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provide a copy of their most recent report on internal controls(Statement of Auditing Standards No. <br /> • 70,or SAS 70). <br /> 3. Internal Controls <br /> The investment officer is responsible for establishing and maintaining an internal control structure <br /> designed to ensure that the assets of the [entity]are protected from loss,theft or misuse. Details of the <br /> internal controls system shall be documented in an investment procedures manual and shall be <br /> reviewed and updated annually. The internal control structure shall be designed to provide reasonable <br /> assurance that these objectives are met. The concept of reasonable assurance recognizes that(1)the <br /> cost of a control should not exceed the benefits likely to be derived and(2)the valuation of costs and <br /> benefits requires estimates and judgments by management. <br /> The internal controls structure shall address the following points: <br /> • Control of collusion <br /> • Separation of transaction authority from accounting and recordkeeping <br /> • Custodial safekeeping <br /> • Avoidance of physical delivery securities <br /> • Clear delegation of authority to subordinate staff members <br /> • Written confirmation of transactions for investments and wire transfers <br /> • Dual authorizations of wire transfers <br /> • Development of a wire transfer agreement with the lead bank and third-party custodian <br /> Accordingly,the investment officer shall establish a process for an annual independent review by an <br /> external auditor to assure compliance with policies and procedures or alternatively,compliance should <br /> • be assured through the [entity] annual independent audit. <br /> Alternative sample language. <br /> The investment officer shall establish a system of internal controls,which shall be documented in <br /> writing. The internal controls shall be reviewed by the investment committee,where present, and <br /> with the independent auditor. The controls shall be designed to prevent the loss of public funds <br /> arising from fraud,employee error,misrepresentation by third parties,unanticipated changes in <br /> financial markets,or imprudent actions by employees and officers of the [entity.] <br /> VII. Suitable and Authorized Investments <br /> 1. Investment Types <br /> Consistent with the GFOA Policy Statement on State and Local Laws Concerning Investment <br /> Practices,the following investments will be permitted by this policy and are those defined by state <br /> and local law where applicable: <br /> • U.S.Treasury obligations which carry the full faith and credit guarantee of the United States <br /> government and are considered to be the most secure instruments available; <br /> • U.S.government agency and instrumentality obligations that have a liquid market with a readily <br /> determinable market value; <br /> • Canadian government obligations(payable in local currency); <br /> • Certificates of deposit and other evidences of deposit at financial institutions, <br /> • Bankers'acceptances; <br /> • Commercial paper,rated in the highest tier(e.g.,A-1,P-1,F-1, or D-1 or higher)by a nationally <br /> recognized rating agency; <br />