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HomeMy WebLinkAboutFCS-12-189 - Investment Policy UpdateStaff Re~p~r~ I~~rc~~nT~~ Finance and Corporate Services 1~eparfinent REPORT TO: DATE OF MEETING: SUBMITTED BY: PREPARED BY: WARD(S) INVOLVED: DATE OF REPORT: REPORT NO.: SUBJECT: RECOMMENDATION: Finance and Corporate Services Committee November 26th, 2012 Ryan Hagey, Director of Financial Planning Alicia Italiano, Senior Financial Analyst All November 13th, 2012 FCS-12-189 Investment Policy Update www.kitchenerca THAT the City investment policy, attached as appendix Appendix A to staff report FCS-12-189, be approved as amended. BACKGROUND: The City of Kitchener Investment Policy is governed by the Municipal Act and its regulations, and was last updated in April of 2008. The goal of the City Investment Policy is to set out the guiding principles for the purpose of investing public funds. The policy applies to all financial assets of the City of Kitchener including Operating, Capital, Reserve, Trust and Enterprise Funds. The primary objective of the policy is the preservation of capital therefore; the types of investments held are very low risk alternatives such as Guaranteed Investment Certificates (GIC's), Money Market funds and Bonds. This objective is accomplished through diversification as the policy has limits by sector as well as individual issuer to minimize potential losses on individual securities. In addition, the securities must meet minimum credit rating criteria thereby restricting investments to high quality instruments. The investment portfolio is designed to attain the maximum rate of return while meeting the above objective and adhering to all statutory requirements. The policy also governs the quality of securities the City can accept from others, for example, Letters of Credit. The income resulting from the investment of City funds is one of the revenue sources available to reduce the burden on the taxpayers. The proposed amendments have been recommended to permit greater flexibility within the investment portfolio and improve returns, while maintaining policy goals. 5-1 REPORT: From time to time it is necessary to recommend amendments to the investment policy in order to react to market conditions, changes in legislation or operational needs and requirements. The purpose of this report is to make three minor updates to certain sections in the current investment policy and is not a comprehensive policy review. For easier reference, updated policy sections are highlighted below and in the revised policy, the changes are in bold, italic type. The remainder of the report summarizes the proposed updates. Update 1: Increase Holdings for Schedule 1 Banks in the Lon_g-Term Portfolio Policy Section: Schedule D In the long term investment portfolio, Schedule I banks (domestic banks or banks that are not a subsidiary of a foreign bank) are limited to 40% of the portfolio, with no more than 15% in any single Schedule I bank. The current low interest rate environment has limited the City's investment opportunities over the past few years. Staff have reviewed the current policy and one area that could result in yield improvements is to increase the City's investment in Schedule I banks. Schedule I bank bonds offer better returns than government bonds, and are still very secure investments. Although there is an increase in portfolio risk with purchasing bank bonds instead of government bonds, Schedule I bank debt generally has a very strong credit rating. It should be noted that The Municipal Act requires municipalities to sell bank bonds if their rating falls below AA(low), and that bank debt can only be purchased if it is rated AA(low) or higher, thus limiting portfolio risk. The chart below shows the difference in yields between government bonds and financial institution bonds for the last three full years and 2012 to date. Type 2012* 2011 2010 2009 GOVERNMENT 1.66 1.69 2.64 2.87 FINANCIAL 2.64 3.155 3.595 3.725 Spread 1.0 1.5 1.0 0.9 * Up to September *Notes on chart calculations: • Average yields are according to the DEX Bond Market Index • Typical term of investments in the long term portfolio range from two to ten years. o Chart averages assume an equal weighting using the DEX Short Term Bond Index (1-5 years) and the DEX Mid Term Bond Index (5-10 years). A survey of other local municipalities revealed the following Schedule I bank limits: • City of Cambridge - no limits or restrictions: 100% can be invested in Schedule I Banks • City of Waterloo -100% can be invested in Schedule I Banks • Region of Waterloo - 35% limit on Schedule I Banks • City of Guelph - 75% limit on Schedule I Banks in the long term portfolio and 90% in the short term portfolio Given this information and that the Canadian banking system is among the strongest in the world, staff recommend the long term portfolio maximums be amended to increase the holdings in Schedule I banks from 40% to 75%. A limit of 75% is within the mid-range in the region and matches the City of Guelph. The portfolio requirement that no more than 15% be held in any single bank would be unchanged. Increasing the percentage of the portfolio that can be held in Schedule I banks gives increased investment income potential with minimal risk. 5-2 Update 2: Adjust Pooled Fund Description in Schedule C and Schedule D Policy Section: Schedule C and D Section 420 of The Municipal Act allows municipalities to purchase investments through the "ONE Fund". The ONE Fund is a municipal pooled investment program established in 1993 and is operated jointly by Association of Municipalities of Ontario (AMO) and Municipal Finance Officers' Association of Ontario (MFOA). The ONE Fund is designed for the municipal sector and provides Ontario municipalities with access to a range of investment options unavailable to them directly. The ONE Fund currently has four different fund types: • Money Market Fund • Bond Fund • Universe Corporate Bond Fund • Equity Fund The offerings available through the ONE Fund continue to change over time. The Equity Fund was introduced in 2007 and the Universe Corporate Bond Fund was introduced in 2008 (after the last policy update). The wording in Schedules C and D of the City's current policy speaks to specific components of the ONE FUND (e.g. Eligible Money Market Investment Pools and Eligible Pooled Equity Investment Funds). The proposed change would adjust the wording on both schedules to read "Eligible Pooled Investment Funds". This will allow the policy to stay current with any changes or new investment opportunities offered by the ONE Fund program. The purpose of the recommended wording change is so the City has access to all available investments allowed under legislation. Whether or not the City chooses to use some, all, or none of these investment funds will be based on opportunities that best meet the City's needs. Although the current policy does allow for investment through the ONE Fund, it is subject to the rules laid out in section 4 b) regarding Investment Pools. This section speaks to the due diligence that is required before investing in the ONE Fund, which includes a Council approved by-law. Update 3: Eligibility of Credit Union Letters of Credit Policy Section: 11 (a) (ii) The City of Kitchener often requires Letters of Credit as security for Subdivision and Development Servicing. The investment policy requires that issuers of letters of credit have a superior credit rating to ensure that the City has access to funds in the event the contractual obligations to the City are not fulfilled. Recently, the City has received several inquiries from developers wanting to use Credit Unions to provide Letters of Credit. The City has been unable to accept these Letters of Credit due to the wording of the current policy, as individual Credit Unions are not rated. However, most individual credit unions are members of the Central 1 Credit Union which is rated R-1 (middle), a high quality credit rating per the Dominion Bond Rating Service (DBRS). According to their website www.dbrs.com "the rating assessment reflects the strength of both Central and the underlying credit union members". The last time the City's investment policy was updated in 2008 the rating was only R-1 (low), which did not meet the minimum risk threshold. 5-3 Staff is aware that recently the City of Waterloo made updates to its Letter of Credit Policy to deal with this issue and are recommending adopting the standards approved by the City of Waterloo. This would allow the City of Kitchener to accept Letters of Credit from those Credit Unions that are members of Central 1 Credit Union provided that: • The Credit Union is verified as a member of Central 1 Credit Union • The Central 1 Credit Union (rated R-1 (middle) maintains or improves on their rating) • The Credit Union has its Head Office in Ontario • The Letter of Credit does not exceed $100,000 The $100,000 limit is consistent with the City of Waterloo and will limit the City's risk exposure to individually unrated entities. ALIGNMENT WITH CITY OF KITCHENER STRATEGIC PLAN: Foundation: Efficient and Effective Government Goal: Financial Management Strategic Direction: Ensure responsible stewardship of public funds within a supportive policy framework FINANCIAL IMPLICATIONS: There are no immediate financial implications of the changes recommended in this report, however they would increase the City's flexibility with respect to investment choices. Over time, this could result in improved investment yields. Credit Unions continue to experience membership increases, as more people and businesses choose Credit Unions as their Financial Institution. Historically, Credit Unions have been considered less stable than banks, and therefore a higher risk. Although the City has experienced an increase in the number of requests from Credit Unions to provide Letters of Credit, the volume is minimal in proportion to the overall volume of requests. Given the recommended limit of $100,000, staff believe the additional risk is manageable and still aligns with the City's overall policy objective. ATTACHMENTS: Appendix A -Investment Policy COMMUNITY ENGAGEMENT: Not applicable. ACKNOWLEDGED BY: Dan Chapman, Deputy CAO (Finance and Corporate Services) 5-4 POLICY NUMBER: I-605 POLICY TYPE: FINANCIAL SUBJECT: INVESTMENT POLICY DATE: AUGUST 30, 2004 Amended: APRIL 7, 2008 1 2 3. POLICY CONTENT It is the policy of the City of Kitchener to invest public funds in a manner that will provide the highest investment return while protecting and preserving capital, maintaining liquidity, meeting the daily cash flow demands of the City and conforming to all legislation governing the investment of public funds. SCOPE The investment policy applies to all financial assets of the City of Kitchener held within the following: (a) General Fund (b) Capital Fund (c) Reserve Funds (d) Enterprise Funds (e) Trust Funds OBJECTIVES The primary objectives, in order of priority, of the City's investment activities shall be: (a) Adherence to statutory requirements Investment activity will be governed by the Municipal Act as amended. Investments will be limited to investments eligible under the Act and related subsequent provincial regulations. 5-5 3. OBJECTIVES, CONT'D (b) Preservation of capital Safety of principal is a key objective of the investment program. Investments of the City shall be undertaken in a manner that seeks to ensure the preservation of capital in the overall portfolio. This is accomplished as follows: (i) Credit Risk: Credit Ratings All long-term non-government investments will be in securities of borrowers with a minimum DBRS rating of AA(low) (or its equivalent rating if unavailable). Schedule A contains the equivalent ratings. All short- term investments will be in securities with a minimum DBRS rating of R-1 (middle) (or its equivalent rating if unavailable). Schedule B contains the equivalent ratings. 2. Diversification Investments must adhere to sector and individual issuer limitations established under Schedule C to minimize potential losses on individual securities. (ii) Interest Rate Risk The following measures will minimize the risk associated with fluctuating interest rates: • Structure portfolio so securities mature to meet ongoing cash requirements to reduce the need to sell securities on the open market prior to maturity • Primarily invest operating funds in shorter-term securities or investment pools • Diversifying longer-term holdings to match term exposures to requirements of underlying funds and to mitigate effects of interest rate volatility 5-6 3. OBJECTIVES, CONT'D (c) Liquidity The City's investment portfolio will remain sufficiently liquid to enable the City to meet all operating and capital requirements that might be reasonably anticipated and to limit temporary borrowing requirements. Where possible, securities are selected to mature concurrent with projected cash demands. As these cannot be fully anticipated, the portfolio shall consist largely of securities with an active secondary or resale market. (d) Return on Investments The investment portfolio shall be designed to attain the maximum rate of return while meeting the above three objectives. 4. ELIGIBLE INVESTMENTS The City of Kitchener may invest in securities expressed and payable in Canadian dollars issued or guaranteed by issuers identified in Schedule E and Schedule F subject to the restrictions, limitations and terms in Schedule C and Schedule D. (a) Forward Rate Agreements A Forward Rate Agreement is an agreement to make an investment on a future date in a security in order to minimize the cost or risk associated with the investment because of fluctuations in interest rates. The agreement fixes the interest rate that will be paid on an investment at a future date when know cash inflows such as tax payments will be received. The agreement is subject to the conditions set out below: (i) Conditions • The Agreement is made with a bank listed as Schedule I, II or III in the Bank Act (Canada) whose long-term debt obligations have a minimum DBRS rating of "A (high)" or its equivalent. 