HomeMy WebLinkAboutFIN-2021-20 - Investment Policy Update
Finance and Corporate Services Committee
REPORT TO:
DATE OF MEETING: 4/19/2021
SUBMITTED BY: Ryan Hagey, Director of Financial Planning
PREPARED BY: Ryan Hagey, Director of Financial Planning
WARD(S) INVOLVED: All Wards
DATE OF REPORT: March 30, 2021
REPORT NO.: FIN -2021-20
SUBJECT: Investment Policy Update
RECOMMENDATION:
That the City investment policy FIN-PLA-605, attached as Appendix A to staff report
FCS-17-095, be approved as amended.
REPORT HIGHLIGHTS:
The purpose of this report is to amend the Investment Policy based on content
presented through the Long Term Financial Plan (LTFP)
The main changes involve better role definitions, updating the standards for eligible
investments, and exclusion from the Prudent Investor standard
This report supports the delivery of core services.
BACKGROUND:
The City of Kitchener Investment Policy is governed by the Municipal Act and related
regulations. The policy was last updated in 2017.
The goal of the 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, and Trust Funds. The income resulting from the
investment of City funds is one of the revenue sources available to reduce the financial
burden on ratepayers. The objectives of the policy, in order of importance include:
Adherence to statutory requirements
with the Municipal Act and related regulations.
Preservation of capital
that the possibility of losing the invested funds is extremely unlikely.
Liquidity
sufficient funds availa
they are due.
*** This information is available in accessible formats upon request. ***
Please call 519-741-2345 or TTY 1-866-969-9994 for assistance.
Return on Investment - The investments will be managed to attain the
maximum rate of return while meeting the other objectives.
The policy also governs the quality of securities the City can accept from others, for example,
Letters of Credit.
As part of the comprehensive content presented during the Long Term Financial Plan
change to using a multi-year average to budget for investment income, as well as content
changes to the Investment Policy which would be approved at a later date. The attached
Investment Policy is largely consistent with the version presented to Council during the LTFP
discussions.
REPORT:
The proposed Investment Policy is in a revised format and includes changes to the way it is
presented. The primary content changes include:
Better role definitions (Section 3 Scope Responsibilities)
Updated standards for eligible investments (Section 4 Eligible Investments a)
Exclusion from the Prudent Investor Standard (Section 4 Eligible Investments b)
Each of these is briefly discussed below.
Better role definitions (Section 3 Scope Responsibilities)
The previous policy did not include any role definitions. The updated version includes clear
definitions from Council, the Chief Administrative Officer, the Chief Financial Officer, and the
Director of Financial Planning. Having better role definitions in financial policies was one of
the recommendations from the LTFP.
Updated standards for eligible investments (Section 4 Eligible Investments a)
The City is limited by the Municipal Act and associated regulation in terms of the kinds
of/quality of instruments in which it can invest. Under the updated policy, the City will be
Schedule A of the policy. Under the previous policy only investments
quality were considered.
preserving capital, but should also better meet the policy goal of improving return on
investment. During the historically low interest rate environment caused by COVID-19,
investment returns for items like GICs, and bonds have been significantly lower than normal.
The change to the quality of investment options will also apply to letters of credit accepted
by the City as financial security. This will help development within the City, as some
a letter
of credit from their preferred financial institution instead of a different institution that would
require a higher premium for their services. The change
investments in add represents little risk to the City and is consistent
with policies in other municipalities.
