BVSD Board of Education · Document
DFA January 2026.pdf (124 KB)
Regular Meeting, January 27, 2026 · item 10.3: Board Policy DFA, Cash Management/Investment Policy · 7 pages
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Boulder Valley School District File: DFA Adopted: June 9, 1988, date of manual adoption Revised: April 13, 2004, June 12, 2007, June 9, 2009, February __, 2026
CASH MANAGEMENT/INVESTMENT POLICY The Board recognizes the importance of prudent and profitable investment of School District monies and its responsibility in overseeing this part of the School District’s financialprogram.ItisthepolicyoftheSchoolDistricttoinvestpublicfundsinamanner that will preservecapital,meetthedailyliquidityneedsoftheSchoolDistrict,diversify the School District’s investments, generate market rates of return, and conform to all local and statestatutesgoverningtheinvestmentofpublicfunds,andgeneratemarket rates of return, and to exercise prudence. This Cash Management Investment Policy addresses the methods, procedures, and practiceswhichmustbeexercisedtoensureeffectiveandjudiciousfiscalandinvestment management of theSchoolDistrict’s funds. SCOPE ThispolicyshallapplytotheinvestmentofallfinancialassetsandallfundsoftheSchool District over which the Board exercises financial control. All cash shall be pooled for investment purposes, except for cash balances in the Bond Redemption Fund, the Building Fund, the Health Insurance Fund, the Dental Insurance Fund, the Non-expendableTrustFundandtheExpendableTrustFund.Investmentincomederived from the pooled investment account shall be allocated to the General FundCash balances in the Bond RedemptionFund,theBuildingFund,theHealthInsuranceFund, the Dental Insurance Fund, the Non-expendable Trust Fund and the Expendable Trust Fund shall not be pooled and the investment income derived from the individual investment accounts shall be allocated directly to the individual fund. All cashshallbepooledforinvestmentpurposes,exceptforcashbalancesofthefunds listed above. Investment income derived from the pooled investmentaccountshallbe allocated to the General Fund. This Investment Policy shall apply to all funds accounted for in the District’s Comprehensive Annual Financial Report. INVESTMENT OBJECTIVES¶ ¶ The District’s principal investment objectives include:¶
¶ ● Preservation of capital and protection of investment principal;¶ ● Maintenance of sufficient liquidity to meet anticipated cash flows;¶ ● Attainment of a market rate of return;¶ ● Diversification to avoid incurring unreasonable market risks;¶ ● Conformance with all applicable District policies, state statutes and Federal regulations. DELEGATION OF AUTHORITY¶ ¶ The Superintendent is vestedwithresponsibilityformanagingtheDistrict’sinvestment program and for implementing this Cash Management Investment Policy. The Superintendent may delegate the authority to conduct investmenttransactionsandto managetheoperationoftheinvestmentportfoliototheAccountingServicesDirectoror theChiefFinancialOfficer.Nopersonmayengageinaninvestmenttransactionexceptas expressly provided under the terms of this Investment Policy.¶ The Superintendent or his/herdesigneeshallestablishwrittenproceduresandinternal controlsfortheoperationoftheDistrict’sinvestmentprogram,designedtopreventloss of public funds due to fraud, error, misrepresentation and imprudent actions. The School District may engage the support services ofoutsideinvestmentadvisorsin regardtoitsinvestmentprogram,solongasitcanbedemonstratedthattheseservices produce a net financial advantage or necessary financial protection of the School District’s financial resources. PRUDENCE¶ ¶ The standard of prudence, asdefinedbytheColoradoRevisedStatutes,tobeusedfor managing the District’s assets is the "prudent investor" standard applicable to a fiduciary, which states that a prudent investor "shall exercise the judgment and care, under circumstances then prevailing, which men of prudence, discretion, and intelligence exercise in the management of the property of another, not in regard to speculation but in regard to the permanent disposition of funds, considering the probable income as wellastheprobablesafetyofcapital." (ColoradoRevisedStatutes 15-1-304, Standard for Investments.)