Lone Star Investment Pool Investment Policy

The purpose of this Investment Policy is to set forth the policies which are to be followed in managing and operating the Lone Star Investment Pool.

Overview

The purpose of this Investment Policy is to set forth the policies which are to be followed in managing and operating the Lone Star Investment Pool (the “Pool”). Policies presented in this document have been developed based on the advice and recommendations of consultants and professionals who serve the Pool. The Board of Trustees of the Pool (the “Board”) has approved these policies. All actions with respect to the Pool, including the establishment and implementation of this Investment Policy, shall be made solely for the interest of the Participants in the Pool. Capitalized terms used herein and not otherwise defined have the same meanings assigned to them in the Investment Agreement creating the Pool.

Identification of Pool

The investment objectives of the Pool, in order of priority, are preservation and safety of principal, liquidity, and yield.

The Pool is a public funds investment pool, designed to invest in certain fixed income securities, and is created under the Interlocal Cooperation Act, Chapter 791, Texas Government Code, and the Public Funds Investment Act, Chapter 2256, Texas Government Code (the “Investment Act”).

Investment Policy objective

The primary objective of this Investment Policy is to emphasize the importance of safety of principal and liquidity of Pool assets. The policy also addresses other key elements, including but not limited to investment diversification, maturity, quality and capability of investment management, and yield.

Communication objective

This document is intended to serve as a guide to improve communication between the Board and:

The Advisory Board;
The Investment Officer(s);
The Investment Advisor(s);
The Custodian;
The Administrator;
The Investment Consultant;
New Board members;
Current and potential Participants.

Investment strategy and guidelines

Pursuant to the Agreement and applicable law, the Pool’s investments are limited to those permitted under the Investment Act. Further restrictions on eligible investments for each of the Pool’s funds are set forth below.

Government Overnight Fund

The Government Overnight Fund is designed for funds that may be required for immediate expenditure. The objectives of the Government Overnight Fund are, in order of importance:

an understanding of the suitability of the investment to the financial requirements of the Government Overnight Fund;
preservation and safety of principal;
liquidity;
marketability of each investment if the need arises to liquidate the investment before maturity;
diversification of the investment portfolio;
and yield.

The Government Overnight Fund seeks to offer daily liquidity and to maintain a net asset value of one dollar. The net asset value of the Government Overnight Fund is determined daily to ensure that the market value of the Fund’s assets is maintained at one dollar. The dollar-weighted average maturity of the Government Overnight Fund is 60 days or fewer. The maximum stated maturity of each security acquired by the Government Overnight Fund is 13 months for fixed rate securities and 24 months for variable rate securities. Because of their short maturities, high quality, and minimal price fluctuations, securities in which the Government Overnight Fund invests are generally considered to be marketable and very liquid. Though the Government Overnight Fund may hold investments until they mature, it may periodically trade securities to take advantage of perceived disparities between markets for various categories of investments in an effort to increase returns. The Government Overnight Fund may not invest more than one-third of the value of its assets (determined as of the date of investment) in the securities of any single issuer, except for direct obligations of the U.S. Government.

Though the Pool has the authority to invest in all securities authorized under the Investment Act, it is the Board’s policy that only the following of such authorized investments will be eligible as Government Overnight Fund investments:

Obligations of the United States or its agencies and instrumentalities
Other obligations, the principal and interest of which are unconditionally guaranteed or insured by, or backed by the full faith and credit of, the United States or its agencies and instrumentalities
Fully collateralized repurchase agreements that meet the following criteria: (1) have a defined termination date; (2) are secured by obligations of the United States or its agencies and instrumentalities; (3) require the securities being purchased by the Government Overnight Fund to be pledged to the Government Overnight Fund, held in the Government Overnight Fund’s name, and deposited at the time the investment is made with the Government Overnight Fund or with a third party selected and approved by the Government Overnight Fund; and (4) are placed through a primary government securities dealer, as defined by the Federal Reserve, or a financial institution doing business in this state. The market value of repurchase agreement collateral is required to initially be 102 percent of the principal amount of such repurchase agreement. Thereafter, the market value of such collateral will be determined (marked-to-market) daily and reset to 102 percent of the principal amount if it falls below 100 percent.
The Government Overnight Fund may lend up to 25 percent of its securities pursuant to a reverse repurchase agreement authorized under the Investment Act. Any funds obtained pursuant to a reverse repurchase agreement must be invested in authorized Government Overnight Fund investments and match the term of the reverse repurchase agreement. The term of any reverse repurchase agreement may not exceed 90 days.
No-Load money market mutual funds regulated by the Securities and Exchange Commission (“SEC”), that invest exclusively in authorized Government Overnight Fund investments, provided the Government Overnight Fund shall not invest its funds in any one money market mutual fund in an amount that exceeds (i) 25 percent of the Government Overnight Fund’s total assets or (ii) 10 percent of the total assets of such money market mutual fund.

