HomeMy WebLinkAboutResolution No.89010
RESOLUTION NO. 8901
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
AZUSA ADOPTING ITS INVESTMENT POLICY
WHEREAS 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 City Treasurer is charged with the duties
of handling and maintaining the cash that is taken in or
otherwise received by the City; and
WHEREAS the balance of these funds fluctuates between
$3,000,000 and $10,000,000 or more; and
WHEREAS the City 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 to
adopt an investment policy for its jurisdiction.
NOW, THEREFORE, BE IT RESOLVED that the City Council of
the City of Azusa does hereby approve its Investment Policy
attached hereto as Exhibit A and instructs the City Treasurer
to be guided by it in carrying out the duties of his office for
the benefit of the City of Azusa.
ADOPTED AND APPROVED this 6th day of August 1990.
I HEREBY CERTIFY that the foregoing resolution was duly
adopted by the City Council of the City of Azusa at a regular
meeting thereof on the 6th day of August, 1990 by the following
vote of Council:
AYES: COUNCILMEMBERS: ALEXANDER, MOSES, NARANJO, STEMRICH
NOES: COUNCILMEMBERS: NONE
IS
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 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 Azusa'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 City shall insure 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
(iii) by diversifying the investment portfolio
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so that the failure of any one issue or
backer will not place an undue financial
burden on the City.
b) Interest rate risk will be mitigated by:
(i) structuring the City's portfolio so that
securities mature to meet the City's
cash requirements for ongoing oper-
ations, 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
City's investments is also an important
element of safety. Detailed safekeeping
requirements are defined in Section III of
this policy.
Liquidity
The City'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.
Yield
Yield on the City'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 City
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.
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B. Time Frame for Investment Decisions
The City's investment portfolio shall be structured to
provide that sufficient funds from investments are
available every month to meet the City'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 City Council approval.
C. Definition of Idle or Surplus Funds
Idle or surplus funds for the purpose of this policy
are all City funds which are available for investment
at any one time, including the estimated checking
account float, excepting those minimum balances
required by the City'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 City of Azusa personnel provide financial
management services.
This section of the Investment Policy identifies the types
of instruments in which the City will invest its idle funds.
A. Eligible Securities
The City of Azusa operates its temporary pooled idle
cash investments under the Prudent Man Rule - l/ (Civil
Code Section 2261, et seq). See Exhibit A. This
affords the City 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 City's
investments shall not exceed One Hundred Thousand
Dollars ($100,000.00) per institution. If the
l/ 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 ......"
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B.
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investment exceeds the insured $100,000.00, the
funds are to be collateralized at 1108 of the
deposit in government securities or 1508 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 308
of portfolio)
* Bankers Acceptance (limited to 408 of portfolio)
(Not collateralized; emergency use only)
* Commercial Paper (limited to 308 of portfolio)
(Not collateralized; emergency use only)
* Passbook Savings or Money Market Demand Deposits
* Repurchase Agreements (limited to 308 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 City 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.
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E. Notice of Dealers
The City 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 investments. Receipt of the Policy and
Resolution, including confirmation that it has been
received by persons handling the City'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, 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 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.
III SAFEKEEPING OF SECURITIES
A. Safekeeping Agreement
The City shall contract with a bank or banks for the
safekeeping of securities which are owned by the City
as a part of its investment portfolio or transferred to
the City under the terms of any repurchase agreements.
B. Handling of City Owned Securities and Time
Deposit Collateral
All securities owned by the City 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 City'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 City'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.
D. Verification of Security
Securities transferred to the City as collateral
securing time deposits which are being held in
safekeeping for the City will be verified in writing
and examined on a surprise basis during the year by the
City's independent auditors as part of the City'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 City Treasurer
The City Treasurer is charged with responsibility for
maintaining custody of all public funds and securities
belonging to or under the control of the City, 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.
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V.
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B. Responsibilities of the City Manager
The City Manager is responsible for keeping the City
Council fully advised as to the financial condition of
the City.
C. Responsibilities of the City Council
The City Council shall consider and adopt a written
investment policy. As provided in that policy, the
Council shall receive, review and accept monthly
investment reports.
