til. Record contained no evidence that de- fendant trustees satisfied even the lesser standard of care for which they contended in claiming that trust instrument conferred on chem an "absolute discretion" so as to require them to refrain to act arbitrarily and to use their best judgment- Id. 6. Corporate trustees Different types of im'estments for "cor- porate lnusteew" and for "amateur Irus- tces" are not authorized under prudent in- eestnr standard; difference, ratter, is that corporate trustee is held to a greater stan- dard of care based on his presumed exper- tise. Mutter of Collins' Fstate (1977) 131) CaLltplr. 64.1, T2 GA.ad 663. 7. Borrowing funds Under this section, though trustees are nut orcioarily liable fur interest on moneys coming into their hoods unless they have improperly failed to incest them, they are out justified ill borrowing inure money than they need, and charging trust with interest un sums borrowed, and. where thuy have idle namcy nn hand, it is their iluly Un apply it sn as to slop nmcreessary intemlit charges. Purdy v. Johnson (1917) Ilia P. 8!):I, 174 C. 521. 325 11 § 2261 Nole 8 8. Charges against trust for beneficiary Fact that testamentary trustee had violat- ed her duties as such by commingling trust funds with her own, omitting to invest them, anti negligently failing to keep any records which would enable her to render a true account had a bearing, in absence of vouchers or receipts, on question of wheth- er charges against trust estate for board, clothes, laundry, etc., for beneficiary for 15 years were established by satisfactory evi- dence. In re McCabe's Estate (1948) 220 P.2d 614, 98 C.A.2d 593. 9. Declaration of trust Even if trust instrument permitted a type of investment generally frowned on under prudent -investor rule, it did not authorize defendant trustees to make that investment blindly. Matter of Cullins' Estate (1977) 139 Cnl.Rptr. 644, 72 C.A.3d 663. While the declaration of trust may have possibly enlarged the prudent -investor stan- dard as far as the type of instrument was concerned, it could nut be construed as per- mitting deviations from that standard in investigating the soundness of a specific investment. Id. 10. Collecting Judgment.%, notes, rents, etc. One holding judgment a% trustee for cor- poration and another was required as such trustee and as secre Lary of the corporation to use his hest efforts to collect the judg- ment in full by execution sale of stock owned by judgment debtor. Darden v. Reese (1949) 200 P.2d 81. 88 C.A.2d 9U4. Where trust instrument provided that trustor and son should occupy a dwelling on land constituting the corpus of the trust during trustor'% lifetime and that the land should be sold on trustor's death and pro- ceeds of the sale distributed in a specified mnnner, and on trustor's death trustee re- covered. but dirt not collect judgment in ejectment against the son, trustee was pmper(y charged with the stipulated value of the property an dale trust was to be terminated, the rental of the house former- ly occupied by the son, and the judgment E TRUSTS FOR THIRD PERSONS Div. 3 fault Purdy v. Johnson 11917) 163 P. 893, 174 C. 521. Where testamentary trustees rented land of trust. but their accounts in beneficiary's action against them showed that only part of rent was collected. trustees were bound to account for balance, unless they could show some good reason for failure to col- lect. Id. I1. Deposit of funds Generally fiduciary is personally liable for money deposited by him in bank which becomes insolvent, unless evidence shows that he was not negligent in so doing, and, In absence of order of court. deposit of trust funds in bank is not warranted as an Investment. Allen v. Rainey (1935) 41 P.2d 374, 4 C.A.2d 558. 12. Investing property—In general Rule that trustee has duty to invest al- though generally pertaining to investment of principal, applies likewise to investment of accumulated income. Lynch r. John M. Redfield Foundation (1970) 88 Cal.Rptr. 86, 9 C.A.3d 293, 51 A.L.R.3d 1284. Objections of trust beneficiary that trus- tee, which had been given absolute discre- tion in managing trust property, had negli- gently and carelessly failed to properly ad- minister or manage trust and that as a proximate result beneficiary had been de- prived of reasonable return and had sus- tained loss of some E50.W0 from sale of assets were sufficient to raise issues of abuse of discretion and failure to exercise judgment which trustee should be required to meet Coberly v. Superior Court for Los Angeles County (1966) 42 Cal.Rptr. 64, 231 C.A.2d 685. Rule that it is duly of a tnistee to invest trust funds so that they will he productive of income is designed for trusts intended to be productive of income or other gain, but the Wile is not applicable in the rnae of a trust not designed for income purlroses but for other purposes. such as holding and preservation of property for use by others. Higgins Y. City of Santa Monica (1964) 41 Cal.Rptr. 9. 