Corporate Overnight Fund

The Corporate Overnight Fund is designed for funds that may be required for immediate expenditure. The objectives of the Corporate Overnight Fund are, in order of importance:

an understanding of the suitability of the investment to the financial requirements of the Government Overnight Fund;
preservation and safety of principal;
liquidity;
marketability of each investment if the need arises to liquidate the investment before maturity;
diversification of the investment portfolio;
and yield.

The Corporate Overnight Fund seeks to offer daily liquidity and to maintain a net asset value of one dollar. The net asset value of the Corporate Overnight Fund is determined daily to ensure that the market value of the Fund’s assets is maintained at one dollar. The dollar-weighted average maturity of the Corporate Overnight Fund is 60 days or fewer. The maximum stated maturity of each security acquired by the Corporate Overnight Fund is 13 months for fixed rate securities and 24 months for variable rate securities. Because of their short maturities, high quality, and minimal price fluctuations, securities in which the Corporate Overnight Fund invests are generally considered to be marketable and very liquid. Though the Corporate Overnight Fund may hold investments until they mature, it may periodically trade securities to take advantage of perceived disparities between markets for various categories of investments in an effort to increase returns.

The Corporate Overnight Fund has the authority to invest in all securities authorized under the Investment Act. However, it is the Board’s policy to also have the following restrictions:

Except for money market mutual funds regulated by the SEC, the Corporate Overnight Fund shall not invest its assets in the securities of any one nongovernmental issuer in an amount that exceeds 5 percent of the Corporate Overnight Fund’s total assets at cost.
Fully collateralized repurchase agreements that meet the following criteria: (1) have a defined termination date; (2) are secured by obligations authorized under the Investment Act; (3) require the securities being purchased by the Corporate Overnight Fund to be pledged to the Corporate Overnight Fund, held in the Corporate Overnight Fund’s name, and deposited at the time the investment is made with the Corporate Overnight Fund or with a third party selected and approved by the Corporate Overnight Fund; and (4) are placed through a primary government securities dealer, as defined by the Federal Reserve, or a financial institution doing business in this state. The market value of repurchase agreement collateral is required to initially be 102 percent of the principal amount of such repurchase agreement. Thereafter, the market value of such collateral will be determined (marked-to-market) daily and reset to 102 percent of the principal amount if it falls below 100 percent.
If an A-1 or P-1 investment is placed on the watch list with negative implications by Standard & Poor’s or Moody’s Investor Services, the Investment Advisor must notify the Investment Consultant and Administrator that same day and if a ready market exists for that security, sell the investment within one week.
The Corporate Overnight Fund shall not invest its funds in any one money market mutual fund in an amount that exceeds (i) 25 percent of the Corporate Overnight Fund’s total assets or (ii) 10 percent of the total assets of such money market mutual fund.

Corporate Overnight Plus Fund

The Corporate Overnight Plus Fund is designed for funds that may be required for immediate expenditure. The objectives of the Corporate Overnight Fund are, in order of importance:

an understanding of the suitability of the investment to the financial requirements of the Government Overnight Fund;
preservation and safety of principal;
liquidity;
marketability of each investment if the need arises to liquidate the investment before maturity;
diversification of the investment portfolio;
and yield.

The Corporate Overnight Plus Fund has longer maturities than those of the Corporate Overnight Fund and Government Overnight Fund. The Corporate Overnight Plus Fund seeks to offer daily liquidity and to maintain a net asset value of one dollar. The net asset value of the Corporate Overnight Plus Fund will be determined daily to ensure that the fair value of the fund’s assets is maintained at one dollar. The dollar-weighted average maturity of the Corporate Overnight Plus Fund is 120 days or fewer. The maximum stated maturity of each security acquired by the Corporate Overnight Plus Fund is two years from date of purchase unless otherwise restricted by the Investment Act. Because of their short maturities, high quality, and minimal price fluctuations, securities in which the Corporate Overnight Plus Fund invests are generally considered to be marketable and very liquid. Though the Corporate Overnight Plus Fund may hold investments until they mature, it may periodically trade securities to take advantage of perceived disparities between markets for various categories of investments in an effort to increase returns.

