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policy. Such procedures shall include delegation of authority to persons responsible for <br /> investment transactions. The Finance Director and/or City Administrator shall be • <br /> responsible for all transactions undertaken and shall establish a system of internal <br /> controls designed to prevent losses from fraud, employee error, unanticipated changes in <br /> financial markets and imprudent actions by employees and officers of the City. <br /> CONFLICT OF INTEREST <br /> Any City official (elected or appointed) involved in the investment process shall refrain <br /> from personal business activity that could conflict, or give the appearance of a conflict, <br /> with proper execution of the investment program or which could impair his/her ability to <br /> make impartial investment decisions. <br /> AUTHORIZED FINANCIAL INSTITUTE AND DEALER <br /> In accordance with Minnesota Statutes §118.02, the responsibility for conducting <br /> investment transactions resides with the City Council of the City of Forest Lake. Also, <br /> the Council shall be responsible for designating the depositories of the funds. <br /> Depositories shall be selected through a banking services procurement process, which <br /> shall include a comprehensive review of credit characteristics and financial history by the <br /> Finance Director or reliance on selection criteria by an independent third party. In <br /> selecting depositories, the creditworthiness of the institutions under consideration shall be <br /> examined. The City Council shall designate depositories after a recommendation from <br /> staff. <br /> • <br /> Only approved security broker/dealers selected by creditworthiness shall be utilized <br /> (minimum capital requirement $10,000,000 and at least five years of operation.) These <br /> may include "primary" dealers or regional dealers that qualify under Securities and <br /> Exchange Commission Rule 15c3-1 (uniform net capital rule.) <br /> All financial institutions and broker/dealers must supply the following as appropriate: <br /> ➢ audited financial statements; <br /> ➢ proof of National Association of Securities Dealers(NASD) certification, <br /> ➢ proof of state registration; <br /> ➢ completed broker/dealer questionnaire for firms who are not major regional or <br /> national firms; <br /> ➢ certification of having read the City's investment policy. <br /> BROKER REPRESENTATIONS <br /> Municipalities must obtain from their brokers certain representations regarding future <br /> investments. The City of Forest Lake will provide each broker with information <br /> regarding the municipality's investment restrictions. Before engaging in investment <br /> transactions with the City of Forest Lake the supervising officer at the securities <br /> broker/dealer shall submit a certification stating that the officer has reviewed the • <br /> - 3 - <br />