Exclusion from the Prudent Investor Standard (Section 4 Eligible Investments b)
As noted above, the City is limited by the Municipal Act and associated regulation in terms
of the kinds of/quality of instruments in which it can invest. In 2018, a new section (Prudent
Investment, 418.1) was added to the Municipal Act. Under the Prudent Investor Standard,
ould choose to invest in more volatile
products that could potentially provide higher returns, but also have a greater degree of risk,
such as investing in stocks traded on the open market. Staff are not recommending this
option at this time for a number of reasons including:
It is more risky, because investment options are unlimited
o While the Municipal Act is quite restrictive and limits returns, it also almost
guarantees that invested funds will not be lost due to bankruptcy
It relinquishes all control to an investment board
o A municipality must either establish or participate through an investment
board, which cannot include members of council or municipal staff, with the
exception of a municipal treasurer. This would significantly limit the
ypes of investments being entered into and
would represent a risk to the municipality
It is permanent
o Once a municipality opts into Prudent Investment it cannot opt back out
If Council is interested in pursuing Prudent Investment, the policy decision recommended
as part of this report could be revisited at some point in the future.
STRATEGIC PLAN ALIGNMENT:
This report supports the delivery of core services.
FINANCIAL IMPLICATIONS:
There are no immediate financial implications of the changes recommended in this report.
; however they would increase
ult in
improved investment yields.
COMMUNITY ENGAGEMENT:
INFORM
the council / committee meeting.
PREVIOUS REPORTS/AUTHORITIES:
Investment Policy FIN-PLA-605
APPROVED BY: Jonathan Lautenbach, Chief Financial Officer
ATTACHMENTS:
1. Investment Policy
POLICY Policy No: FIN-PLA-605
Approval Date: Click here to enter a
Policy Title: INVESTMENT
date.
Policy Type: COUNCIL
Reviewed Date: August 2019
Category: Finance
Next Review Date: August 2024
Reviewed Date: Click here to enter text.
Sub-Category: Financial Planning
Author: Senior Financial Analyst
Last Amended: Click here to enter a
date.
Dept/Div: Finance/Financial Planning
Replaces: Click here to enter text.
Repealed: Click here to enter a date.
Replaced by: Click here to enter text.
Related Policies, Procedures and/or Guidelines:
Municipal Act, 2001, S.O. 2001, c. 25, Part XIII, Section 418(1)
Municipal Act, 2001, Ontario Regulation 438/97
1. POLICY PURPOSE:
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.
The purpose of the policy is to establish guidelines and controls related to the
investment and holding of public funds to ensure funds are available when
needed, while maximizing return.
2. DEFINITIONS:
Asset-backed Securities short- or long-term debt instruments, which are
backed by 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 Paper short-term notes or drafts issued by a corporation,
incorporated under the laws of Canada or a province of Canada
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Policy No:
Policy Title:
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
Dominion Bond Rating Service (DBRS) a service that assesses the credit rating of
institutions
Forward Rate Agreement (FRA) contract with a qualified financial institution
allowing an investor to fix the interest rate to be received on an investment for a
specified term beginning at an agreed to future date
Interest rate risk risk of an increase or decrease in the value of a fixed income
security caused by declining or rising interest rates
Long-term investment investment whose term to maturity is greater than one
year
Liquidity
ONE Fund Public Sector Group of Funds pooled investment fund meeting the
eligibility criteria defined by the regulations under the Municipal Act. It is
operated by the Local Authorities Service Limited and CHUMS Financing
Corporation
Regulation Ontario Regulation 438/97 related to section 418 and 418.1 of the
Schedule I Bank a chartered bank operating under the Bank Act. The voting
shares must be widely held with no investor holding more than10% and foreign
ownership limited to 25%
Schedule II Bank a chartered bank operating under the Bank Act. It may be
wholly owned by non-residents
Schedule III Bank a foreign bank branch of foreign institutions operating under
the Bank Act under certain restrictions
Short-term Investment investment whose term to maturity is two years or less
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Supranational Institutions an agency sponsored by highly rated foreign bank(s)
or Governments issuing debt to fund loans in developing countries for large
infrastructure projects. They may be owned or guaranteed by a consortium of
national governments
Trust Company financial institution which acts as a fiduciary, trustee or agent in
the administration of trust funds, estates and custodial arrangements
3. SCOPE:
POLICY APPLIES TO THE FOLLOWING:
All Employees
All Full-Time Employees All Union
Management C.U.P.E. 68 Civic
Non Union C.U.P.E. 68 Mechanics
Temporary C.U.P.E. 791
Student I.B.E.W. 636
Part-Time Employees K.P.F.F.A.