The Corporate Overnight Plus Fund has the authority to invest in all securities authorized under the Investment Act. However, it is the Board’s policy to also have the following restrictions:

Except for money market mutual funds regulated by the SEC, the Corporate Overnight Plus Fund shall not invest its assets in the securities of any one nongovernmental issuer in an amount that exceeds 5 percent of the Corporate Overnight Plus Fund’s total assets at cost.
Fully collateralized repurchase agreements that meet the following criteria: (1) have a defined termination date; (2) are secured by obligations authorized under the Investment Act; (3) require the securities being purchased by the Corporate Overnight Plus Fund to be pledged to the Corporate Overnight Plus Fund, held in the Corporate Overnight Plus Fund’s name, and deposited at the time the investment is made with the Corporate Overnight Plus Fund or with a third party selected and approved by the Corporate Overnight Plus Fund; and (4) are placed through a primary government securities dealer, as defined by the Federal Reserve, or a financial institution doing business in this state. The market value of repurchase agreement collateral is required to initially be 102 percent of the principal amount of such repurchase agreement. Thereafter, the market value of such collateral will be determined (marked-to-market) daily and reset to 102 percent of the principal amount if it falls below 100 percent.
If an A-1 or P-1 investment is placed on the watch list with negative implications by Standard & Poor’s or Moody’s Investor Services, the Investment Advisor must notify the Investment Consultant and Administrator that same day, and if a ready market exists for that security, sell the investment within one week.
The Corporate Overnight Plus Fund shall not invest its funds in any one money market mutual fund in an amount that exceeds (i) 25 percent of the Corporate Overnight Plus Fund’s total assets or (ii) 10 percent of the total assets of such money market mutual fund.

Pool administration

The Board has appointed Investment Officers and entered into a service agreement with the Administrator. The respective authority and responsibilities of the Board, the Investment Officers, and the Administrator are listed below. It should be noted that some of these responsibilities may overlap, and further that the Investment Officers and the Administrator shall at all times be subject to the Board’s direction.

Authority and responsibilities of the Board

Adopt this Investment Policy.
Appoint one or more Investment Officers.
Oversee selection of Investment Advisor, Custodian, Investment Consultant, and other service providers.
Monitor compliance with this Investment Policy, the Investment Act, and other law governing the Pool.
Monitor performance of the Pool.
Consider revisions to this Investment Policy to reflect changing conditions affecting the Pool or the needs of the Participants.

Authority and responsibilities of the Investment Officers

Invest or oversee the investment of Pool assets.
Execute contracts on behalf of the Pool, including contracts with the Investment Advisor and other service providers.
Oversee the daily operations of the Pool.
Monitor performance of the Pool.
Monitor the selection and performance of the Investment Advisor and other service providers.
Monitor compliance with this Investment Policy, the Investment Act, and other law governing the Pool.
Report at least quarterly to the Board.
Obtain training required under the Investment Act and report training status to the Board not less than annually.

Authority and responsibilities of the Administrator

Conduct search for and negotiate contracts with Investment Advisor, Custodian, Investment Consultant, and other service providers, subject to the direction and oversight of the Board and Investment Officers.
Market program to Local Governments.
Service Participants on an ongoing basis.
Meet monthly with Investment Officers and Investment Consultant to review Pool performance.
Monitor compliance with this Investment Policy, the Investment Act, and other law governing the Pool.
Report at least quarterly to the Board.
Prepare and distribute the Information Statement.

Additional guidelines and restrictions

Standard of care

Investments of Pool assets shall be made with judgment and care, under circumstances then prevailing, that persons of prudence, discretion, and intelligence exercise in the management of their own affairs, not for speculation, but for investment, considering the probable safety of their capital as well as the probable income to be derived.

Liquidity needs

The liquidity needs of the Pool shall be determined from its operating history and with a general awareness of the needs of Participants. The Pool’s investments and operations shall be managed consistently with such liquidity needs.

Cash holdings

For liquidity purposes or to respond to unusual market conditions, the Pool may hold some or all of its total assets in cash as a temporary defensive measure, for purposes of assuring sufficient liquidity, or due to the lack of eligible investment securities.