¶ ¶ TheDistrict’soverallinvestmentprogramshallbedesignedandmanagedwithadegree of professionalism that is worthy of the public trust. The District recognizes that no investmentistotallywithoutriskandthattheinvestmentactivitiesoftheDistrictarea matter of public record. Accordingly, the District recognizesthatoccasionallossesmay be possible in a diversified portfolio and shall be considered withinthecontextofthe overall portfolio’sreturn,providedthatadequatediversificationhasbeenimplemented and that the sale of a security is in the best long-term interest of the District.¶ Page2of7
The Superintendent and other authorized persons acting in accordance with written procedures and exercising due diligence shall be relieved ofpersonalresponsibilityfor an individual security's credit risk or market price changes, provided deviations from expectationsarereportedinatimelyfashiontotheBoardofEducationandappropriate action is taken to control adverse developments.¶ ETHICS AND CONFLICTS OF INTEREST¶ ¶ District employees involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the District’s investment programorthatcouldimpairorcreatetheappearanceofanimpairmentoftheirability tomakeimpartialinvestmentdecisions.EmployeesshalldisclosetotheSuperintendent orhis/herdesigneeanymaterialfinancialinteresttheyhaveinfinancialinstitutionsthat conductbusinesswiththeDistrict,andtheyshallsubordinatetheirpersonalinvestment transactions to those of the District.¶ ¶ AUTHORIZED SECURITIES AND TRANSACTIONS¶ ¶ All investments will be made in accordance with applicable law. the Colorado Revised Statutesasfollows:C.R.S.§11-10.5-101,etseq.,PublicDepositProtectionAct;C.R.S.§ 11-47-101, et seq.,SavingsandLoanAssociationPublicDepositProtectionAct;C.R.S.§ 24-75-601, et. seq., Funds - Legal Investments; C.R.S. § 24-75-603, Depositories; and C.R.S.§24-75-702,Localgovernments–authoritytopoolsurplusfunds.Anyrevisionsor extensions of these sections of the statutes will be assumed to be part of this Investment Policy immediately upon being enacted. This Cash Management Investment Policy further restricts the investment of District funds to the following types of securities and transactions:¶ ¶ 1. U.S. Treasury Obligations: Treasury bills, Treasury notes, Treasury bonds and Treasury STRIPS with maturities not exceeding five years from the date of trade settlement.¶ ¶ 2. Federal Instrumentality Securities: Debentures, discount notes, callable securities, step-up securities and stripped principal or coupons with maturitiesnotexceeding five years from the date of trade settlement issued by thefollowingonly: Federal National Mortgage Association (FNMA), Federal Farm Credit Banks (FFCB), Federal Home Loan Banks (FHLB) and Federal Home Loan Mortgage Corporation (FHLMC). Federal Instrumentality Securitiesshallberatedinthehighestratingcategorybyat least two Nationally RecognizedStatisticalRatingOrganizations(NRSROs),andshall be rated not less by any NRSRO that rates the debt.¶ ¶ Page3of7
3. RepurchaseAgreementswithaterminationdateof180daysorlesscollateralizedby U.S. Treasury obligations or Federal Instrumentality securities listed in 1. and 2. above with a final maturity not exceeding 10 years. The purchased securitiesshall haveaminimummarketvalueincludingaccruedinterestof102percentofthedollar value of the transaction. Collateral shall be held by the District’s third-party custodian bank, and the market value of the collateral securities shall be marked-to-the market daily.