390 Ptd 41, 62 C.2d 24 - rendered in the ejectment action. Johns v. The capacity of co -trustees to seek court's Peterson (1942) 126 P 2d 90:4, 52 C.A2d 720. instruction as to interp relation of trust It was duty of testamentary tnntees t collect prornissory notes distributed t them, and they were liable Gr beneficiary for amount of notes, with interest, unless their failure to collect was not due to thei o instrument and to obtain permission to de - o viate from terms thereof regarding making or retention of investments, did not cnn%li- s Lute exercise of a "Imwer' within cnntem- r elation of 4 860 requiring that all unite in 326 OBLIGATIONS OF TRUSTEES PL 4 execution of a power vested in several per sans, and 4 '_2?68 requiring all co -trustees to unite in any act to bind trust property, and hence one trustee could appeal from daci- sion allowing deviation from trust require - mems us to investments, though other trus- tee did not wish to appeal. Stanton v. Preis (19561 291 P.2d 118, 138 C.A.2d 63. Under will and decree of distribution giv- ing testamentary trustees right to invest in stocks of corporations of which testatrix was a stockholder on her death if trustees obtained written consent of beneficiaries, trustees were nut required to obtain such consent to purchase stocks of corporations of which testatrix was not a stockholder. In re Fowler's Estate (1943) 182 P.2d 535, 56 C.A.2d 751. That trustees held an investment in stock of bank which thereafter failed did not show mismanagement of trust. In re Knox' Estate (1942) 126 P.2d 108, 52 C.A.2d 338. Under will directing testamentary trus- tees to accumulate in cosh or negotiable securities the sum of $15,000 and to pay income therefrom to beneficiary, a note se- cured by mortgage on Illinois realty was not improper investment, as against conten- tion that. under Illinois law, murtguge was not negotiable security, where negotiability of note was not affected under Illinois how by the mortgage, and word "negotiable" in will was employeil to keep trust funds in comparatively liquid state. Id. In investiug trust funds, trustee 311011111 consider aggregate value of trust estate, nature of other investments of funds of trust, and udvisability of diveroifying in- vestments in order to insure against all. verse enmlitions in any particular field. Day v. First Trust k Savings Rank of Pasa- dena WAD 118 P.2tl 51, 47 C.A.2d 476. Whether trustee los acted prolwrly in making investment depends on circumstanc- es at time investment is made and not oil subsequent events. W. A financial institution with broad general knowledge of nummunity oasls and trends, of character and worth of citizens with whom institution hus dealt and specific knowledge of property values in cumuumi- ty, can consider such positive generul knowledge in investing trust funds, and is not restricted to letter upon letter and line upon line conformity with pme. criled ritual in estimating value of pminised invuzooent C� § 2261 Note 17 in order to avoid charge of negligently man- aging such funds. Id. In determining whether gulf club mort- gages were proper investments for trust funds, appraised value of realty and charac- ter, financial standing, and past perform- ance of officers and members of clubs could be considered. Id. The fact that mortgage participation cer tificates purchased by trustee depreciates in value standing alone does not warrant equi- ty court in opening, surcharging, or falsify- ing trustee's accounts, approved by court. Ormeral v. Security -First Nat. hank of Los Angeles (1937) 69 P.2d 469, 21 C.A.2d 882. In an action against trustees to have de- clared void a purchase made by diem, evi- dence that one of them understood the pro- priety of the purchase was first to be sub- mitted to the beneficiary is admissible. Rett Jacket Tribe No. 28 Y. Gibson (1886) 12 P. t27, 70 C. 128. A California domiciled state or national baulk having a trust department which is the trustee under an instrument which di- rects the investment of the corpus in United States government obligations, may not in- vest such corpus in a mutual fund, the portfolio of which is limited to short -Lunn United States treasury obligaduus. bi Ops. Atty.Gen. 212, fr29-84. Where unly the interest on the corpus of funds given in trust to the director of elu- culiun is to be used for educatimud pur- poses the director of education on hehalf of estate and in his official capacity should invest the trust funds, collect the interest and apply the iutcrest as specified by the trustor. I Ops.A Lty.Gen. 90. 17. — Prudent investor standard, in. vesting property Ilmdeul investor standard does not apply where settlor himself specifies trustee is not limited by what law provides are proper iuvesunenls. Matter of Collins' Estate (1977) 139 Cal.Rplr. 644. 