5-7 4. ELIGIBLE INVESTMENTS, CONT'D (a) Forward Rate Agreements, cont'd (i) Conditions, cont'd Agreement shall specify the forward amount, settlement day, forward rate of interest, and reference rate of interest, and shall require a settlement payment on settlement rate if the forward and reference rate of interest are different. 2. All forward amounts under other forward rate agreements shall not exceed the total amount of the principal of the investment. 3. Settlement day is within 12 months of the day on which the agreement is executed. 4. Settlement shall not exceed the difference between the amount of interest that would be payable on the forward amount calculated at the forward rate of interest and the amount that would be payable calculated at the reference rate of interest. (ii) Use of Forward Rates By the City The City may enter into Forward Rate Agreements (FRA) to reduce the risk of future interest rate changes associated with known cash inflows. A report analyzing the risks and return profile of the transaction, the risk exposure to the City without the FRA and specific risk control measures must be approved by the Treasurer prior to entering into a FRA agreement. The FRA may only be executed with Schedule I, II or III Banks whose minimum DBRS rating is AA(low) (or its equivalent if unavailable). The term of any FRA must be less than 12 months and comply with the issuer limits in Schedule C. The FRA must specify the forward amount, settlement date, forward interest rate, reference rate of interest and schedule of approximate payments/costs to or by the City should the reference and forward rate differ. 5-8 (b) Investment Pools Council must approve a by-law which authorizes the City of Kitchener to enter into an Agency Agreement for the purpose of participation in joint municipal investment funds. Unrated municipalities are only permitted to invest in the following securities if made through the ONE Fund: commercial paper, corporate debt and shares, and asset-backed securities. A thorough investigation of the pool/fund is required prior to Council approval and on a continual basis. Investigation should include the following: (i) a written statement of investment policies and objectives (ii) a description of eligible investments (iii) a description of who may invest in the program, how often, what size deposit and withdrawal are allowed (iv) a description of how earnings are allocated and distributed (v) a description of how investments are safeguarded and how often the investments are priced and the program audited (vi) a schedule for receiving statements and portfolio listings (vii) a fee schedule, and when and how it is assessed 5. DIVERSIFICATION The City of Kitchener will diversify its investments by security type and institution according to Schedules C and D. These restrictions apply at the time an investment is made. At specific times, portfolio limitations may be exceeded as a result of timing of individual instrument maturities. 6. SAFEKEEPING AND CUSTODY Investments are held in safekeeping either in the City's safety deposit box or by the vendor financial institution. 5-9 7. TERM OF INVESTMENTS To the extent possible, the City will attempt to match its investments with anticipated cash flow requirements. Unless matched to a specific cash flow, the City will not directly invest in securities maturing more than 365 days from the date of purchase. Reserve and Trust Funds may be invested in securities exceeding 365 days if the maturity of such investments is made to coincide as nearly as possible with the expected use of the funds. 8. PERFORMANCE STANDARDS The investment portfolio shall be designed with the objective of obtaining a rate of return throughout budgetary and economic cycles commensurate with the investment risk constraints and the cash flow needs. (a) Yields Yields on the short-term portfolio-contains securities with a term to maturity of 1 year or less on the purchase date--should be higher than the rate given by the City's bank for the City's general bank account. Bond indices used as long-term benchmarks calculate returns based on prevailing market values. As the accounting system maintains only historical cost data, the City's calculated returns are derived from the purchase cost. Since the comparison of cost based returns to market returns is not meaningful, there is no benchmark for the long-term portfolio. 9. STANDARD OF CARE (a) Prudence Investments shall be made with judgment and care under circumstances then prevailing, which 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. Investment officers and employees exercising due diligence and acting in accordance with written procedures and this Policy shall be relieved of personal responsibility for an individual security's credit risks or market price changes, provided deviations from expectations are reported in a timely fashion and the liquidation or 5-10 9. STANDARD OF CARE, CONT'D (a) Prudence, cont'd the sale of securities are carried out in accordance with the terms of the Policy. (b) Ethics and Conflicts of Interest Officers and employees involved in the investment process shall refrain from personal business activity that could conflict with the proper execution and management of the investment program, or that could impair their ability to make impartial decisions. Employees and investment officials shall disclose any material interests in financial institutions with which they conduct business. They shall further disclose any personal financial/investment positions that could be related to the performance of the investment portfolio. Officers and employees shall not undertake personal transactions with the same individuals with whom business is conducted on behalf of the Corporation. (c) Internal Control The Treasurer shall ensure adequate internal controls over investment policies and procedures. The Treasurer shall establish a process of independent review by an internal or external auditor. (d) Delegation of Authority The investment policy and any amendments must be adopted by City Council. The City Treasurer will have overall responsibility for the prudent investment of the Corporation's portfolio which complies with this policy, pursuant to the requirements of the Municipal Act. The Director of Financial Planning will be responsible for and have the authority for the implementation of the investment program and the establishment of written investment procedures to provide for the effective control and management of investments. These procedures require explicit delegation of authority to persons responsible for investment transactions. No person may engage in an investment transaction except as provided under the terms of this policy and the procedures established by the Director of Financial Planning. 5-11 9. STANDARD OF CARE, CONT'D (e) Reporting The Treasurer shall provide an investment report to Council at least twice per year. The investment report should include: (i) statement by Treasurer whether all investments made in accordance with policy, (ii) amount and percentage of portfolio represented by each authorized investment category, (iii) monthly short term investment balances, (iv) long term investment balances, (v) earned rates, (vi) proportion of total investments invested in the City's own long and short term securities, (vi) statement of all transactions involving purchase and sale of City's own securities, if any. 10. AUTHORIZED INVESTMENT DEALERS Authorized investment dealers must be registered as Investment Dealers with the Ontario Securities Commission and members of the Investment Dealers Association of Canada, and approved by the Treasurer. 11. SECURITIES FOR SUBDIVISION AND DEVELOPMENT SERVICING This policy relating to securities required for Subdivision and Development Servicing has been designed to provide adequate protection to the City of Kitchener and to be fair and reasonable to developers and other interested parties. The objective of the securities policy is to ensure that monies to guarantee the installation of services will be available to the City when required. 5-12 11 SECURITIES FOR SUBDIVISION AND DEVELOPMENT SERVICING, CONT'D (a) Permitted securities The City of Kitchener shall accept only the following approved securities: (i) Letter of Credit (in prescribed form acceptable to the City Solicitor) issued by a Schedule I bank, Schedule II bank, Schedule III bank or Trust Company with a DBRS rating of R-1 (middle or high) or AAA , AA (low , middle or high) (or its equivalent if unavailable). (ii) Letter of Credit (in prescribed form acceptable to the City Solicitor) issued by a Credit Union provided that: i. The Credit Union is verified as a member of the Central 1 Credit Union ii. The Central 1 Credit Union (rated R-1 (middle) maintains or improves on their rating) iii. The Credit Union has its Head Office in Ontario iv. The Letter of Credit does not exceed $100,000 12 ri n~~ARv Asset-backed Short or long term debt instruments, which are backed by Securities: high quality assets (such as loans or mortgages) of the issuer, issued under Reg. 733 (50) (1) of the Loans and Trust Corporations Act Commercial Short term notes or drafts issued by a corporation, Paper: incorporated under the laws of Canada or a province of Canada Credit Risk: Risk to an investor that the issuer of an investment will default interest or principal payments Credit Union: Community based financial co-operatives owned and controlled by members Diversification: Process of investing in a range of security types by class, sector, maturity, and quality rating DBRS: Dominion Bond Rating Service is a service that assesses the credit rating of institutions 5-13 12. GLOSSARY, CONT'D Forward Rate Contract with a qualified financial institution allowing an Agreement investor to fix the interest rate to be received on an (FRA): investment for a specified term beginning at an agreed to future date Interest rate Risk of an increase or decrease in the value of a fixed- risk: income security caused by declining or rising interest rates Long-term investment: Investment whose term to maturity is greater than one year Liquidity: Measure of asset's convertibility into cash ONE Fund- Pooled investment fund meeting the eligibility criteria defined Public Sector by the regulations under the Municipal Act. It is operated by Group of the Local Authorities Service Limited and CHUMS Financing Funds: Corporation Schedule I A chartered bank operating under the Bank Act. The voting Bank: shares must be widely held with no investor holding more than 10% and foreign ownership limited to 25% Schedule II A chartered bank operating under the Bank Act. Schedule II Bank: banks may be wholly owned by non-residents Schedule III A foreign bank branch of foreign institutions operating under Bank: the Bank Act under certain restrictions Short-term Investment whose term to maturity is one year or less investment: Supranational An agency sponsored by highly rated foreign bank(s) or Institution: governments issuing debt to fund loans in developing countries for large infrastructure projects. Supranational institutions may be owned or guaranteed by a consortium of national governments Trust Financial institution which acts as a fiduciary, trustee or Company: agent in the administration of trust funds, estates and custodial arrangements 5-14 SCHEDULE A: LONG-TERM CREDIT RATINGS The following chart compares the different scales for long-term securities used by four rating agencies recognized in Ontario Regulation 438/97. Credit Quality DBRS S&P Moody's Fitch Superior: extremely strong capacity to AAA AAA Aaa AAA repay principal and interest AA(high) AA+ Aa1 AA+ AA AA Aa2 AA AA(low) AA- Aa3 AA- Good: strong capacity to repay A(high) A+ Al A+ principal and interest A A A2 A Allow) A- A3 A- SCHEDULE B: SHORT-TERM CREDIT RATINGS The following chart compares the different scales for short-term securities used by four rating agencies recognized in Ontario Regulation 438/97. Credit Quality DBRS S&P Fitch Superior: extremely strong capacity to R-1 (high) A-1 + F-1 + repay principal and interest R-1(middle) Good: strong capacity to repay principal R-1 (low) A-1 F-1 and interest 5-15 SCHEDULE C: INVESTMENT POLICY SUMMARY-- SHORT TERM PORTFOLIO Sector Government of Canada Provinces Municipalities Schedule I banks Maximum Credit Rating Portfolio Share Limit 100% R-1 middle, high R-1 middle, high R-1 middle, high Schedule II banks R-1 middle, and Schedule III high banks Credit Unions and R-1 middle, Trust Companies high Eligible Pooled Investment Funds 100% 25%/issuer 20% 10%/issuer 100% For top 5 major chartered banks: 25%/issuer Other Schedule I banks: 20%/issuer 30% HSBC Canada: 20%/issuer Other Schedule II and III banks: 10%/issuer 20% 10%/issuer 100% 5-16 SCHEDULE D: INVESTMENT POLICY SUMMARY-- LONG TERM PORTFOLIO Maximum Sector DBRS Credit Rating Portfolio Limit Share Government of Canada 100% Governments of other AAA 10% 5%/issuer Countries and Supranationals Provincial AAA 50% 25%/issuer AA(high), AA, AA(low) 25%/issuer A(high), A, Allow) 10%/issuer Municipal Region of Waterloo 35% Other municipalities 25% 10%/issuer Including Infrastructure Ontario (10), Municipal Finance Authority of British Columbia (BCMFA), boards and Conservation authorities College, University, AAA 10% 5%/issuer Housing Corp. & Hospital AA(high), AA, AA(low) Municipal Total 35% Debt in Incorporated 100% Total issued Municipal Electrical to City at Utilities incorporation 5-17 SCHEDULE D: INVESTMENT POLICY SUMMARY-- LONG TERM PORTFOLIO (CONT'D) Maximum Sector DBRS Credit Rating Portfolio Limit Share Financial Schedule Ibanks--top 5 major chartered banks AAA 75% AA(high), AA, AA(low) AAA 10% AA(high), AA, AA(low) 15%/issuer Other Schedule I, Schedule II and Schedule III Banks, Loans and Trust Companies, Credit Unions Financial Total Eligible Pooled Investment Funds 75% 10% 5%/issuer 5-18 SCHEDULE E: SUMMARY OF ELIGIBLE DEBT INVESTMENTS AND CONDITIONS Bonds, Debentures, Promissory Notes or Other Evidences of Indebtedness Issuer Conditions Canada or province or territory of Canada gency of Canada or a province or territory of Canada Country other than Canada Minimum DBRS rating of "AA(low)" or its equivalent When an investment falls below this standard, the municipality shall sell the investment within 90 days Municipality in Canada School board or similar entity in Canada Money raised is to be used for school purposes. Local board as defined in the Municipal Affairs ct (not including a school board or a municipality) Conservation authority established under the Conservation Authorities Act Municipal Finance Authority of British Columbia Ontario Infrastructure Projects Corporation (10) Post-secondary education institution as Minimum DBRS rating of "AA(low)" or its defined in s. 3 of the Post-Secondary Choice equivalent and Excellence Act, 2000 or Board of When an investment falls below this Governors of college of applied arts and standard, the municipality shall sell the technology investment within 90 days Board of a Public Hospital within the meaning Minimum DBRS rating of "AA(low)" or its of the Public Hospitals Act equivalent When an investment falls below this standard, the municipality shall sell the investment within 90 days Non-profit housing corporation as defined in s. Minimum DBRS rating of "AA(low)" or its 13 of Housing Development Actor local equivalent housing Corporation as defined in s. 2 of When an investment falls below this Social Housing Reform Act, 2000 standard, the municipality shall sell the investment within 90 days Bank Defined As Schedule I, II or III by the Minimum DBRS rating of "AA(low)" or its Bank Act equivalent Loan Corporation or Trust Company, Credit Minimum DBRS rating of "AA(low)" or its Union or League, Province of Ontario Savings equivalent Office 5-19 SCHEDULE E: SUMMARY OF ELIGIBLE DEBT INVESTMENTS AND CONDITIONS (CONT'D) Bonds, Debentures, Promissory Notes or Other Evidences of Indebtedness Issuer Conditions International Bank for Reconstruction and Development (IBRD) Supranational financial institution or Minimum DBRS rating of "AAA" or its government organization other than equivalent International Bank for Reconstruction and When an investment falls below this Development (IBRD) standard, the municipality shall sell the investment within 90 days sset-backed securities made under Loan Unrated Municipalities shall invest through and Trust Corporations Act the ONE Fund Corporation incorporated under the laws of Unrated Municipalities shall invest through Canada or a province of Canada the ONE Fund Corporation incorporated under section 142 s long as it is held, it ranks at least equally of the Electricity Act, 1998 in payment of principal and debt with all unsecured debt Total debt investment after the proposed investment is not greater than the total debt investment in such a corporation prior to the proposed investment May not be held longer than 10 years Bove conditions do not apply if acquired through a transfer by-law or otherwise under that Act. Source: Municipal Act, 2001 Ontario Regulation 438/97, Last amendment: O. Reg. 39/07 5 - 20 POLICY NUMBER: I-605 SUBJECT: INVESTMENT POLICY SCHEDULE F: SUMMARY OF ELIGIBLE SHARE INVESTMENTS AND CONDITIONS Issuer Conditions Corporation incorporated under the laws of Only permitted through the ONE Fund with Canada or a province of Canada the following exceptions: • Securities of a corporation if the municipality first acquires the securities as a gift in a will and the gift is not made for a charitable purpose. However, the securities must be sold within 90 days after it vests in the municipality • Shares of a corporation if: o the corporation has a debt payable to the municipality o under a court order, the corporation has received protection from its creditors o the acquisition of the shares in lieu of the debt is authorized by the court order, and o the treasurer of the municipality is of the opinion that the debt will be uncollectible by the municipality unless the debt is converted to shares under the court order Source: Municipal Act, 2001 Ontario Regulation 438/97, Last amendment: O. Reg. 39/07 KITCHENER PAGE 17 OF 17 NOVEMBER 2012 5-21