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time, when requested by the City, the City shall make no new investments <br /> with or through the fiduciary or third party and shall not renew maturing <br /> investments with or through the fiduciary or third party. <br /> 9.4 Prohibited Investment Practices <br /> Assets of the City shall not be invested pursuant to the following investment <br /> practices: <br /> • Trading of securities strictly for speculation or solely for the realization of <br /> short-term trading gains. <br /> • A contract providing for the compensation of an agent or fiduciary solely <br /> based upon the performance of the invested assets. <br /> • If a fiduciary or other third party with custody of public investment <br /> transaction records of the City fails to produce records within a reasonable <br /> time, when requested by the City, the City shall make no new investments <br /> with or through the fiduciary or third party and shall not renew maturing <br /> investments with or through the fiduciary or third party. <br /> 10.0 INVESTMENT POOLS/MUTUAL FUNDS <br /> Government sponsored investment pools (Local Agency Investment Fund (LAIF), County <br /> Pools, Joint Powers Authority Pools, and the State Treasury Voluntary Investment <br /> Program Fund), are sources for short-term cash management. <br /> Before seeking City Council approval for participation in one or more additional <br /> investment pools/money market mutual funds, the Executive Director for FMSA or his/her <br /> designees will conduct a thorough investigation the prospective pool prior to <br /> recommending City investment. <br /> Before recommending investing in a prospective pool, the following issues must be <br /> reviewed and considered: <br /> The pool must meet the requirements of state statue description of <br /> eligible investment securities, and a written statement of investment <br /> policy and objectives. <br /> A description of interest calculations and how it is distributed, and how <br /> gains and losses are treated. <br /> i. A description of how the securities are safeguarded (including the <br /> settlement processes), and how often the securities are priced and the <br /> program audited. <br /> ii. A description of who may invest in the program, size and frequency of <br /> minimum and maximum deposits, how many withdrawal transactions <br /> are allowed (daily, monthly, quarter, annually, etc.), and whether <br /> advance notice is required for withdrawal transactions. <br /> iii. A description of how and who in the governing body of the program is <br /> Ci1y of Santa-Annual page 14 Jul 1.2y 025—_ <br /> Statement of Investment Policy June 30,2026 <br /> Resolution No. 2025-019 <br /> Page 18 of 24 <br />