¶ ¶ Repurchase Agreements shall be entered into only with broker/dealers recognized as primarydealersbytheFederalReserveBankofNewYork,orwithfirmsthathavea primary dealer within their holding company structure. Approved Repurchase Agreementcounterpartiesshallhaveashort-termcreditratingofatleastA-1orthe equivalent and a long-term credit rating of at least A or the equivalent by a Nationally Recognized Statistical Rating Organization (NRSRO). Repurchase agreement counterparties shall execute a District approved Master Repurchase Agreement with the District. The Chief Operations Officer shall maintain a copyof the District’s approved Master Repurchase Agreement along with a list of broker/dealers who have executed same.¶ ¶ 4. CommercialPaperwithanoriginalmaturityof180daysorlessthatisratedatleast A1+, P-1 or the equivalent atthetimeofpurchasebybyatleasttwoNRSROsand ratednotlessbyallNRSROsthatratethecommercialpaper.Ifthecommercialpaper issuer has senior debt outstanding, it must be rated at least AA-, Aa3 or the equivalent atthetimeofpurchasebyatleasttwoNRSROsandratednotlessbyall NRSROs that rate the issuer.¶ ¶ 5. Non-negotiableCertificatesofDepositwithamaturitynotexceedingoneyearinany FDIC insured state or national bank, or state or federal savings bank located in Colorado that is a state approved depositoryperC.R.S.§24-75-603.Certificatesof deposit that exceed FDIC insurance limits shall be collateralized asrequiredbythe Public Deposit Protection Act or the Savings and Loan Association Public Deposit Protection Act.¶ ¶ 6. LocalGovernmentInvestmentPoolsauthorizedunderC.R.S.§24-75-702that: 1)are "no-load"(nocommissionorfeeshallbechargedonpurchasesorsalesofshares);2) have a constant net asset value of $1.00 per share; 3) limit assets of the fund to thosesecuritiesauthorizedbystatestatute;4)haveamaximumstatedmaturityand weightedaveragematurityinaccordancewithRule2a-7oftheInvestmentCompany Act of 1940; and 5) have a rating of AAA or the equivalent by one or more NRSROs.¶ ¶ 7. MoneyMarketMutualFundsregisteredundertheInvestmentCompanyActof1940 that:1)are"no-load"(nocommissionorfeeshallbechargedonpurchasesorsales ofshares);2)haveaconstantnetassetvalueof$1.00pershare;3)limitassetsofthe fund to those securities authorized by state statute; 4) have a maximum stated maturity and weighted average maturity in accordance with Rule 2a-7 of the Page4of7
Investment Company Actof1940;and5)havearatingofAAAortheequivalentby one or more NRSROs.¶ ¶ The foregoing list of authorized securities shall be strictly interpreted. Any deviation from this list must be approved by the Board of Education.¶ ¶ INVESTMENT DIVERSIFICATION¶ ¶ ItistheintentoftheDistricttodiversifytheinvestmentswithintheinvestmentportfolio to avoid incurring unreasonable risksinherentinover-investinginspecificinstruments, individual financial institutions or maturities. Nevertheless, the asset allocation in the investment portfolio should be flexible depending upon the outlook for the economy, the securities markets and the District’s anticipated cash flow needs.¶ ¶ INVESTMENT MATURITY AND LIQUIDITY¶ ¶ The investment portfolio shall remain sufficiently liquid to meet allcashrequirements that may be reasonably anticipated. To the extent possible, investments shall be matched with anticipated cash flows and known futureliabilities.Investmentsshallbe limited to maturities not exceeding five years from the date of trade settlement.¶ ¶ COMPETITIVE TRANSACTIONS¶ ¶ Each investment transaction shall be competitively transacted with authorized broker/dealers.Atleastthreebroker/dealersshallbecontactedforeachtransactionand their bid and offering prices shall be recorded.¶ ¶ If the District is offered a security for which there is no other readily available competitive offering, quotations for comparable or alternative securities will be documented. SELECTION OF BROKER/DEALERS¶ ¶ The Chief Operations Officer shall maintain a list of broker/dealers approved for investmentpurposes,anditshallbethepolicyoftheDistricttopurchasesecuritiesonly from those authorized firms.¶ ¶ To be eligible, a firm must meet at least one of the following criteria: ¶ ¶ 1. BerecognizedasaprimarydealerbytheFederalReserveBankofNewYorkorhave a primary dealer within its holding company structure;¶ 2. Report voluntarily to the Federal Reserve Bank of New York;¶ 3. QualifyunderSecuritiesandExchangeCommission(SEC)Rule15c3-1(UniformNet Capital Rule).¶ ¶ Page5of7