72 C.A.3d 663. Although Californias does not limit trus- tee's authority to a list of authorized invest. mmnts, relying instead un prudent invevutor rule• that rule nevertheless encompasses curtain guidelines that must le followed by trustee. Id. Provision in trust Instnunenl to purchase every kill([ of pmperly and stake every kind of invustment "irruapective of whether said invealmcuci are in accorda ce widt We luws 327 § 2261 Note 13 then enforccl in the Stale of California pertaining to the investment of trust funds by corporate trustees" did not authorize trustees to make improper investments in vialnlion of prudent investor standard. Id, Different types of inveslme-nl-a are not authorized for "corporate trustees" as dis- tinguished from amateurs; difference, rath- er. is that corporate trustees are held to a greater standard of care based on their presumed expertise. Id. Defendant trustees failed to follow 'pr t - dent investor" standard with respect to ad- ministration of testamentary trust of which plaintiffs were beneficiaries where they In- vested two thirds of trust principal in a single investment, invested in real property secured only by a second deed of trust, and made that investment without adequate in- vestigntion of either borrowers or collater- al. Id. Investment by nonprofit cemetery corpo- ration of nearly BIM of its endowment fund in note and first deed of trust on one parcel of real property could be found to be a violation of prudent investors role with re- spect to investment of trust funds and cem. etery boort], department of professional and vocational standards, was authorized to or- der Hot sum lent be reinvested. Mandel v, Cemetery Bd., Dept_ of Prnfcssiona] and Vocational Standards (1960) 8 Cal.Rptr. 342, 185 C.A.2d 583. This section broadens list of legal invest- ments for trustees of endowment care funds. but also places trustees under man- date of prudent investors role in regard to all of their financial transactions. Id. An essential part of prudent investors rule with respect to investment of trust funds is the miquirement that investments be diversified. Id. Under provisions of this section eml)n dv- iug "prudent man role" in setting forth duty of trustee in cnnucetiun with invest- Where an agent or trustee is instructed me.nL of trust funds, aml under general law to "loan out" frauds held by him. it means applicable to Lrustmw. trustee, even where that he is to invest them far his principal's given broad discretionary luoacer of invest. ncent nt. and to make an accounting to the ment, must exercise its independent discre- principal of such investment and he is nut tion and judgment io reference to iuvmt. authorized to borrow Lite funds for his own ment of trust funds. In re Talbot's ESlate purposes, In re Armstrong's Estate (1883) 11956) 296 P.2I 848, 141 C.A.2d 30:), 58 1 Cot 157, affirmed 10 P. 335, 69 C. 239. A.LR.2d MR- Where trustee loaned out the funds of A trustee is neither expected in bury his beneficiary without advising her of the risk talents nor to exercise infallible judgment in to which he was subjecting her funds nor of investment of Grads, hitt he mast exercise his mingling the funds with Itis own in lis - skill rand judgment of reasonably prudent crinrinalely he was liable for the loss result. business man its preserving estate and at ing therefrom and his account a; special 328 0 TRUSTS FOR THIRD PERSONS Div. 3 Lite same time make the estate productive. Day v. First Trust & Savings Bank of Pma- dena (1941) 118 P.2d 51, 47 C.A.2d 470. A trustee must use due care and skill and the caution of a prudent man in making investments, and, in absence of provision in trust or statute, he can make those invest- ments which a prudent man would make in investing in property outside of ordinary business risks and with a view to safety of principal and to securing of an income ren- sonable in amount and payable with regu- larity. Id. Evidence warranted denial of liability of trustee for depreciation of trust assets dur- ing economic depression, on ground that trustee was not negligent in investment of funds, but exercised care of ordinarily pru- dent person. Id. The liability of a director of education acting as official trustee for bequests of funds to be used for educational purposes is to make such investments its a prudent man would make of his own property, having primarily in view the preservation of the estate and the regularity and amount of Income. 1 Ops.A Lty.Gen. 90. H. Loaning property Evidence that the land mortgaged to se. cure a Iran made by a trustee was and land, which it -at; practically imlossible to irrigate, and that the trustee made the loan upon the statements of one man, whom she knew, and a written report by three strang- ers, two of whom were the former owners of the land who had conveyed it to a dummy for Lite purpose of securing the loan there- on, sustained the trial court's finding that the trustee was negligent in making the loan, and was therefore bound to mnke good Lite loss. In re Hamon's Estate (1923) 212 P. 399, 60 C.A. 154. r� u OBLIGATIONS OF TRUSTEES Pt. 4 administrator for the beneficiary should be charged with the loss sustained. Id. 15. Possession of property In action for declaratory relief with re- spect to the scope of joint will by which husband and wife converted property into community property, court had broad pow- ers and could, prior to distribution, interpret will on question of whether widow upon distribution, would be entitled as against trustees to possession of any of property involved. Chase Y. Leiter (1950) 215 P.2d 756, 96 C.A.2d 439. 16. Preserving property Executor serves in fiduciary capacity and has powers and obligations similar to trus- tee, except that primary duty is to preserve estate until distribution, rather than invest funds. In re Slingsby's Estate (1931) 297 P. 931, 112 C.A. 767; In re Brenhart's Estate (1931) 297 P. 9:11. 112 C.A. 766; In re Smidn's Estate (1931)'297 P. 927, 112 C.A. 680. 17. Retention of property Usually trust is created to preserve prop- erly intact and to earn income for benefi- ciary, and ordinarily trustee is directed to administer funds in order to substitute sup- posedly superior judgment of trustee for that of beneficiary. Day v, t•Irst Trust & Savings Bunk of Pasadena (1941) Hil 11.24 51, 47 C.A.2tl 470. An honest trustee is not liable to make good the loss susunined by retaining an authorized security it, a falling market, if he did so honestly and truthfully, in the belief that it was best course to take in inwresl of all parties. Id. 18. Selling property Where trustee bud broud power of stile but, iusteud of exercising independent judg- ment as to sale of common stocks, relied on one beneficiary's unfulfilled ;wsurance that latter would secure from other beneficiaries written consents to the sale. and tnnstee sold stocks which thereafter doubled in val- ue, trustee was liable for mluctimn in value of objecting beneficiary's share of corpus, i.e., reduction consisting of capital gains taxes and expense of stock sales and bond purchases. and for interest oil amount of such reluction, but trustee was not liable for appreciation in value of stocks after sale or for loss of income on stocks. In re 0 § 2261 Note 18 Talbot's Estate (19561 '296 P.2d 848, 141 C.A.2d 309, 58 A.L.R.2d 658. Where trustee has a broad power of sale, right of income beneficiury is simply to insist that trustee shall exercise its indepen- dent judgment. and income beneficiary has no legal right to compel retention of any stocks and is not legally hurt by reason of the trustee's failure to keep certain stocks. Id. When trustee who owned as trustee all the stock of corporation, which by the sale of its real estate supplied assets for distri- bution to trustee is trust, dissolved the cor- poration, trustee had title to real estate and had power and duty to carry out purpose of trustor by selling lands and receiving pro- ceeds from sales into the trust Stubbs v. Jones (19531 263 P.2d 100. 121 C.A.2d 218. A testamentary trustee, using diligence and discretion in selling foreign government bunds includeil in trust assets and receiving highest prices obuninable therefor, was properly allowed credit on accounting for loss sustained in sale thereof for less than their value as fixed by court in settlement of previous accuunts, in absence of evidence of negligence in making sale or showing that life beneficiaries of income, in contest. ing previous account, sought to charge Lrua- tee with value of bonds as cash on hand owing to estate because of his neglect to sell bonds. In re Bothwell's Estate (1944) 151 P.2d LN8, tis C.A.2d 5,98, rebeuring de- nied 151 1'.2d 868, 65 C.A."_d 598. Assessment of damages against trustee for negligence in falling to Sell trust really as directed by trust instrnnent, thereby depriving life beneficiaries of income, should not be resorted to by them when another appropriate remedy, such as appur- lionnnenl of proceeds of subsequetlL stile thereof between principal and income, is available. Id. In action apminst lroslee for accounting under contract authorizing trustee to man- age and sell pam is of really on such Lerms and at such tiles as trustee, within his discretion, should determine, evidence did not show that trustee, in refusing offer to purchase prupery at price subsequently shown to be adequate, did not exercise an honest judgmunt. :and his estate was, there- fore, not liable for da o ges for such refus- ul. Neel v. Barnard 119441 150 Ptd 171, 24 C.2d 406. In action against trustee by beneficiaries of trust for accounting and for damages. 329 0 § 2261 Note 18 finding that trustee had no opportunity to sell property involved at such prices as would have liquidated plaintiffs' indebted. ness as provided by contract crendng trust. or on such terms as trustee properly fixed, determined in effect, that a rensnnnble time for sale of property had not elapsed. Id. Even if offer was made to trustee for purchase of realty which trustee held for sale for benefit of beneficiaries of trust, it would be presumed that trustee exercised Isis judgment upon it and deemt"I price of- fered too low, and court could not say that he acted fraudulently or in bad faith in declining to sell. Id. A trustee can properly sell trust property if such sale is necessnry or appropriate to enable trustee to carry out purposes of trust. unless sale is forbidden in specific words by terms of trust or it appears from terms of trust that property was to be retained in specie in trust Church v. Church (1940) 105 P.2d 840, 40 C.A.2d 886. Where father of minor children took out shares of stock in a family corporation in his name ns trustee for children, and the father had never executed any document in writing or declaration of trust restricting his