Operational guidelines

Each fund within the Pool is designed and shall be managed to ensure it is continuously rated no lower than AAA or AAA-m or at an equivalent rating by at least one nationally recognized rating service.
Each fund within the Pool will be marked-to-market daily.
The Custodian may register or transfer assets of the Pool into its own name or the name of one or more nominees, provided its books and records at all times show that such assets are part of the Pool.
Total administrative and operating expenses of the Pool are not to exceed 0.06 percent per year based on the daily average assets.
The Investment Officers may prepare and transmit additional written guidelines and expectations for the Pool or for any Fund within the Pool, provided they do not exceed the parameters set forth in this Investment Policy. The Investment Officers will provide a copy of any such transmission to the Board at its next Board meeting.
If the Corporate Overnight Fund or the Government Overnight Fund’s amortized cost is above or below the market value by more than one-half of one percent, the Investment Officer will take such action as the Investment Officer deems appropriate to eliminate or reduce to the extent reasonably practicable any dilution or unfair result to existing participants, including a sale of portfolio holdings to attempt to maintain the ratio between 0.995 and 1.005.
If the Corporate Overnight Plus Fund’s book value of units outstanding is above or below market value by more than one-half of 1 percent, the Investment Officer will take such action as the Investment Officer deems appropriate to eliminate or reduce to the extent reasonably practicable any dilution or unfair result to existing participants, including a sale of portfolio holdings to attempt to maintain the ratio between 0.995 and 1.005.
If the Weighted Average Maturity (“WAM”) of the Corporate Overnight Plus Fund exceeds 90 days, the Investment Advisor must file a report with the Investment Consultant and Administrator detailing why they have the fund positioned beyond 90 days. The report is due the Monday following any week in which the fund’s WAM exceeded 90 days.
The Corporate Overnight Plus Fund will be evaluated on a “total rate of return” basis for the purpose of this Investment Policy; “total rate of return” is defined as interest plus appreciation or depreciation of market value.
The Investment Advisor(s) shall monitor rating changes in investments acquired by the Pool and shall take all prudent measures that are consistent with this Investment Policy to liquidate an investment that no longer has the minimum rating required under the Investment Act.
In connection with Chapter 2270 of the Texas Government Code (“Chapter 2270”), the Investment Advisor(s) shall monitor the list of scrutinized companies maintained by the Texas Comptroller of Public Accounts, shall take all prudent measures to avoid investing in scrutinized companies, and shall divest from scrutinized companies in accordance with Chapter 2270. When applicable, the Administrator will facilitate all required notifications pursuant to Chapter 2270.

Securities transactions

All securities transactions are required to be affected through licensed broker-dealer firms, in accordance with all applicable laws and selected on the basis of reasonableness of brokerage commissions and provision of other services, if any, to the Pool. A detailed list shall be maintained showing all commissions paid by the Pool and the identity of and amount paid to each broker-dealer firm executing orders for the Pool.

The Investment Advisor shall not order the purchase of investments in mutual funds, or other similar pooled investment vehicles, that are managed by the Investment Advisor or affiliates of the Investment Advisor.

Evaluation and review

Frequency of meetings and reports

The Administrator, Investment Officers, and Investment Consultant will meet at least monthly to review the market, the Pool’s investment portfolio, and other issues related to the Pool. The Investment Officers and the Administrator will provide a written investment report to the Board at least quarterly.

Quality and capability of investment management

The Pool and the Investment Advisor shall be carefully monitored on the basis of several key indicators to ensure a consistent and high quality investment approach is being followed. Such indicators include:

Changes in the Advisor personnel, ownership or fees;
Compliance with investment guidelines included in this Investment Policy;
Advisor’s current investment outlook for the next six to 12 months and policy developed in response to such outlook;
Consistency of Pool’s performance with the Advisor’s investment style;
Consistency of Pool’s performance with the Advisor’s style peer group. See “Performance Goals.”

Performance goals

Although the primary emphasis of this Investment Policy is safety of principal and liquidity, the Board expects the Pool to perform credibly within a peer group of other funds or pools with similar investment structures. The performance of each fund may vary. The following standards, established as benchmarks only, will apply:

Government Overnight Fund

The Government Overnight Fund should outperform the 91-day U.S. Treasury Bill.
The Government Overnight Fund’s return should be in the upper one-half of comparably managed funds selected by the Investment Consultant.

Corporate Overnight Fund

The Corporate Overnight Fund should outperform the 91-day U.S. Treasury Bill. The Corporate Overnight Fund’s return should be in the upper one-half of comparably managed funds selected by the Investment Consultant.

Corporate Overnight Plus Fund

The Corporate Overnight Plus Fund should outperform the 91-day U.S. Treasury Bill.
The Corporate Overnight Plus Fund’s return should be in the upper one-half of comparably managed funds selected by the Investment Consultant.
If the dollar-weighted average maturity of the Corporate Overnight Plus Fund is greater than 60 days for the period, the Corporate Overnight Plus Fund should outperform the Corporate Overnight Fund.

Policy review and amendment

The Investment Officers and the Administrator will use each of their quarterly investment performance evaluations as an opportunity to also consider recommending whether any elements of the existing Investment Policy should be modified.

The Board and Advisory Board shall review this Investment Policy and investment strategies not less than annually. Possible reasons for policy modification include, but are not limited to, the following:

A rationale for change presented by the Investment Consultant or other industry specialist that has merit
New areas found to be important that are not covered in this Investment Policy
Impractical time horizon for the Pool’s portfolio

The Board considers this Investment Policy to be a basic tool for the implementation of a long-range investment program for Participants but also as a dynamic document that is responsive to the need for any fundamental changes. The Board recognizes that a potentially damaging inconsistency would occur if policies were to undergo substantial change over relatively short periods, or if policy changes were implemented as a “reaction” to current short-term market conditions.

Adopted: 7/18/2019 / Effective 9/1/2019
LoneStar-703, Investment Policy