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• • managers should receive periodic training and have sufficient expertise and <br /> technical resources to oversee derivative programs; <br /> • recordkeeping systems should be sufficiently detailed to allow governing <br /> bodies, auditors, and examiners to determine if the program is functioning in <br /> accordance with established objectives; managers should report regularly on <br /> the use of derivatives to their governing body and appropriate disclosure <br /> should be made in official statements and other disclosure documents; and <br /> • reporting on derivative use should be in accordance with generally accepted <br /> accounting principles, and because use of these instruments is a complex <br /> matter, early discussion with public accountants is essential to determine if <br /> specialized reporting may be required. <br /> 5. Governmental entities should be aware if their broker/dealer is merely acting as <br /> an agent or intermediary in a derivatives transaction or is taking a proprietary <br /> position. Possible conflicts of interest should be taken into consideration before <br /> entering into a transaction. <br /> 6. Governmental entities should be aware that there may be little or no pricing <br /> information or standardization for some derivatives. Competitive price comparisons <br /> are recommended before entering into a transaction. <br /> 7. Governmental entities should exercise caution in the selection of broker/dealers or <br /> investment managers and ensure that these agents are knowledgeable about, <br /> understand and provide disclosure regarding the use of derivatives, including <br /> • benefits and risks. The entity should secure written acknowledgment from <br /> broker/dealers that they have received, read, and understood the entity's debt and <br /> investment policies, including whether derivatives are currently authorized under <br /> the entity's investment policy and that the broker/dealer or investment manager <br /> has ascertained that the recommended product is suitable for the governmental <br /> entity. <br /> 8. Governmental entities are responsible for ensuring this same level of safeguards when <br /> derivative transactions are conducted by a third party acting on behalf of the <br /> governmental entities. <br /> 9. Government Entities should analyze the materiality of a transaction closely to <br /> determine if it might affect a bond or other credit— related rating of such entity. <br /> Rating agencies should be notified at the appropriate time, before a transaction is <br /> completed. <br /> References <br /> • A Public Investor's Guide to Money Market Instruments, Second Edition, edited by M. <br /> Corinne Larson, GFOA, 1994. <br /> • An Elected Official's Guide to Investing, M. Corinne Larson, GFOA, 1995. <br /> Approved by the Committee on Cash Management,June 15, 2002 <br /> Approved by the Executive Committee,October 25,2002. <br />