power, as trustee, to transfer shares, and evidence warranted finding that, aside from trustee's certificates, there was no such agreement entered into concerning shares, and it did not appear that any re- striction on power of sale was contained in certificates, it could not be said as matter of law that the faduer did not have the right• as trustee, to transfer shares whenever, in exercise of his discretion, it appeared to him proper or necessary to do so. Id. Where money is bequeathed to a trustee to invest in land, with liberty to change the investment at his discrelimu. the superior court is without jurisdiction to entertain a suit by the cestui que trust to order the tnistee to sell Lite land subject to confirmn- don by the court nor an application by an inten•ener in such a suit to confirm an alleged contract of side to him by the trus- tee, and to direct Lite execution of convey- ance. Murphy v. Union Tnixt Co. of San Francisco (1907) 89 P. 988, .5 C.A. 146. 19. Speculating with property A beneficia" who learned that trustee had disoheyed instructions not to speculate in stocks was required to net within a Mo. suitable time thereafter and could not wait and hold trustee for subsequent decreases 0 TRUSTS FOR THIRD PERSONS Div. 3 in value of stocks in the account Weiner v. Mullaney (1943) 140 P.2d 704, 59 C.A.2d 620. Where beneficiary learned from broker in January, 1938, that instructions to trustee not to deal in stocks had been violated, beneficiary was put upon inquiry at that time and was charged with "notice" of all that an inquiry would have disclosed. Id. Where trustee failed to make full disclo- sure of facts surrounding use of benefr ciary's shares in stock transactions contrary to instructions, that it was no longer within beneficiary's power to rescind tranenction when she finally learned the true situation and her only recourse was to salvage what stocks were left, such action on her part did not amount to a "ratification" of trustee's eonducL Id. Where trustee was expressly instructed not to sell or deal in stocks for beneficiary, his action in dealing in stock was a "breach of trust" for which he was liable. Id. A trustee is not permitted to buy and sell bonds on speculation and die fluctuations in market value after purchase by the trustee are merely changes in the value of the assets of the trust "Lite. which are to be wholly disregarded in any accounting be- tween life tenant and remaindermen for fumis from the trust estate invested in in- come-benring property. In re Gartenlauh's Estate (1921) 198 P. 209, 185 C. 648, 16 A.LR. 520. 20. Surrendering properly Evidence was sufficient to support find- ing as to market value of bonds in action by beneficiary against trustee for value of bonds deposited with trustee which trustee without authority surrendered to bondhold- ers' pmtective committee. Martin v. Bank of America Trust k Savings Assn (1935) 41 P.2d 200, 4 C.A.2d 431. 21. Value of use and occupation by trus- tee A purchaser of land with notire of the facts entitling another to the delivery to him of a deed pmviouM'v made out in his favor, who obtains possession by force from We cestui que trust, must account to him for Use value of the use and occupation. and the cestui que trust must pay tiro purchase price into court for the benefit of the trus- tee. adding interest from the date of the tender of the price, unless he chooses to regard the interest as liquidating the value 330 0 OBLIGATIONS OF TRUSTEES PL 4 of the use. Cannon v. Handley (1887) 13 P 315, 72 C. 133. 22. Record of trust funds A trustee or attorney handling funds of a client cannot escape responsibility for trust fund by failing to keep any record or data from which an accounting might be made. Bruns v. State Bar of California (1941) 117 P.2d 327, IS C.2d 667. 23. Court orders for deviation from trust Equity court order to sell realty, contrary to terms of expnsa testamentary trust, and reinvest proceeds, was unauthorized, in ub- sence of present market value Lhereof and showing of character or security of proper. ty in which he proposed to reinvest pro- ceeds. Security -First Nat. Bank Y. Easter (1934) 29 P.2d 4=f. 136 C.A. 691. 21. Liability of trustee If money paid for trust is lost or de stroved without fault of trustee -payee, trus tee -payee is not liable therefor and loss c borne by payer, trustorlteneficiary. Pelh erbridge v. Prudential Say. & Loan Ass'r (1978) 145 Cal.Rptr. 87, 79 C.A.3d 509. Defendant trustees were subject to being surcharged for imprudent investment of monies from testamentary trust in which plaintiffs were beneficiaries, not because they lacked prescience of what would hap pen, but because they both lacked and ig nored information about what wtu happen ing at time. Matter of Collins' Eatatt 11977) 139 Cal.Rptr. 644, 72 C.A.3d 663. Trustee who negligently breaches hit trust by failing to invest income within rein sortable time is liable pursuant to statutt for simple interest at rate of 75 per annum. Lynch v. John M. Redfield Foundatior (1970) 88 Cul.liptr. 86, 9 C.A.3d 293, 51 A.LR.3d 1284. One who engages services of trustee, cor porate or otherwise, contracts for exercise of trustee's best judgment and for perform ante of duties outlined in this section; tone he has no right to receive any more that that and no right to complain if those ser vices are rendered in good faith and with reasonable prudence. discretion anti intelli genre. In re Rissinger's Estate MGM 2E Cal.Rptr. 217. 213 C.A.2d 531. Generally, trustee's violation of equitable duty, whether fraudulently or through neg ligence, mere oversight or forgetfulness, it breach of trust, and trustee may be churget 10AC I.CaEe—t2 0 § 2261 Note 25 with rents, profits and income which he never received, but might and should have received by exercise of due and reasonable care and diligence. White v. Citizens Nat. Trust & Savings Bank of Los Angeles (1941) 116 P.2d 117, 46 C.A.2d 418. The nominal title holder of realty, incum- bered by a trust deed, who upon taking title to realty assumed obligations of trustee for benefit of obligees whose claims were se- cured by trust deed, differed from a mort- gagor in possession and was liable for all rents and profits received while in posses. sion of Lite realty even prior to sale thereof under power of sale contained in trust deed. Baumann v. Harrison (1941) 115 P.2d 530, 46 C.A.2d 84. 25. Interest charges against trustee Failure of directors of charitable, non. profit corporation to invest dividend income deposited in corlwration's checking account over five -your period was breach of their duty to invest funds as would a reasonable Pian so that funds would be productive of income and were liable for interest on suns Inst in consequence of such failure, notwith. standing facts that bank had refused to honor drafts drawn on corporation's ac- count due to dispute among directors, that directors served without compensation, that, during period of inaction, corpus gained approximately 100.1 in value, and that costly lawsuit would be necessary to settle directors dispute and remuve "block- ing" from bank account. Lynch v. John M. Redfield Foundation (19701 SS Cal.Rptr. 86, 9 C.A.3d 2993, 51 A.LR.3d 1294. In action by beneficiary under two ex. press trusts for an accounting by Lite re- slwctive trustees, where trustees had waived delinquent interest on notes due Lite trust, had not collected note from deceased maker, and had made loans which were disapproved! by the court, trial court's charge of Cis- interest on amount thus sur- charged, except for the unauthorized loan concerning which current savings bank in- terest rates compounded semiannually were charged, did not constitute nn abuse of dis- crelinn. Douglas V. Westfull (1952) 248 P.2d 68, 113 C.A.2d 107. Where will created trust of specific lega- cy, with amount thereof and accumulations to be paid to beneficiary when she reached age of 26, when executor who was also trustee had failedl to transfer corpus to himself as trustee or to invest same as raluired by this section, and estate was not 331 r-1 L-A § 2261 Note 25 distributed prior to time for distribution to beneficiary of trust, 7 per cent interest due upon corpus for failure to invest would be allotted 4 per cent against estate and the remaining 3 per cent against trustee as such. In re Prior's Estate (1952) 244 P.2d 697, Ill C.A.2d 464. Where will crented trust of specific lega- cy, with amount thereof with accumulations to be paid to beneficiary whet, she reached age of 26. duties of trustee who was also executor commenced upon deaUt of testa- tor, and failure of executor to transfer fund to himself as trustee could not absolve him of his duties and responsibilities asst trustee including duty to invest, and could not limit liability for interest to 4 per cent rate appli- cable to executors. Id. 26. Mortgnges Equity will sanction an investment se- cured by a second mortgage it, a rare case but only when security is adequate and unusual circumstances justify trustee in 1J TRUSTS FOR THIRD PERSONS Div. 3 making such an investment. Matter of Col. lins' Estate (1977) 139 Cal.Rptr. 644, 72 C.A.3d 6f.9. In buying a mortgage for trust invest- ment. trustee should give careful attention to valuation of property in order to make certain that margin of security is adequate; he must use every reasonable endeavor to provide protection which will cover risks of depreciation in property and changes in price levels and must investigate status of property and of mortgage m well us finan- cial situation of mortgagor. Id. Provision of testamentary trust that "all discretions conferred upon the trustee shall be absolute" did not authorize the trustees to invest in a junior encumbrance without ability to protect against the foreclosure of a senior lien or to refrain from making a business like investigation of the credit worth of the borrower or insisting on an appraisal of the security given by the bor- rower. Id. § 2262. Interest on failure to invest INTEREST. SIMPI.E OR COMPOUND, ON OMISSION TO INVEST TRUST 610NEYS. If a trustee omits to invest the trust moneys according to the last section, he must pay simple interest thereon, if such omission is negligent merely, and compound interest if it is willful. (Enacted 1812.) Forms See West's California Code Forms, Civil. Library Rderences Probate Court Practice. Goddard, H 1590, 1825. Not" of De[btluna In general I Clrcumelnnces of the case 3 Compound Interest 9 Construction with other law. 2 Dunllon of investment innclivity R Duration of liability for Interest 5 Gmrd fnilh 4 Fruitless inrestmenls 7 Rate of Interest 9 Liability of lrusleds estate it) 3:32 1. In general Main chnncteri+tics of trust relationship are Umt pny-or retains beneficial interest in money paid, trustee payee muv not use money for own puritan", in absence of agreement to contrary, trustee keeps mon. ev as separate from his own funds, trustee h duty to invest money and make it produc. tive and is entitled to reimbursement for all expenses Irrolterly incurred in performance of trust, and if money Imid is lost without 0 0 CIVIL CODE Law Re'ieion Commission Comment 1966 Repeal Former Section 2233 Is superseded by Probate Cade Sections 15642().) (grounds for removal of trustee), 16902 (duty of loysity), and 16004 (duty a avoid connet of interest). [IS CaLLRev.Comm. Repons 301 (1986)1. Former Section 2234 is superseded by Probate Code Section 16400 (violation of duty is breach of Iruat). The liability for breach Is governed by statute. See Prob.Code 11 16440 (measure of liability for breach of trust), 16441 (measure of liabifity for Interest). [I1 CaLLR".Comm. Reports 501. 1750 (1986)]. Forme Section 2235 is supmeded by Probate Cade Section 16002 (duty of loyally) and 16004 (duty to avoid =film of interest). [18 CAL-Rev.Comm. Reports 501 (1966)1. Former Section 2.236 is superseded by Probate Code Seniors 16009 (duty to keep tout property separate) and 16440 (measure of liability for bench of trust). See elm Prob.Cde § 16420(a)(3) (rdros of breach by payment of money). 118 CAI.LRev.Casnm. Reports 501 (1996)]. Farmer Section I237 is mpessdd by Probate Code Salon 16440'x) (meaurc of liability for breach of trout) and 16441 (meaure of liability fear interet). See elm Prob.Code § 16420(a)(3) (redress of breach by payment of master). [IS U.LRev.Comm. Repona 501 (1986)). Subdivision (1) of farmer Smim 2239 is superseded by Probate Code Smion 16440 (measure of liability for breach of cwt). Subdivision (b) ts restated in Probate Code Section 16462(s) (nonliabiilty for following Instruatiana aro der revocable trust) without substantive chants. See dm Prob.Code 1 16420(1)(3) (redress of breach by payment of money). 118 Cal.LRey.Comm. Reports 501 (1986)1. Farmer Smion 2239 is restated In Probate Code Section 16402 (lwtee'a liability to beneficiary for acts of cmwlR) with several changes. See the Comment to Pmb.Code 1 16402 (18 Cs1.LRev.Camrrt Reports 501 (1986)3. Pana of former Section 2240 are superseded by Probate Code Sections 15620 (action by totwtm) and 16200 (powers subject to limitations In Irsn). The authority to make deposits is euvr inud In Probate Code Section 16239 (power to deposit seeuritin in depository) without subsun. dye change (18 C11.LRev.Comm. Reports 501 (1986)). Pointer Section 2243 is superseded by Probate Code Section 18100 (protenion of third perxo t dealing with trust. R). See aim Pmb.Cde 1 15003 (comtructive and resulting sail unARend). [Ie Cal.LRey.Cornm. Reports 501 (1986) ). Former Section 2344 is superseded by probate Code Salon 18101 (eppllcatlon of propeny delivered to trustee by thiel person). [I8 CaLL-Rcy.Comm. Report, Sol (1986)3. Fortner Section 2250 is mpersdd by Probate Code Section 32 ("wsl" defined). The provision relating to the '"ting of title in the trustee is not continued Se, the Comment m form" Section 863. [19 CO.LRev.Comm. Reports 501 (1986)} Former Section 2251 is Npencdd by Probate Code Section 15200-15207 (creation of Irwt), 15600 (a«eptance Of trent by IwtR), and 16420(aKI) (beneRnary may wen• laid tat= m perform clinical. [I$ CaLLRev.Comm. it.. Pons 501 (1986)]. Farmer Section 2252 is omitted a unnecessary. [18 CALLRee.Comm. Reports Sol (1956) 1. Former Smion 2253 is Npersdod generally by Pmbate Code Secthsm 15200 (mahode of creating Inst), 17201 (Intension to create Iwt), and 16000 (duty to Administer trca). 119 GLLRev.Comm. Reports 501 (1986) 1. 14 2228 to 2290.9 Repealed Former Section 2254, which stated a special application of the parol evidence Nle, is omitted because this quedon la governed by the general parol evidence Nle. See Code Civ.Proe 1 1856; ser also Prob.Code 1 13207 (proof of terms of oral tnst of personal Property). [18 CAL -Rev. Comm. Reports 501 (1986) 3. The pan of .subdivision (a) of runner Section 1258 relating to control of the trustee I duties by the Inset imwmest is muted In Probate Code Seellon 16000 (duty to Administer Irttst according to tat instrument) without substantive change. but the channerintiun of the duly of the trustee a that of an employ= is omitted. The pan of subdivision (a) relating to modification is superseded by Probate Code Smion 15404 (mdlfintion by settlor and a0 bcmflciarieF The Mt sentence of suhdMsim (b) is continued in Probate Code Section 16001 (duty of trustee of revocable was) without substantive change. The second sentence is restated in Probate Code Sections 1616I (nemllability for following instruction under