Broker/dealers will be selectedbytheSuperintendentorhis/herdesigneeonthebasis of theirexpertiseinpubliccashmanagementandtheirabilitytoprovideservicetothe District’s account. Each authorized broker/dealer shall be required to submit and annually update a District approved Broker/Dealer Information Request Form that includes the firm's most recent financial statements. In the event that an external investmentadvisorisnotusedintheprocessofrecommendingaparticulartransaction intheDistrict’sportfolio,anyauthorizedbroker/dealerfromwhomacompetitivebidis obtainedforthetransactionwillattestinwritingthathe/shehasreceivedandreviewed a copy of this policy. The District may purchase commercial paper from direct issuerseventhoughtheyare notontheapprovedbroker/dealerlistaslongastheymeetthecriteriaoutlinedinitem 3. of the Authorized Securities and Transactions section of this Investment Policy.¶ ¶ SAFEKEEPING AND CUSTODY¶ ¶ The Superintendent or his/her designee shall approve one or more banks to provide safekeeping and custodial services for the District. A District approved safekeeping agreement shall be executed with each custodian bank. To be eligible, a financial institutionshallqualifyasadepositoryofpublicfundsinColoradoasdefinedinC.R.S.§ 24-75-603.¶ The purchase and sale of securities and repurchase agreement transactions shall be settledonadeliveryversuspaymentbasis.Ownershipofallsecuritiesshallbeperfected in the name oftheDistrict.Sufficientevidencetotitleshallbeconsistentwithmodern investment, banking and commercial practices.¶ ¶ All investment securities, except non-negotiable Certificates of Deposit, Local Government Investment Pools and Money Market Mutual Funds, purchased by the District will be delivered by either book entry or physical delivery and will be held in third-partysafekeepingbytheDistrictapprovedcustodianbank,itscorrespondentbank or the Depository Trust Company (DTC).¶ ¶ All Fed wireable book entry securities shallbeevidencedbyasafekeepingreceiptora customer confirmation issued to the District by the custodian bank stating that the securities are held in the Federal Reserve system in a Customer Account for the custodian bank which will name the District as “customer.”¶ ¶ AllDTCeligiblesecuritiesshallbeheldinthecustodianbank’sDepositoryTrustCompany (DTC) participant account and the custodian bank shall issue a safekeeping receipt evidencing that the securities are held for the District as “customer.”¶ ¶ Allnon-bookentry(physicaldelivery)securitiesshallbeheldbythecustodianbankorits correspondent bank and the custodian bank shall provide evidence thatthesecurities are held for the District as “customer.” ¶ Page6of7
The District’s custodian will be required to furnish the District monthly reports of holdings of custodied securities as well as a report of monthly safekeeping activity.¶
REPORTING At the end of each quarter, the Chief Financial Officer shall submit to the Board an investment report listing the investments held by the School District and the current marketvalueoftheinvestments.Thesereportsshallbeformattedinamannerthat allowstheBoardtoevaluatethesuccessofitsinvestmentpracticesinlightofits stated objectives. POLICY REVISIONS¶ ¶ This Cash Management/ Investment Policy shall be reviewed annually by the Superintendentorhis/herdesigneeandmaybeamendedbytheBoardofEducationas conditions warrant.¶ LEGAL REFS.: C.R.S. §11-10.5-101(Public Deposit Protection Act) C.R.S. § 11-47-101 (Savings and Loan Association Public Deposit Protection Act) C.R.S. §22-45-103(bond redemption fund trustee or escrow requirement) C.R.S. §24-75-601(public funds - legal investments) C.R.S. §24-75-701(investment funds - local government pooling)
End of File: DFA
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