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considering the probable safety of the plan capital as well as the probable investment return to be derived <br /> from the assets." <br /> The investment officer, acting in accordance with this policy and with Minnesota Statute 118A and <br /> exercising due diligence shall be relieved of personal liability for an individual security's credit risk or <br /> market price changes,provided that reasonable action is taken to control adverse developments and <br /> unexpected deviations are reported in a timely manner. <br /> I <br /> SECTION 6. CONFLICT OF INTEREST <br /> Any City official (elected or appointed) involved in the investment process shall refrain from personal <br /> business activity that could conflict with proper execution of the investment program or which could <br /> impair his/her ability to make impartial investment decisions. <br /> SECTION 7. INTERNAL CONTROLS <br /> Internal controls shall be designed to prevent loss of public funds due to fraud, error,misrepresentation, <br /> unanticipated market changes,or imprudent actions. Internal controls shall be reviewed annually by an <br /> independent auditor. <br /> SECTION 8. AUTHORIZED FINANCIAL INSTITUTE AND DEALER <br /> The responsibility for conducting investment transactions resides with the City Council of the City of <br /> Pequot Lakes. Also, the Council shall authorize the investment officer to exercise the powers of the <br /> Council in designating a depository of the Funds. <br /> In accordance with Minnesota Statute 118A.02, only approved security broker/dealers selected by <br /> creditworthiness shall be utilized. <br /> SECTION 9. BROKER REPRESENTATIONS <br /> Before engaging in investment transactions with the City of Pequot Lakes,brokers shall submit a <br /> certification annually according to Minnesota Statutes, Section I I8A.04. The document will state that the <br /> officer has reviewed the investment policies and objectives, as well applicable state law, and agrees to <br /> disclose potential conflicts of interest or risk to public funds that might arise out of business transactions <br /> between the firm and the City of Pequot Lakes. All financial institutions shall agree to undertake <br /> reasonable efforts to preclude imprudent transactions involving the City's funds. <br /> SECTION 10. SUITABLE AND AUTHORIZED INVESTMENT INSTRUMENTS <br /> Minnesota Statutes, Section 118A.04, lists all permissible investments for municipalities. This list <br /> establishes the maximum investment risk permitted for a Minnesota municipality. Even though MN <br /> Statutes 118A.04 provides for more instruments to be used for investing purposes; the following is a <br /> listing of investments the City will be authorized to invest in. <br /> 1. Government Securities: Instruments such as bonds, notes, bills, mortgages and other securities <br /> which are direct obligations of the federal government or its agencies, with the principal fully <br /> guaranteed by the U.S. Government or its agencies. <br /> 2. Certificate of Deposit: A negotiable or nonnegotiable instrument issued by commercial banks <br /> and insured up to $100,000 by the Federal Deposit Insurance Corporation (FDIC). The City may <br /> Page 2 <br />