rerooble tout) wlthoat Nb• suntive change. The reference to a person having a voted or coningent interest in the trust is replaced by the refer- tote in Probate Cde Section 16462 to the beneficiary. See Pmb.Cde § 24 ("beneficiary" defined). The last pan of the second sentence relating to fiduciary obligations of the dir=ting party is omitted As unnmeaary. See also Prob. Code 1 10 (singular includes plural). [I9 CaI.LRm.Comna Repoms 501 (1986)). The pan of former Section 2259 relating to the effect of tumpemation on the standard of care is roused in Probate Code Smion 16041 without substantive change The "ordl- nary n= and diligence" standard of former Section 2259 Is superseded by Probate Code Smion 16640 (tout='a suss. dard of care in Administering mcst). [I8 Cal.LRev.Camm. Reports 501 (1996)1. Fortner Smion 2260 is superseded by Pmhale Code Sections 15641 (liability of resigning tout"), 15660 (ap. pointment of utas= Io fill vacancy). 16000 (duty m admin• lst" bust), and 17200(b)(10) (petition for Appointment of Wsft). [18 CaLL-Rev.C'ornot. Reports 501 (1986)1. The standard of care governing Investments and manage• mast of lint property provided by subdivision (a)(1) of former Section 2261 is restated in Probate Code Smion 16040(b) without substantive change The authority to Acquire ""cry kind of property" Is rotated in Probate Code Sections 16223 (pow" to invest) and 16226 (power to acquire pmpeny). See also Prob.Cde 11 62 ("propertf defined). 16200 (general Powers of trust= include powers of prudent person). Subdivision (a)(2) of former Section 2261 is rotted in Probate Code Salon IW40(c) without sob. nanlye change. See also Prob.Cde 1 16000 (genenl duties of trustee subject to control by trust insnamem). The standard of sue provided in the last IWf of the near sentence of subdivision (b) Is vupmdd by Probate Code Sections 16040 (trustee's standard or care in administering (rust) And 16200 (exercite of powers subject to Iimiudasn In Ins(). See Also Prob.Cde 1 16220 (power to calla ad hold propeny). The Authority to retain pmpeny in hurt at las Inception or later acquired pursuant to proper authority Is rotated In Smion 16003(b) as an ex.eplim to the Mersa duty to dlspont of improper invesummm The secod tee. tense of nbdlyiskm (b) Is superseded by Probate Code Settlors 16220 (power to hold property in which mss= is Interested). See also Pmb.Code 1 62 ("property^ delhsed). Subdivision (c) Is superseded by Probate Cade Sections 16200 (exercise of pow. sabj=t to Ilmitation I. mat) and 16235 (Pow" to make depmiu). See Wo Pn4Cda 1 16201 (power of tours to relieve tat" froom roenetlmu). Additions or changes Indicated by underline; deletions by seterlsks 7 DESCRIPTION OF INVESTMENTS The Redevelopment Agency of the City of Azusa's investments are placed in those securities as outlined below; the balance between the various investment instruments may change in order to give the Redevelopment 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 seq). 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 future. 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 fust $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. The State keeps an amount for reasonable costs of making the investments, not to exceed one- quarter of one percent of the earnings. 1 0 0 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. kWO-G-7 l . r U.S. Treasury securities are highly liquid 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, 6, 10 years. Notes are coupon securities paying interest every six months. The Agency will not invest in notes having maturities longer then 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 higher yields than regular Treasury issues with all of the same advantages. Examples are: FNMA'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. 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. 2 Negotiable Certificate of Denosit 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 institution, 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. Commercial 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. 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. C Passbook Savipas or Money Niarket 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. Wrlvivm- 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 reasonable administrative costs of the pool. The Los Angeles County Treasurer has started 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 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. 4 0 0 Repurchase Agreements Another authorized investment for cities is repurchase agreements. 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 counter -party may be used for book entry delivery. 5 :7 , : EXHIBIT C LIST OF THE PRIMARY GOVERNMENT SECURITIES DEALERS REPORTING TO THE MARKET REPORTS DIVISION OF THE FEDERAL RESERVE BANK OF NEW YORK Bank of America NT & SA Bankers Truct 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 National Bank of ChicagoGoldman, 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 compiled 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 Reports Division Federal Reserve Bank of New York December 11, 1986