Administrative Regulation Title:  Investment Procedures

Regulation Number:  6.9.1

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Eastern Wyoming College (EWC) has adopted an investment policy that provides management with flexibility to enhance revenue through short-term, local investment opportunities. Investment earnings generated by the investment of excess cash resources are a vital revenue component to EWC. A minimum threshold level of earnings must be maintained in order to fully fund existing programs for the budget year. Earnings that are greater than the established minimum are available to enhance operating budgets, upon approval by the EWC Board of Trustees.  Therefore, a successful investment program is important, as it benefits not only sustainability, but growth.

Eastern Wyoming College may only purchase those investments that comply with Wyoming Statutes (see W.S. 9-4-831).  Further, the EWC Board of Trustees must pre-approve each investment type except for certificates of deposits/time deposits, which have already been approved) and financial Entity employed in the investment of College funds.

Eastern Wyoming College may only invest in those investment types that are listed in current Wyoming Statutes and have been approved by the EWC Board of Trustees.  As of July 30, 2013, approved investment types are:

  1. United States treasury bills, notes or bonds, including stripped principal or interest obligations of such issuances, or any other obligation or security issued by the United States treasury or any other obligation guaranteed as to principal and interest by the United States.
  2. Bonds, notes, debentures, or any other obligations or securities issued by or guaranteed by any federal government agency or instrumentality, including but not limited to the following to the extent that they remain federal government agencies or instrumentalities: Federal National Mortgage Association, Federal Home Loan Bank, Federal Farm Credit Bank, Federal Home Loan Mortgage Corporation, and Government National Mortgage Association.  All federal agency securities shall be direct issuances of federal agencies or instrumentalities.
  3. Repurchase agreements involving securities which are authorized investments under (1.) and (2.) above. The securities may be held in a custodial arrangement with a member bank of the Federal Reserve System or in a segregated account at a Federal Reserve System bank.   The repurchase agreement must provide for daily valuation and have a minimum excess market price reserve of one hundred two percent (102%} of the investment.
  4. Mortgage-backed securities that are obligations of or guaranteed or insured issues of the United States, its agencies, instrumentalities, or organizations created by an act of congress, excluding those defined as high risk. High risk mortgage-backed securities are defined as any security which meets either of the following criteria:
    1. Is rated V-6 or higher by Fitch Investors Service or at an equivalent rating by another nationally recognized rating service; or,
    2. Is defined as a high-risk mortgage security under Section Ill of the Supervisory Policy Concerning Selection of Securities Dealers and Unsuitable Investment Practices, as amended by the Federal Financial Institutions Examination Council, as created under 12 U.S.C. 3301, et seq., or its successor.
  5. Banker’s acceptances of United States bank eligible for purchase by the Federal Reserve System.
  6. Guaranteed investment contracts, if issued and guaranteed by a United States commercial bank or a United States insurance company. The credit quality of the issuer and guarantor shall be the highest category of A.M. Best, Moody’s, or Standard and Poor’s rating service.  The contract shall provide the governmental entity a non-­ penalized right of withdrawal of the investment if the credit quality of the investment is downgraded.
  7. A commingled fund of eligible securities listed herein, if the securities are held through a trust department of a bank authorized to do business in Wyoming or through a trust company authorized to do business in Wyoming with total capital of at least ten million dollars ($10,000,000) or which has an unconditional guarantee with respect to those securities from an entity with total capital of at least one hundred million dollars ($100,000,000).
  8. Certificates of deposit of a savings and loan association or a federal savings bank authorized to do business in this state to the extent that they are fully insured by the Federal Deposit Insurance Corporation (FDIC} or secured by a pledge of assets, and are otherwise authorized as a depository by the EWC Board of Trustees, as prescribed by law.
  9. Certificates of deposit of a bank authorized to do business in Wyoming to the extent that they are fully insured by the FDIC or secured by a pledge of assets, and are otherwise authorized as a depository by the EWC Board of Trustees, as prescribed by law.
  10. As authorized by W.S. 37-5-206 and 37-5-406, bonds of the Wyoming pipeline authority and the Wyoming infrastructure authority.
  11. Investments in shares of a diversified money market fund are authorized except that no entity of Wyoming government shall at any time own more than ten percent (10%) of the fund’s net assets or shares outstanding. Investments under this subsection are limited to a diversified money market fund which seeks to maintain a stable share value of one dollar ($1.00), is registered under the Securities Act of 1933 and Investment Company Act of 1940, as amended, and has qualified under state registration requirements, if any, to sell shares in Wyoming and which:
  1. Invests its assets:
    1. Solely in securities issued by the United States treasury, obligations, or securities issued by or guaranteed by any federal government agency or instrumentality, and repurchase agreements collateralized by such instruments at not less than the repurchase price including accrued interest;
    2. Solely in securities issued by the United States treasury, obligations, or securities issued by or guaranteed by any federal government agency or instrumentality, and repurchase agreements collateralized by such instruments at not less than the repurchase price including accrued interest;
    3. So that an average dollar weighted maturity of ninety (90) days or less is maintained at all times; and,
    4. Under limitations such that the fund may borrow funds for temporary purposes only by entering into repurchase agreements and only to the extent permitted by federal law.
  2. Does not impose a sales charge.
  3. Maintains the highest quality rating from at least one (1) of the nationally recognized rating organizations, such as Standard & Poor’s Corporation or Moody’s Investor Services.
  4. Has an operating history of not less than five (5) consecutive years.
  5. Requires submission of sixty (60) days advance notice of any investment policy change, in the case where such policy changes may be approved without approval of the fund’s shareholders or requires approval by shareholders entitled to vote a majority, as the term is defined under the Investment Company Act of 1940, as amended, of the fund’s shares.
  6. Is purchased from a person licensed to sell securities in Wyoming through or for an account with an entity which, at the time the investment is made by the state or local government:
    1. Has been continuously engaged in the business of selling securities in Wyoming for the preceding two (2) years or a financial institution authorized to do business in Wyoming and qualified by law to act as a depository of public funds in this state; and,
    2. Currently, and during the preceding two (2) years, continuously had at least one (1) established place of business in this state. As used in this subparagraph, “established place of business” means a place in this state which is actually occupied either continuously or at regular periods by employees or agents of the entity who are licensed to sell securities in this state and where a large share of the entity’s business in this state is actually conducted.