Specified Positions only:! Other:!
Council Local Boards & Advisory Committees
The investment policy applies to all financial assets of the City of Kitchener held
within the general fund, capital fund, reserve funds, enterprise funds, and trust
funds.
R esponsibilities
Council
Under section 224(e) of the Municipal Act 2001, Council is responsible for
ouncil is required to
make decisions that adhere to the financial policies and procedures that have
been put in place to provide investment income for the municipality.
Chief Administrative Officer
Under section 229(a) of the Municipal Act 2001, the Chief Administrative Officer is
responsible
municipality for the purpose of ensuring the efficient and effective operation of
in place that support
the effective administration related to investment of City funds.
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Policy No:
Policy Title:
Chief Financial Officer (Treasurer)
Under section 286(1) of the Municipal Act 2001, the treasurer is responsible for
nicipality on behalf of and in the
Monitoring adherence to statutory requirements
Ensuring preservation of capital
Monitoring interest rate risk
Ensuring liquidity of investments
Maximizing return on investments
Director of Financial Planning
As part of their role the Director of Financial Planning has been delegated
authority and is responsible for:
Establishing investment procedures aligned with this policy
Monitoring cash flow to make effective investment decisions
Ensuring proper controls are in place related to investments
Delegating specific investment related tasks to staff where appropriate
4. POLICY CONTENT:
Objectives
be:
a) Adherence to statutory requirements
Investment activity will be governed by the Municipal Act as amended and
limited to eligible investments under the Act and associated provincial
regulations
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 including:
Utilizing credit ratings to assess the overall credit risk related to a
particular investment
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Diversifying the overall investment portfolio in accordance with this
policy
Properly assessing and mitigating risk associated with fluctuating
interest rates for short- and long-term investments
c) Liquidity
to meet all operating and capital requirements that might be reasonably
anticipated and to limit temporary borrowing requirements.
d) Return on Investments
The investment portfolio shall be designed to attain the maximum rate of
return while meeting the above three objectives
Eligible investments
a) Section 418 of Ontario Regulation 438/97 provides a list of eligible securities
that the municipality may invest in. The regulation includes securities such as
bonds, debentures, promissory notes, and other evidence of indebtedness.
The City of Kitchener will consider potential investment opportunities related
to all eligible securities types included in the regulation provided that:
comply with all other aspects of this policy
Schedule A and meet the minimum credit rating requirements and
conditions as outlined in the regulation
They have not been specifically restricted or excluded in this policy
b) Exclusions Prudent Investor Standard (Section 418.1)
Part of Ontario Regulation 438/97 includes new prudent investor standards
that allow municipalities that meet certain eligibility criteria the option to
invest in a broader range of securities. The City of Kitchener has not opted-in
to this new standard and as such, is only authorized to invest in securities
described under section 418 and not section 418.1 of the regulation.
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Policy No:
Policy Title:
c) The City may enter Forward Rate Agreements (FRA) to reduce the risk of
future interest rate changes associated with known cash inflows provided
that:
The FRA is only executed with Schedule I, II, or III Banks whose minimum
The term of any FRA must be less than 12 months
An agreement must specify the forward amount, settlement date,
forward interest rate, reference interest rate, as well as other pertinent
details as prescribed in the regulation
The agreement must be reviewed and approved by the Treasurer and
comply with all other requirements of the regulation
d)
funds. Unrated municipalities are only permitted to invest in the following
securities if made through the ONE Fund Program:
Commercial paper
Corporate debt and shares
Asset-backed securities
A Council approved bylaw is required prior to entering into any such agreement.
Diversification
The City of Kitchener will diversify its investments by security type and institution
according to Schedule B. 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.
Safekeeping and custody
Investments and letters of credit are stored
physically on site or electronically on City servers.
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
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Policy Title:
City will not directly invest in securities maturing more than two years from the
date of purchase. Reserve and Trust Funds may be invested in securities
exceeding two years if the maturity of such investments is made to coincide as
nearly as possible with the expected use of the funds.
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. Yields on the short-term
general bank account.
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
changes, provided deviations from expectations are reported in a timely
fashion and the liquidation or 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.
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Policy Title:
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) Reporting
The Treasurer shall provide an investment report to Council at least twice per
year.
Authorized investment dealers
Authorized investment dealers must be registered as Investment Dealers with the
Ontario Securities Commission and be members of the Investment Dealers
Association of Canada, and be approved by the Treasurer.
Securities for subdivision and Development Servicing
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.
The City of Kitchener shall accept only the following approved securities:
a) 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 minimum DBRS rating A (low) (or equivalent).
b) Letter of Credit (in prescribed form acceptable to the City Solicitor) issued by
a Credit Union provided that:
The Credit Union is verified as a member of the Central 1 Credit Union
The Central 1 Credit Union is rated A (low) (or equivalent) or higher
The Credit Union has its Head Office in Ontario
The cumulative Letters of Credit do not exceed 1% of the Credit
financial statements.
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Policy Title:
5. HISTORY OF POLICY CHANGES
Administrative Updates
2016-07-01 - I-605 policy template re-formatted to new numbering system and given
number FIN-PLA-605.
Formal Amendments
2008-04-07 - Resolution passed by Council
2012-12-03 - Resolution passed by Council, see report FCS-12-189
2016-06-01 - I-605 policy template was re-formatted to new numbering system and given
number FIN-PLA-605
2017-06-05 - Resolution passed by Council, see report FCS-17-095.
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 Fitch
Superior: extremely strong capacity AAA AAA Aaa AAA
to 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+ A1 A+
principal and interest A A A2 A
A (low) A- A3 A-
SHORT-TERM CREDIT RATINGS
The following chart compares the different scales for short-term securities used by three
rating agencies recognized in Ontario Regulation 438/97.
Credit Quality DBRS S&P Fitch
Superior: extremely strong capacity to repay R-1 (high) A-1+ F-1+
principal and interest R-1 (middle)
Good: strong capacity to repay principal and R-1 (low) A-1 F-1
interest
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Schedule B:
INVESTMENT POLICY DIVERSIFICATION SUMMARY SHORT-TERM PORTFOLIO
Sector Maximum Limits**
Portfolio
Share
Government of Canada 100% None
Provinces 100% 25%/issuer
Municipalities 20% 10%/issuer
Schedule I Banks 100% Top 5 major chartered banks: 75%/issuer*;
Other Schedule I banks: 25%/issuer
Schedule II Banks and 30% HSBC Canada: 25%;
Schedule III Banks Other Schedule II and III banks: 10%/issuer
Credit Unions and Trust 20% 10%/issuer
Companies
Pooled Investment Funds 100% None
* The minimum primary bank account balance required to obtain a preferred rate is
excluded from the limit per issuer.
** Compliance with limits is required within 30 days of non-compliance.
INVESTMENT POLICY DIVERSIFICATION SUMMARY LONG-TERM PORTFOLIO
Sector Maximum Limits
Portfolio
Share
Government of Canada 100% None
Governments of other 10% 5%/issuer
countries and supranationals
Provinces 50% 25%/issuer
Municipalities 35% total 10%/issuer
Region of Waterloo 35%
Other municipalities 25%
College, University, Housing 10%
Corp., Hospital
Incorporated Municipal 100% Common Shares Total issued to City at
Electrical Utilities incorporation; Preferred Shares None
Financial 75% total Top 5 - 25%/issuer
Schedule I banks top 5 75%
major chartered banks Other 10%/issuer
Other Schedule I, II, III 20%
banks, Trust Companies,
Credit Unions
Pooled Investment Funds 75% 10% limit on equity portfolio
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