D. Responsibilities of the Investment Committee
There shall be an Investment Committee consisting of
the City Manager, the Director of Finance and City
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 City Treasurer.
This will require timely reports from the department
heads to the City Treasurer concerning significant
future cash flow requirements. The Committee's
meetings will be summarized in minutes that are
distributed to the City Council.
The City 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 City Manager and City Council to
ascertain whether investment activities during the reporting
period have deviated from the City'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 City's investments.
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E. Maturity aging by type of investments.
VI. REVIEW OF INVESTMENT MANAGEMENT
VII.
Policy Review
This investment policy shall be reviewed annually by the
City Council 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 City Council for consideration.
This policy was duly adopted by authority of the City
Council of the City of Azusa on the 24th day of October,
1988.
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• • EXl{I9I': A�j
PRUDENT MAN RULE
AAr",CIVIL CObL
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.Yp}�. .. •...-•r'.rr r.... ,-r+.. � .., . -.. 11 f i '
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.'Jett. • s\'CiiP.1 C''.L C.
2261. Unvestment of funds]
investing, reinvesting, purchasing, acquiring, exchanging, selling
;:. , .... and managing property for the benefit of another, a trusted shill
'exercise the judgment and care, under the circumstances then prevail-
-! ''" ing, which mea of prudence. discrerion and intelligence exercise in the
' �'''• • management of their dam affairs. not in regard to speculation, but it:
• ���'''- regard to the permanent disposition of their funds, considerin$ the
-probable income. as well as the probable satery of their upitaL
' Within the limitations of the foregoing stsndatd. and subject to any
' express provisiansor limitatiotu contained Ice any particular trust
instrsment, s trustee; is authorized to :cyuire every land of property,
real, personal or mixed, and every kind of investment, specifically
including, but not by way of limitation, corporate obligations of every
kind, and stock:, preferred or common, which men of prudence.
discretion and intelligence acquire for their own account.
(2) In the absence of express' provisions to the contrary in the trust
--
instrument, a trustee may continue to hold property rezetved 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 intelligtnce,
may consider that retention is in the best interests of the trust Such
property may include stock in the trusted, if a corporation, and stock
to any corporation controlling, controlled by, or under common
control with such trussta6
(3) In the absence of express provisions to the contrary is the trust
instrument, a deposit of trust funds at interest in any bank (ncluding
the trustm if a batik) shall be a qusMed investment to the extent "
that such deposit its insured under any present or future law of the
United States, or zo 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 aces to make deposits of
trust moneys in banks, subject, in the case of interest-bearing depasits.
to such notice or other conditions respecting withdrawal as may be
prescribed by law or governmental regulation affecting such deposits.
(4) Nothing in this section shall abrogate or restrict the power of the
Appropriate court in propa cases to direct or percent the trustee to
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de%iate from the teras of the trust regarding the making or
of investments _ .... retgtian
...... .•..._
(Sj 1'he provisions of dlis Wilton shall apply to all trusts now existing
r ' .:• or heresfter Created. Wbere, is trusts noa• existing or hereafter
crated, the term "investments permissible by Iaw for or
of
trust funds," or "authorized by law for investment of trust fund,,"
"legal investments," "authorized
a•.:,
or investments," or other words of
import
:-''r • Similar are used in defining the powers of the trustee relative
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to investments -'-such language, in the absen:.e of other controlling or
modifying
pro%isions of the trust instrument, sE&U be construed as
authorizing any i;nvestmeat permitted by the terms of subdivision (1)
_ of this section.
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(6) The term "property" as used in this section includes life insur-
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comp, endowment, and annuity Contracts issued by legal reserve
companies authorized to do business in this mate.
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EXHIBIT B
DESCRIPTION OF INVESTMENTS
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 City of Azusa the
best combination of safety, liquidity and high yield. Surplus
funds of local agencies may only be invested in certain eligible
securities. The City of Azusa 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 City 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 City 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 City's advantage to waive
this collateral requirement for the first $100,000 because the
City 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.
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The State keeps an amount for reasonable costs of making the
investments, not to exceed one-quarter of one percent of the
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 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, 7, 10 years. Notes are coupon
securities paying interest every six months. The City 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 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.
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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 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.
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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 City 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
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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 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 National 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 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