12. Commercial paper of corporations organized and existing under the laws of any state of the United States, provided that at the time of purchase, the commercial paper shall:

    1. Have a maturity of not more than two hundred seventy (270) days; and,
    2. Be rated by Moody’s as P-1 or by Standard & Poor’s as A-1+ or equivalent ratings indicating that the commercial paper issued by a corporation is of the highest quality rating.

Any company or person (other than EWC employees or Trustees) that executes investment transactions on behalf of or offers investment advice to Eastern Wyoming College must sign a Securities Dealer Certification Form that indicates the company or person has read EWC’s investment policy and accompanying Administrative Regulation Titles, and agrees to abide by Wyoming state law with respect to investment advice given and transactions completed.   For the purpose of purchasing certificates of deposits or time deposits under (8.) and (9.) above, the Securities Dealer Certification Form is not required of banks that have been approved as a depository of EWC public funds.

Competitive bidding among participating authorized depositories offering time deposits for the highest possible yield under substantially equal risk levels is encouraged and shall be used when management can reasonably commit excess cash resources to an investment program for a predetermined length of time.       However, the length of time should not generally exceed 120 days.  It is allowable to roll the investment over for an additional 30 days without re-bidding.

 

Original Adoption Date: 6/10/03

Revision Date(s): 11/8/05(RF), 2/11/14, 10/10/11 (RN)

Date reviewed, no change: