REQUEST FOR INFORMATION (“RFI”)FOR SELECTION OF BROKERS/DEALERS

FOR THE YEAR 2018

OFFICE OF THE CITY TREASURERCITY OF CHICAGO

KURT A. SUMMERS, JR.TREASURER

Responses Due: Friday, June 15, 2018, 4:00 p.m.

TABLE OF CONTENTS

INTRODUCTION & INSTRUCTIONS…………………………….……………3

SUBMISSION CHECKLIST……………………………………………….……..4

QUESTIONNAIRE………………………………………………………….……..6 Firm Information………………………………………………….......……..6 Diversity, Social Responsibility……………………………………………..7 Sales Coverage Information…………………………………………………8 Trading Products Capacity Information……………………………………..9 Sales Coverage Ability / Experience Selling City of Chicago

Treasurer’s Office (“CTO”) Investment Guideline Products…………..…..11 Research/Strategy Capabilities……………………………………..…...….12 Compliance/Due Diligence……………………………………..………..…13 Municipal Advisory Rule (“MA Rule”)/Securities Exchange

Act of 1934 (Rule 15Bal et seq.) ………………………………………...…14 Operations…………………………………………………………………...15 References……………………………………………………………….......16 Firm Capital Capacity……………………………………………………….17 Questionnaire Compliance……………………………………………..........18

CERTIFICATION…………………………………………………...……………19 Exhibit A: City of Chicago Economic Disclosure

Statement and Affidavit…………………………………………………….21 Exhibit B: Scope of City of Chicago Interface……………………………...34 Exhibit C: Minority Participation Affidavit…………………………...……36 Exhibit D: Supplemental Reference Materials…………………………........38

o Statement of Investment Policy and Guidelines…………………….38o Municipal Code for the City of Chicago…………………………….47

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INTRODUCTION & INSTRUCTIONS

The Office of the City Treasurer of the City of Chicago (the “City Treasurer’s Office”) is in the process of compiling a list of qualified brokers/dealers with whom it will place orders to purchase and sell securities for various City of Chicago accounts beginning in the second quarter of 2018. It is the policy of the City Treasurer’s Office to only approve a broker/dealer for inclusion on the list of Approved Firms if the Firm maintains a physical office within the City of Chicago.

In order to be considered for inclusion on the list of Approved Firms in 2018, your Firm must submit a complete hardcopy Request for Information (“RFI”) response to the City Treasurer’s Office by Friday, June 15, 2018, 4:00 p.m. Please refer to the document entitled “Checklist” located in this packet for a complete list of documents that must be submitted as part of your Firm’s RFI response. If a question does not apply to your Firm, the question should be answered “none” or “not applicable.” Complete and legible copies of all requested documents should accompany the RFI response. The broker/dealers that the City Treasurer’s Office deems Approved Firms for 2018 will be notified by the City Treasurer in writing of their eligibility to transact investments for the City of Chicago in July 2018.

If you have any questions about the RFI process or the bid/quote procedures, please call Assistant City Treasurer, Mary Christine Jackman, of the City Treasurer’s Office, at (312) 744-3363 for further assistance.

NOTES:

RESPONSES RECEIVED AFTER THE FRIDAY JUNE 15, 2018 4:00 P.M. CDT DEADLINE WILL NOT BE CONSIDERED.

INCOMPLETE RESPONSES WILL NOT BE CONSIDERED.

RESPONDING TO THIS RFI DOES NOT GUARANTEE THAT A FIRM WILL BE INCLUDED IN THE LIST OF APPROVED FIRMS.

SELECTION AS AN APPROVED FIRM DOES NOT GUARANTEE A TRANSACTION.

ALL TRANSACTIONS ARE COMPETITIVELY BID.

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SUBMISSION CHECKLIST

The following must arrive in the City Treasurer’s Office by Friday June 15, 2018, 4:00 P.M. CDT: Please submit these items in the sequence indicated below.

FORMATTING NOTE: EACH SEGMENT OF THE CHECKLIST MUST BE SEPARATED AND DESIGNATED WITH IDENTIFIABLE TABS OR LABELS. INFORMATION SHOULD BE BOUND OR IN A 3-RING BINDER WITH APPROPRIATE, VISIBLE TABS IN SEQUENCE TO THE LIST. LOOSE PAPERS ARE UNACCEPTABLE.

Submission Checklist

Questionnaire (all pages)

Certification

City of Chicago Economic Disclosure Statement and Affidavit (“EDS”) (Exhibit A)

Scope of City of Chicago Interface (“COC”) (Exhibit B)

Minority Participation Affidavit (Exhibit C)

Certification(s) with dates for MBE, DVBE, WBE as applicable (quest. #3)

Applicant’s policy on equal employment opportunity efforts (quest. #4)

Complete FINRA CRD report(s) for sales coverage (quest. #7)

Sample of Commercial Paper inventory or Firm list of A-1/P-1 issuers (if applicable) (quest. #10)

Copy of your Firm’s most current FOCUS Report (quest. #33)

Copy of your Firm’s most recent certified financial statements (quest. #34)

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Please send the RFI response to the following address:

City Treasurer’s OfficeCity Hall, Room 106121 North LaSalle StreetChicago, IL 60602Attn: Ms. Nancy Candelaria

I understand that failure to submit any of the preceding documents by Friday June 15, 2018, 4:00 p.m. CDT automatically disqualifies my Firm from designation as an approved broker/dealer for the City of Chicago in 2018.

Applicant Firm:      

Signature:      

Name:      

Title:      

Date:      

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QUESTIONNAIRE

FIRM INFORMATION

1. General Firm information:

Name of Firm:      

Headquarters Address:      

Chicago Address(if different):      

Main Telephone Number:      

# of Permanent Chicago Employees:      

2. Please indicate which category describes your Firm (check all that apply):

Primary Dealer

Regional Broker/Dealer

Minority Business Enterprise (“MBE”), Women Business Enterprise (“WBE”), Disabled Veteran Business Enterprise (“DVBE”) Ownership:

African American

Asian

Disabled Veterans

Hispanic

Women

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DIVERSITY AND SOCIAL RESPONSIBILITY

3. Is your Firm certified as a minority-owned, women-owned or disabled-veteran-owned business?

Yes No

If yes, please provide the certification details: The dates of certification and by whom. (Please provide any MBE, WBE or DVB certifications): ATTACHMENT REQUIRED

4. If your Firm is not a women-, minority- or disabled-veteran-owned business, is your Firm a member of any organization that has adopted or recommended procedures to eliminate discrimination, promote fair and equal employment practices, or foster diversity in the workplace?

Yes No N/A

List all such organizations.

1. National Association of Securities Professionals Yes No 2. Securities Industry Association Yes No 3. Women in Public Finance Association Yes No 4. Other       Yes No 5. Other       Yes No

Please provide a copy of your Firm’s Policy on Equal Employment Opportunity efforts.ATTACHMENT REQUIRED

5. Has your Firm implemented any of the Diversity Initiatives recommended by those organizations?

Yes No N/A (Select N/A if WBE, MBE, DVBE designated)

Please explain:      

6. Please provide a statement of community involvement, describing your Firm’s economic development programs, if any, and identifying any cultural, educational, health, social service, civic, community or similar beneficial contributions made by your Firm to the community that it serves.

Please describe:

     

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SALES COVERAGE INFORMATION

7. Identify the primary representative / manager / partner-in-charge of your Firm that would be responsible for the management of the City of Chicago’s account. Include full FINRA CRD reports for sales coverage. ATTACHMENT(S) REQUIRED

Primary Sales Coverage and Sales Partner contact information:

Sales Coverage Sales Coverage Partner (if applicable)

Name:       Name:      

Title:       Title:      Tel. No.:       Tel. No.:      E-mail:       E-mail:      Mobile:       Mobile:      Fax:       Fax:      

Address:       Address:                            

8. Identify all personnel who will be trading with the City of Chicago or quoting prices to our employees.

Name Telephone

                                                                                        

Note: Should coverage for the City of Chicago change within the term of this RFI 2018 period, your Firm must notify CTO immediately of the change and provide us with name(s), contact information, and background information of new coverage via phone and in writing

TRADING PRODUCTS CAPACITY INFORMATION

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9. Which, if any, of the following instruments are offered and/or regularly traded by your trading desks at the institutional level? In addition, please mark as applicable for each position and/or broker:

POSITION / BROKER Green Bonds

Treasury Bills

Treasury Notes

Treasury Bonds

Federal Farm Credit Bureau

Federal Home Loan Bank

Federal Agricultural Mortgage Corporation

Federal National Mortgage Association

Federal Home Loan Mortgage Corporation

Agency Discount Notes At the Window Broker

Commercial Paper Direct with Issuers Broker

Repurchase Agreements

Bankers Acceptances

Certificates of Deposit

Supranational Bonds (e.g., World Bank, IMF)

High Grade Taxable Municipal Bonds

High Grade Corporate Bonds

High Grade U.S. Dollar Denominated Sovereign Bonds

Instrumentalities (specify which):     

Other (specify):     

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10. Attach an Excel export of your Bloomberg BOOM A-1/P-1 270 days commercial paper inventory as of April 30, 2018. ATTACHMENT REQUIRED

If your Firm does not have the ability to buy/sell commercial paper, please check below:

Our Firm does not have A-1/P-1 commercial paper capabilities.

11. List which U.S. Government Agencies with whom you have Window access:

     

12. List which U.S. Government Agencies with whom you are approved for New Issue creation or reverse inquiry:

     

13. Is your Firm willing to bid on securities from the City of Chicago’s portfolio or from other Chicago City Agency portfolios that are managed by CTO traders?

Yes No

SALES COVERAGE ABILITY / EXPERIENCE SELLING CITY OF CHICAGO TREASURER’S OFFICE (“CTO”) INVESTMENT GUIDELINE PRODUCTS

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14. Which of the following instruments are you as the sales professional(s) versed in selling, if any, at the institutional level:NOTE: (This applies to the individual(s) referenced in question #3)

U.S. Treasury Securities

U.S. Government Agency Securities

High Grade Corporate Debt Securities

High Grade Taxable Municipal Securities

High Grade U.S. Dollar Denominated Sovereign Bonds

Supranational Bonds (e.g., World Bank, IMF, IFC)

Other

15. Please indicate if you as the sales professional(s) indicated in question #3 has direct access to either the Bloomberg Professional Terminal or Bloomberg Anywhere.

Yes No

RESEARCH/STRATEGY CAPABILITIES

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16. Does your Firm offer Research and Market Insight Resources to its clients?

Yes No

If yes, please detail. Of interest would be internal credit research analysis on commercial paper and other securities your Firm offers for sale.

     

17. Does your Firm offer any ESG Research Specialties?

Yes No

18. Does your Firm have an in-house strategist?

Yes No

If yes, in what areas? Briefly list.

     

COMPLIANCE/DUE DILIGENCE

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19. Has your Firm been subject to a state or federal regulatory agency investigation for any reason within the last 10 years?

Yes No

If yes, explain:      

20. Has your Firm been found guilty of violating SEC rules or subject to any FINRA enforcements within the last 10 years?

Yes No

If yes, explain:      

21. Has any member of your fixed-income trading desk been subject to a state or federal regulatory agency investigation for any reason within the last 10 years?

Yes No

If yes, explain:      

22. Has any institutional client ever claimed or sustained a loss on a securities transaction arising from a misunderstanding or misrepresentation of the risk characteristics of the investment instrument as represented by your Firm or any of its employees?

Yes No

If yes, explain:      

MUNICIPAL ADVISORY RULE (“MA RULE”) / SECURITIES EXCHANGE ACT OF 1934 (RULE 15BAL ET SEQ.)

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23. The “Municipal Advisory Rule” enacted under the Securities Exchange Act of 1934 (Rule 15Bal et seq.) became effective July 1, 2014. Has this rule affected/changed the way you do business with your public-sector clients that invest bond proceeds?

Yes No

If yes, explain briefly:      

24. Does your Firm segregate or tag accounts hold bond proceeds in your system?

Yes No

If yes, explain briefly:      

OPERATIONS

25. Are calls with clients such as the City of Chicago recorded?

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Yes No

26. What is the name of your Clearing Firm?

     

27. In addition to SIPC protection, do your customers receive any additional insurance coverage?

Yes No

If yes, explain:      

28. In the event of disaster, does your Firm have a contingency plan in place to ensure continued operations in Sales, Trading and Clearing? In addition, how do you notify your clients of any changes in communications and trade settlement (e.g., Super Storm Sandy)?

Please explain:      

29. Provide delivery instructions:

DTC Instructions:      Book Entry Instructions:      Physical Instructions:      

REFERENCES

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30. Please identify 3 comparable Illinois government or Chicago Agency clients that we may contact as references. Client Name

Contact Person

Tel. No.

Client Since

ServicesRendered

                                                                                    

31. Please identify 3 comparable non-Illinois government or Chicago Agency clients that we may contact as references. Client Name

Contact Person

Tel. No.

Client Since

ServicesRendered

                                                                                    

FIRM CAPITAL CAPACITY

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32. What is your Firm Net Capital as of your latest FOCUS Report?

Firm Net Capital: FOCUS Report Date:

33. Provide a complete copy of your Firm’s most current FOCUS Report.

ATTACHMENT REQUIRED

34. Does your Firm comply with the SEC’s net capital adequacy guidelines?

Yes No

If no, explain:      

Attach the three (3) most recent certified financial statements documenting net capital adequacy measured under relevant standards and your most recent unaudited quarterly financial statement. ATTACHMENTS REQUIRED

35. How many times within the past 5 years has your Firm fallen below the SEC’s net capital requirements?

     

36. Describe the capital line and trading limits that support or limit your ability to conduct business with the City of Chicago.     

37. Please indicate (in number of years) how long your Firm has been in operation.

      Years

QUESTIONNAIRE COMPLIANCE

38. Name, title, telephone number and e-mail address of person completing this questionnaire:

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Name :      Title:      Tel. No.:      E-mail:      

39. By executing and delivering the response to this RFI, the broker/dealer named in response to question 1, above, certifies that (1) its registration with the Securities and Exchange Commission (SEC) is active; (2) Form BDW has not been filed; (3) it is a member in good standing with the Securities Investor Protection Corporation; (5) it is a member in good standing with the Securities and Exchange Commission (SEC); (6) it is registered and in good standing as a “dealer” in securities with the Illinois Secretary of State; (7) it is a member in good standing with those exchanges and other self-regulatory organizations (as that term is defined in the Securities Exchange Act of 1934, as amended) listed below; and (8) no adverse actions have been threatened or brought by either the Securities and Exchange Commission or any regulatory organization that could impair its continued membership and good standing with such organizations.

List of additional regulatory organizations:

               

Firm:      

By (signature): Print Name:       Print Title:       Date:      

CERTIFICATION

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I hereby certify that I have personally read the Municipal Code of the City of Chicago, specifying the investment guidelines for the Office of the City Treasurer in Article VI, Investment of City Funds and Municipal Bonds, Chapter 2-32 and the Statement of Investment Policy (“Investment Policy”).

I hereby certify that the Firm named below has reasonable procedures and controls in place to prohibit investment transactions inconsistent with the City of Chicago’s legal restrictions and Investment Policy. Additionally, I certify that procedures are used for keeping all books of account in such a manner as to show with complete accuracy all monies invested on behalf of the Office of the City Treasurer.

If notified in writing of our appointment as a qualified broker/dealer for the City of Chicago, Office of the City Treasurer, we certify that our sales personnel will thoroughly familiarize themselves with the investment objectives, eligible investments, and risk constraints as specified in the Municipal Code of Chicago and the City of Chicago’s Office of the City Treasurer Investment Policy, and pledge to exercise due diligence in disclosing fundamental risks associated with investments presented to the Office of the City Treasurer.

In the event of a material adverse change in the financial condition of our Firm, we will notify the City of Chicago’s Office of the City Treasurer immediately by telephone and in writing.

In the event that our Firm falls below SEC net capital requirements, we will notify the City of Chicago’s Office of the City Treasurer within five business days by both telephone and in writing.

In the event that our Firm changes sales coverage for the City of Chicago’s Office of the City Treasurer within the term of this RFI 2018 period, we will notify City of Chicago’s Office of the City Treasurer immediately of the change and provide them with the name(s), contact information and background information of the new coverage by both telephone and in writing.

Transaction costs will be consistent with prevailing institutional pricing at the time of each transaction.

I attest to the accuracy of all of our responses to the City of Chicago, Office of the City Treasurer, Request for Information (“RFI”), for Selection of Broker/Dealers, for the Year 2018.

Firm Name:      

TO BE SIGNED BY TWO PRINCIPALS OF THE FIRM NAMED ABOVE.

Name:       Name:      

Signature:       Signature:

Title:       Title:      

Date:       Date:      

EXHIBIT A: CITY OF CHICAGO ECONOMIC DISCLOSURE STATEMENT AND AFFIDAVIT

Please complete the Exhibit A beginning on page 21 and submit along with your questionnaire and other required documents.

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EXHIBIT B: SCOPE OF CITY OF CHICAGO INTERFACE

Please complete the Exhibit B beginning on page 32 and submit along with your questionnaire and other required documents.

EXHIBIT C: MINORITY PARTICIPATION AFFIDAVIT

Please review the recently enacted sections 2-154- 018 of the municipal code (referenced below), that requires financial advisors, underwriters, law firms and brokers to complete. As part of our Broker/Dealer RFI approval process, any participating Broker/Dealer will be required to complete the Minority Participation Affidavit as presented as Exhibit C beginning on page 34.

2-154-018 Diversity in firms – Outside brokers.               (a)   (1) Any person providing brokerage services to the city pursuant to a service contract duly executed by the City Treasurer (for purposes of this section, “reporting firm”), shall provide the gender, role and race or ethnicity of those who will directly provide brokerage services to the city. The City Treasurer shall provide the information received pursuant to this subsection (a) to the City Council.                      (2) A reporting firm shall certify the accuracy of the disclosures and information required by this subsection (a). The disclosures and information required by this subsection (a) shall be provided in a form and manner approved by the City Treasurer.               (b) The City Treasurer is authorized to adopt rules and regulations for the proper administration and enforcement of this section.              (c) Any reporting firm that fails to comply with this section may, as determined by the City Treasurer based on objective criteria, be declared ineligible to participate in future brokerage service contracts. EXHIBIT D: SUPPLEMENTAL REFERENCE MATERIALS

Please review Exhibit D and retain for future reference should you become an Approved Firm for the City of Chicago in 2018.

In Exhibit D, you will find the following: Statement of Investment Policy and Guidelines beginning on page 38 Municipal Code of Chicago beginning on page 47

EXHIBIT A: CITY OF CHICAGO ECONOMIC DISCLOSURE STATEMENT AND

AFFIDAVIT

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SECTION I -- GENERAL INFORMATION

A. Legal name of the Disclosing Party submitting this EDS. Include d/b/a/ if applicable:_____________________________________________________

Check ONE of the following three boxes:

Indicate whether the Disclosing Party submitting this EDS is:1. [ ] the Applicant

OR2. [ ] a legal entity holding a direct or indirect interest in the Applicant. State the legal name of the

Applicant in which the Disclosing Party holds an interest: _____________________________OR

3. [ ] a legal entity with a right of control (see Section II.B.1.) State the legal name of the entity inwhich the Disclosing Party holds a right of control: ____________________________

B. Business address of the Disclosing Party: _________________________________________________________________________________________

C. Telephone: _________________ Fax: ___________________ Email: ______________________

D. Name of contact person: ______________________________

E. Federal Employer Identification No. (If you have one): __________________________________

F. Brief description of contract, transaction or other undertaking (referred to below as the "Matter") towhich this EDS pertains. (Include project number and location of property, if applicable):________________________________________________________________________________

G. Which City agency or department is requesting this EDS? _______________________________

If the Matter is a contract being handled by the City’s Department of Procurement Services, please complete the following:

Specification # __________________________ and Contract # __________________________

Ver. 01-01-12

SECTION II -- DISCLOSURE OF OWNERSHIP INTERESTS

A. NATURE OF THE DISCLOSING PARTY

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1. Indicate the nature of the Disclosing Party:[ ] Person [ ] Limited liability company[ ] Publicly registered business corporation [ ] Limited liability partnership[ ] Privately-held business corporation [ ] Joint venture[ ] Sole proprietorship [ ] Not-for-profit corporation[ ] General partnership (Is the not-for-profit corporation also a 501(c)(3))?[ ] Limited partnership [ ] Yes [ ] No[ ] Trust [ ] Other (please specify)

_______________________________________

2. For legal entities, the state (or foreign country) of incorporation or organization, if applicable:__________________________________________

3. For legal entities not organized in the State of Illinois: Has the organization registered to do business in the State of Illinois as a foreign entity?

[ ] Yes [ ] No [ ] N/A

B. IF THE DISCLOSING PARTY IS A LEGAL ENTITY:

1. List below the full names and titles of all executive officers and all directors of the entity.NOTE: For not-for-profit corporations, also list below all members, if any, which are legal entities. If there are no such members, write "no members." For trusts, estates or other similar entities, list below the legal titleholder(s).

If the entity is a general partnership, limited partnership, limited liability company, limited liability partnership or joint venture, list below the name and title of each general partner, managing member, manager or any other person or entity that controls the day-to-day management of the Disclosing Party.NOTE: Each legal entity listed below must submit an EDS on its own behalf.

Name Title________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

2. Please provide the following information concerning each person or entity having a direct or indirect beneficial interest (including ownership) in excess of 7.5% of the Disclosing Party. Examples of such an interest include shares in a corporation, partnership interest in a partnership or joint venture, interest of a member or manager in a limited liability company, or interest of a beneficiary of a trust, estate or other similar entity. If none, state “None.” NOTE: Pursuant to Section 2-154-030 of the

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Municipal Code of Chicago (“Municipal Code”), the City may require any such additional information from any applicant which is reasonably intended to achieve full disclosure.

Name Business Address Percentage Interest in the Disclosing Party

________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

SECTION III -- BUSINESS RELATIONSHIPS WITH CITY ELECTED OFFICIALS

Has the Disclosing Party had a "business relationship," as defined in Chapter 2-156 of the Municipal Code, with any City elected official in the 12 months before the date this EDS is signed?

[ ] Yes [ ] No

If yes, please identify below the name(s) of such City elected official(s) and describe suchrelationship(s):____________________________________________________________________________________________________________________________________________________________

SECTION IV -- DISCLOSURE OF SUBCONTRACTORS AND OTHER RETAINED PARTIES

The Disclosing Party must disclose the name and business address of each subcontractor, attorney, lobbyist, accountant, consultant and any other person or entity that the Disclosing Party has retained or expects to retain in connection with the Matter, as well as the nature of the relationship, and the total amount of the fees paid or estimated to be paid. The Disclosing Party is not required to disclose employees who are paid solely through the Disclosing Party's regular payroll.

“Lobbyist” means any person or entity who undertakes to influence any legislative or administrative action on behalf of any person or entity other than: (1) a not-for-profit entity, on an unpaid basis, or (2) himself. “Lobbyist” also means any person or entity any part of whose duties as an employee of another includes undertaking to influence any legislative or administrative action.

If the Disclosing Party is uncertain whether a disclosure is required under this Section, the Disclosing Party must either ask the City whether disclosure is required or make the disclosure.

Name (indicate whether Business Relationship to Disclosing Party Fees (indicate whetherretained or anticipated Address (subcontractor, attorney, paid or estimated.) NOTE: to be retained) lobbyist, etc.) “hourly rate” or “tbd”

are not acceptable responses

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_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________(Add sheets if necessary)

[ ] Check here if the Disclosing Party has not retained, nor expects to retain, any such persons or entities.

SECTION V -- CERTIFICATIONS

A. COURT-ORDERED CHILD SUPPORT COMPLIANCE

Under Municipal Code Section 2-92-415, substantial owners of business entities that contract with the City must remain in compliance with their child support obligations throughout the contract’s term.

Has any person who directly or indirectly owns 10% or more of the Disclosing Party been declared in arrearage on any child support obligations by any Illinois court of competent jurisdiction?

[ ] Yes [ ] No [ ] No person directly or indirectly owns 10% or more of the Disclosing Party.

If “Yes,” has the person entered into a court-approved agreement for payment of all support owed and is the person in compliance with that agreement?

[ ] Yes [ ] No

B. FURTHER CERTIFICATIONS

1. Pursuant to Municipal Code Chapter 1-23, Article I (“Article I”) (which the Applicant should consult for defined terms (e.g. “doing business”) and legal requirements), if the Disclosing Party submitting this EDS is the Applicant and is doing business with the City, then the Disclosing Party certifies as follows: (i) neither the Applicant nor any controlling person is currently indicted or charged with, or has admitted guilt of, or has ever been convicted of, or placed under supervision for, any criminal offense involving actual, attempted, or conspiracy to commit bribery, theft, fraud, forgery, perjury, dishonesty or deceit against an officer or employee of the City or any sister agency; and (ii) the Applicant understands and acknowledges that compliance with Article I is a continuing requirement for doing business with the City. NOTE: If Article I applies to the Applicant, the permanent compliance timeframe in Article I supersedes some five-year compliance timeframes in certifications 2 and 3 below.

2. The Disclosing Party and, if the Disclosing Party is a legal entity, all of those persons or entities identified in Section II.B.1. of this EDS:

a. is not presently debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from any transactions by any federal, state or local unit of government;

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b. has not, within a five-year period preceding the date of this EDS, been convicted of a criminal offense, adjudged guilty, or had a civil judgment rendered against them in connection with: obtaining, attempting to obtain, or performing a public (federal, state or local) transaction or contract under a public transaction; a violation of federal or state antitrust statutes; fraud; embezzlement; theft; forgery; bribery; falsification or destruction of records; making false statements; or receiving stolen property;

c. is not presently indicted for, or criminally or civilly charged by, a governmental entity (federal, state or local) with committing any of the offenses set forth in clause B.2.b. of this Section V;

d. has not, within a five-year period preceding the date of this EDS, had one or more public transactions (federal, state or local) terminated for cause or default; and

e. has not, within a five-year period preceding the date of this EDS, been convicted, adjudged guilty, or found liable in a civil proceeding, or in any criminal or civil action, including actions concerning environmental violations, instituted by the City or by the federal government, any state, or any other unit of local government.

3. The certifications in subparts 3, 4 and 5 concern:

the Disclosing Party; any “Contractor” (meaning any contractor or subcontractor used by the Disclosing Party in

connection with the Matter, including but not limited to all persons or legal entities disclosed under Section IV, “Disclosure of Subcontractors and Other Retained Parties”);

any "Affiliated Entity" (meaning a person or entity that, directly or indirectly: controls the Disclosing Party, is controlled by the Disclosing Party, or is, with the Disclosing Party, under common control of another person or entity. Indicia of control include, without limitation: interlocking management or ownership; identity of interests among family members, shared facilities and equipment; common use of employees; or organization of a business entity following the ineligibility of a business entity to do business with federal or state or local government, including the City, using substantially the same management, ownership, or principals as the ineligible entity); with respect to Contractors, the term Affiliated Entity means a person or entity that directly or indirectly controls the Contractor, is controlled by it, or, with the Contractor, is under common control of another person or entity;

any responsible official of the Disclosing Party, any Contractor or any Affiliated Entity or any other official, agent or employee of the Disclosing Party, any Contractor or any Affiliated Entity, acting pursuant to the direction or authorization of a responsible official of the Disclosing Party, any Contractor or any Affiliated Entity (collectively "Agents").

Neither the Disclosing Party, nor any Contractor, nor any Affiliated Entity of either the Disclosing Party or any Contractor nor any Agents have, during the five years before the date this EDS is signed, or, with respect to a Contractor, an Affiliated Entity, or an Affiliated Entity of a Contractor during the five years before the date of such Contractor's or Affiliated Entity's contract or engagement in connection with the Matter:

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a. bribed or attempted to bribe, or been convicted or adjudged guilty of bribery or attempting to bribe, a public officer or employee of the City, the State of Illinois, or any agency of the federal government or of any state or local government in the United States of America, in that officer's or employee's official capacity; or

b. agreed or colluded with other bidders or prospective bidders, or been a party to any such agreement, or been convicted or adjudged guilty of agreement or collusion among bidders or prospective bidders, in restraint of freedom of competition by agreement to bid a fixed price or otherwise; or

c. made an admission of such conduct described in a. or b. above that is a matter of record, but have not been prosecuted for such conduct; or

d. violated the provisions of Municipal Code Section 2-92-610 (Living Wage Ordinance).

4. Neither the Disclosing Party, Affiliated Entity or Contractor, or any of their employees, officials, agents or partners, is barred from contracting with any unit of state or local government as a result of engaging in or being convicted of (1) bid-rigging in violation of 720 ILCS 5/33E-3; (2) bid-rotating in violation of 720 ILCS 5/33E-4; or (3) any similar offense of any state or of the United States of America that contains the same elements as the offense of bid-rigging or bid-rotating.

5. Neither the Disclosing Party nor any Affiliated Entity is listed on any of the following lists maintained by the Office of Foreign Assets Control of the U.S. Department of the Treasury or the Bureau of Industry and Security of the U.S. Department of Commerce or their successors: the Specially Designated Nationals List, the Denied Persons List, the Unverified List, the Entity List and the Debarred List.

6. The Disclosing Party understands and shall comply with the applicable requirements of Chapters 2-55 (Legislative Inspector General), 2-56 (Inspector General) and 2-156 (Governmental Ethics) of the Municipal Code.

7. If the Disclosing Party is unable to certify to any of the above statements in this Part B (Further Certifications), the Disclosing Party must explain below:____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

If the letters "N/A," the word "None," or no response appears on the lines above, it will be conclusively presumed that the Disclosing Party certified to the above statements.

8. To the best of the Disclosing Party’s knowledge after reasonable inquiry, the following is a complete list of all current employees of the Disclosing Party who were, at any time during the 12-month period preceding the execution date of this EDS, an employee, or elected or appointed official, of the City of Chicago (if none, indicate with “N/A” or “none”).___________________________________________________________________________________

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______________________________________________________________________________________________________________________________________________________________________

9. To the best of the Disclosing Party’s knowledge after reasonable inquiry, the following is a complete list of all gifts that the Disclosing Party has given or caused to be given, at any time during the 12-month period preceding the execution date of this EDS, to an employee, or elected or appointed official, of the City of Chicago. For purposes of this statement, a “gift” does not include: (i) anything made generally available to City employees or to the general public, or (ii) food or drink provided in the course of official City business and having a retail value of less than $20 per recipient (if none, indicate with “N/A” or “none”). As to any gift listed below, please also list the name of the City recipient.

______________________________________________________________________________________________________________________________________________________________________

C. CERTIFICATION OF STATUS AS FINANCIAL INSTITUTION

1. The Disclosing Party certifies that the Disclosing Party (check one):

[ ] is [ ] is not

a "financial institution" as defined in Section 2-32-455(b) of the Municipal Code.

2. If the Disclosing Party IS a financial institution, then the Disclosing Party pledges:

"We are not and will not become a predatory lender as defined in Chapter 2-32 of the Municipal Code. We further pledge that none of our affiliates is, and none of them will become, a predatory lender as defined in Chapter 2-32 of the Municipal Code. We understand that becoming a predatory lender or becoming an affiliate of a predatory lender may result in the loss of the privilege of doing business with the City."

If the Disclosing Party is unable to make this pledge because it or any of its affiliates (as defined in Section 2-32-455(b) of the Municipal Code) is a predatory lender within the meaning of Chapter 2-32 of the Municipal Code, explain here (attach additional pages if necessary):___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

If the letters "N/A," the word "None," or no response appears on the lines above, it will beconclusively presumed that the Disclosing Party certified to the above statements.

D. CERTIFICATION REGARDING INTEREST IN CITY BUSINESS

Any words or terms that are defined in Chapter 2-156 of the Municipal Code have the same meanings when used in this Part D.

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1. In accordance with Section 2-156-110 of the Municipal Code: Does any official or employee of the City have a financial interest in his or her own name or in the name of any other person or entity in the Matter?

[ ] Yes [ ] No

NOTE: If you checked "Yes" to Item D.1., proceed to Items D.2. and D.3. If you checked "No" to Item D.1., proceed to Part E.

2. Unless sold pursuant to a process of competitive bidding, or otherwise permitted, no City elected official or employee shall have a financial interest in his or her own name or in the name of any other person or entity in the purchase of any property that (i) belongs to the City, or (ii) is sold for taxes or assessments, or (iii) is sold by virtue of legal process at the suit of the City (collectively, "City Property Sale"). Compensation for property taken pursuant to the City's eminent domain power does not constitute a financial interest within the meaning of this Part D.

Does the Matter involve a City Property Sale?

[ ] Yes [ ] No

3. If you checked "Yes" to Item D.1., provide the names and business addresses of the City Officials or employees having such interest and identify the nature of such interest:

Name Business Address Nature of Interest___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

4. The Disclosing Party further certifies that no prohibited financial interest in the Matter will be acquired by any City official or employee.

E. CERTIFICATION REGARDING SLAVERY ERA BUSINESS

Please check either 1. or 2. below. If the Disclosing Party checks 2., the Disclosing Party must disclose below or in an attachment to this EDS all information required by paragraph 2. Failure to comply with these disclosure requirements may make any contract entered into with the City in connection with the Matter voidable by the City.

____1. The Disclosing Party verifies that the Disclosing Party has searched any and all records of the Disclosing Party and any and all predecessor entities regarding records of investments or profits from slavery or slaveholder insurance policies during the slavery era (including insurance policies issued to slaveholders that provided coverage for damage to or injury or death of their slaves), and the Disclosing Party has found no such records.

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____2. The Disclosing Party verifies that, as a result of conducting the search in step 1 above, the Disclosing Party has found records of investments or profits from slavery or slaveholder insurance policies. The Disclosing Party verifies that the following constitutes full disclosure of all such records, including the names of any and all slaves or slaveholders described in those records:____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

SECTION VI -- CERTIFICATIONS FOR FEDERALLY FUNDED MATTERS

NOTE: If the Matter is federally funded, complete this Section VI. If the Matter is not federally funded, proceed to Section VII. For purposes of this Section VI, tax credits allocated by the City and proceeds of debt obligations of the City are not federal funding.

A. CERTIFICATION REGARDING LOBBYING

1. List below the names of all persons or entities registered under the federal Lobbying Disclosure Act of 1995 who have made lobbying contacts on behalf of the Disclosing Party with respect to the Matter: (Add sheets if necessary):

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(If no explanation appears or begins on the lines above, or if the letters "N/A" or if the word "None" appear, it will be conclusively presumed that the Disclosing Party means that NO persons or entities registered under the Lobbying Disclosure Act of 1995 have made lobbying contacts on behalf of the Disclosing Party with respect to the Matter.)

2. The Disclosing Party has not spent and will not expend any federally appropriated funds to pay any person or entity listed in Paragraph A.1. above for his or her lobbying activities or to pay any person or entity to influence or attempt to influence an officer or employee of any agency, as defined by applicable federal law, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress, in connection with the award of any federally funded contract, making any federally funded grant or loan, entering into any cooperative agreement, or to extend, continue, renew, amend, or modify any federally funded contract, grant, loan, or cooperative agreement.

3. The Disclosing Party will submit an updated certification at the end of each calendar quarter in which there occurs any event that materially affects the accuracy of the statements and information set forth in paragraphs A.1. and A.2. above.

4. The Disclosing Party certifies that either: (i) it is not an organization described in section 501(c)(4) of the Internal Revenue Code of 1986; or (ii) it is an organization described in section 501(c)(4) of the Internal Revenue Code of 1986 but has not engaged and will not engage in "Lobbying Activities".

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5. If the Disclosing Party is the Applicant, the Disclosing Party must obtain certifications equal in form and substance to paragraphs A.1. through A.4. above from all subcontractors before it awards any subcontract and the Disclosing Party must maintain all such subcontractors' certifications for the duration of the Matter and must make such certifications promptly available to the City upon request.

B. CERTIFICATION REGARDING EQUAL EMPLOYMENT OPPORTUNITY

If the Matter is federally funded, federal regulations require the Applicant and all proposed subcontractors to submit the following information with their bids or in writing at the outset of negotiations.

Is the Disclosing Party the Applicant?

[ ] Yes [ ] No

If “Yes,” answer the three questions below:

1. Have you developed and do you have on file affirmative action programs pursuant to applicable Federal regulations? (See 41 CFR Part 60-2.)

[ ] Yes [ ] No

2. Have you filed with the Joint Reporting Committee, the Director of the Office of Federal Contract Compliance Programs, or the Equal Employment Opportunity Commission all reports due under the applicable filing requirements?

[ ] Yes [ ] No

3. Have you participated in any previous contracts or subcontracts subject to the equal opportunity clause?

[ ] Yes [ ] No

If you checked “No” to question 1. Or 2. above, please provide an explanation:__________________________________________________________________________________________________________________________________________________________________

SECTION VII -- ACKNOWLEDGMENTS, CONTRACT INCORPORATION, COMPLIANCE, PENALTIES, DISCLOSURE

The Disclosing Party understands and agrees that:

A. The certifications, disclosures, and acknowledgments contained in this EDS will become part of any contract or other agreement between the Applicant and the City in connection with the Matter, whether

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procurement, City assistance, or other City action, and are material inducements to the City's execution of any contract or taking other action with respect to the Matter. The Disclosing Party understands that it must comply with all statutes, ordinances, and regulations on which this EDS is based.

B. The City's Governmental Ethics and Campaign Financing Ordinances, Chapters 2-156 and 2-164 of the Municipal Code, impose certain duties and obligations on persons or entities seeking City contracts, work, business, or transactions. The full text of these ordinances and a training program are available online at www.cityofchicago.org/Ethics, and may also be obtained from the City's Board of Ethics, 740 N. Sedgwick St., Suite 500, Chicago, IL 60610, (312) 744-9660. The Disclosing Party must comply fully with the applicable ordinances.

C. If the City determines that any information provided in this EDS is false, incomplete or inaccurate, any contract or other agreement in connection with which it is submitted may be rescinded or be void or voidable, and the City may pursue any remedies under the contract or agreement (if not rescinded or void), at law, or in equity, including terminating the Disclosing Party's participation in the Matter and/or declining to allow the Disclosing Party to participate in other transactions with the City. Remedies at law for a false statement of material fact may include incarceration and an award to the City of treble damages.

D. It is the City's policy to make this document available to the public on its Internet site and/or upon request. Some or all of the information provided on this EDS and any attachments to this EDS may be made available to the public on the Internet, in response to a Freedom of Information Act request, or otherwise. By completing and signing this EDS, the Disclosing Party waives and releases any possible rights or claims which it may have against the City in connection with the public release of information contained in this EDS and also authorizes the City to verify the accuracy of any information submitted in this EDS.

E. The information provided in this EDS must be kept current. In the event of changes, the Disclosing Party must supplement this EDS up to the time the City takes action on the Matter. If the Matter is a contract being handled by the City’s Department of Procurement Services, the Disclosing Party must update this EDS as the contract requires. NOTE: With respect to Matters subject to Article I of Chapter 1-23 of the Municipal Code (imposing PERMANENT INELIGIBILITY for certain specified offenses), the information provided herein regarding eligibility must be kept current for a longer period, as required by Chapter 1-23 and Section 2-154-020 of the Municipal Code.

The Disclosing Party represents and warrants that:

F.1. The Disclosing Party is not delinquent in the payment of any tax administered by the Illinois Department of Revenue, nor are the Disclosing Party or its Affiliated Entities delinquent in paying any fine, fee, tax, or other charge owed to the City. This includes, but is not limited to, all water charges, sewer charges, license fees, parking tickets, property taxes, and sales taxes.

F.2 If the Disclosing Party is the Applicant, the Disclosing Party and its Affiliated Entities will not use, nor permit their subcontractors to use, any facility listed by the U.S. E.P.A. on the federal Excluded Parties List System ("EPLS") maintained by the U. S. General Services Administration.

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F.3 If the Disclosing Party is the Applicant, the Disclosing Party will obtain from any contractors/subcontractors hired or to be hired in connection with the Matter certifications equal in form and substance to those in F.1. and F.2. above and will not, without the prior written consent of the City, use any such contractor/subcontractor that does not provide such certifications or that the Disclosing Party has reason to believe has not provided or cannot provide truthful certifications.

NOTE: If the Disclosing Party cannot certify as to any of the items in F.1., F.2. or F.3. above, an explanatory statement must be attached to this EDS.

CERTIFICATION

Under penalty of perjury, the person signing below: (1) warrants that he/she is authorized to execute this EDS and Appendix A (if applicable) on behalf of the Disclosing Party, and (2) warrants that all certifications and statements contained in this EDS and Appendix A (if applicable) are true, accurate and complete as of the date furnished to the City.

____________________________________(Print or type name of Disclosing Party)

By: ____________________________________(Sign here)

____________________________________(Print or type name of person signing)

____________________________________(Print or type title of person signing)

Signed and sworn to before me on (date) ____________________,

at ______________ County, _____________ (state).

____________________________________ Notary Public.

Commission expires: _____________________.

EXHIBIT A CONTINUED: CITY OF CHICAGO ECONOMIC DISCLOSURE STATEMENT AND AFFIDAVIT

FAMILIAL RELATIONSHIPS WITH ELECTED CITY OFFICIALS AND DEPARTMENT HEADS

This Appendix is to be completed only by (a) the Applicant, and (b) any legal entity which has a direct ownership interest in the Applicant exceeding 7.5 percent. It is not to be completed by any legal entity which has only an indirect ownership interest in the Applicant.

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Under Municipal Code Section 2-154-015, the Disclosing Party must disclose whether such Disclosing Party or any “Applicable Party” or any Spouse or Domestic Partner thereof currently has a “familial relationship” with any elected city official or department head. A “familial relationship” exists if, as of the date this EDS is signed, the Disclosing Party or any “Applicable Party” or any spouse or domestic partner thereof is related to the mayor, any alderman, the city clerk, the city treasurer or any city department head as spouse or domestic partner or as any of the following, whether by blood or adoption: parent, child, brother or sister, aunt or uncle, niece or nephew, grandparent, grandchild, father-in-law, mother-in-law, son-in-law, daughter-in-law, stepfather or stepmother, stepson or stepdaughter, stepbrother or stepsister or half-brother or half-sister.

“Applicable Party” means (1) all executive officers of the Disclosing Party listed in Section II.B.1.a., if the Disclosing Party is a corporation; all partners of the Disclosing Party, if the Disclosing Party is a general partnership; all general partners and limited partners of the Disclosing Party, if the Disclosing Party is a limited partnership; all managers, managing members and members of the Disclosing Party, if the Disclosing Party is a limited liability company; (2) all principal officers of the Disclosing Party; and (3) any person having more than a 7.5 percent ownership interest in the Disclosing Party. “Principal Officers” means the president, chief operating officer, executive director, chief financial officer, treasurer or secretary of a legal entity or any person exercising similar authority.

Does the Disclosing Party or any “Applicable Party” or any spouse or domestic partner thereof currently have a “familial relationship” with an elected city official or department head?

[ ] Yes [ ] No

If yes, please identify below (1) the name and title of such person, (2) the name of the legal entity to which such person is connected; (3) the name and title of the elected city official or department head to whom such person has a familial relationship, and (4) the precise nature of such familial relationship.__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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EXHIBIT B: SCOPE OF CITY OF CHICAGO INTERFACE

As part of our commitment to this Office and the City of Chicago, we look to better understand how our Broker/Dealer partners and their parent companies interface within our Office, the City of Chicago, its Sister Agencies and pension plans. Please help us by completing the following:

1. Please mark all other services that your Firm currently provides for the City of Chicago:

      Your Firm has an actively staffed Chicago office

      Current Office of the City Treasurer Broker/Dealer portfolio investments

      Current COC municipal depository bank

      Banking services

      Current securities lending approved borrower

      Current securities lending agent

      Bond underwriting

      Bond issuance trustee bank

      Letters of credit

      Swaps

      CRAs

      Purchasing Cards (“P-Cards”)

SSAs

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      TIFs

      Minority outreach

      Affirmative action plans

      Disabled or returning veteran new career training/job opportunities

      Charitable giving

      Financial literacy

      Small business lending

     

     

     

     

     

     

     

    

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2. Briefly describe any other services your Firm currently provides the City of Chicago.

     

3. Does your Firm work with any of our Sister Agencies or Cook County in any financial capacity? Please mark all that apply?

      Chicago Public Schools (“CPS”)      Chicago Housing Authority (“CHA”)      Chicago Transportation Authority (“CTA”)      City Colleges of Chicago (“CCC”)      Chicago Park District (“CPD”)      Cook County of Illinois      Metropolitan Water Reclamation District of Greater Chicago (“MWRDGC”)      Metropolitan Pier & Exposition Authority (“MPEA”)      Public Building Commission (“PBC”)

4. Briefly explain the scope of your Firm’s business for any of the applicable Sister Agencies selected above:

     

5. Does your Firm or your parent company work with any of the following pension plans?Please mark all that apply:

      Municipal Employees’ Annuity and Pension Plan of Chicago (“MEABF”)      Policemen’s Annuity and Benefit Fund of Chicago (“PABF”)      Firemen’s Annuity and Benefit Fund of Chicago (“FABF”)      Chicago Laborers’ Pension and Welfare Funds (“LPWF”)      Chicago Teachers’ Pension Fund (“CTPF”)      Retirement Plan for Chicago Transit Authority Employees (“CTA Pension”)      Park Employees’ Annuity and Benefit Fund (“Park District”)

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      Cook County Pension Fund (“CCPF”)      Cook County Forest Preserve Pension Fund      Metro Water Reclamation District Pension Fund (“MWRD”)      Park Employees’ Annuity and Benefit Fund of Chicago (“Park District Pension”)

Briefly explain the scope of your Firm’s business for any of the applicable pension plans selected above:

     

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EXHIBIT C: MINORITY PARTICIPATION AFFIDAVIT

Name of Reporting Firm:

Description of Matter:

Role of Reporting Firm:

This affidavit is submitted in conjunction with (check one):

a City of Chicago debt obligation transaction (Municipal Code Section 2-154-017) brokerage services for the City Treasurer (Municipal Code Section 2-154-018)

Fill out below (and attach additional sheets using the same format, if necessary), the following information for each person in the Reporting Firm who will directly provide professional services to the City in connection with the matter described above: the individual’s position in the Reporting Firm and the role he or she will fill in the matter, gender, and race or ethnicity. Individuals’ names need not be disclosed.

Individual # Position and Role Gender Race/Ethnicity

            M F

     

            M F

     

            M F

     

            M F

     

            M F

     

(If needed, please use additional sheets to identify additional personnel.)

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By signing below, I represent under penalty of perjury that: (1) I am authorized to act on behalf of the Reporting Firm, and (2) the information in this Affidavit and associated attachments are true, complete, and correct.

By signing below, I understand and acknowledge, on behalf of the Reporting Firm, that failure to accurately and completely supply the information requested herein may result in a declaration of ineligibility to participate in future Matters for the City of Chicago.

Printed Name: ______________________________

Signature: _________________________________

Title: _____________________________________

Date: _____________________________________

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EXHIBIT D: SUPPLEMENTAL REFERENCE MATERIALS

SUPPLEMENTAL REFERENCE MATERIAL A: STATEMENT OF INVESTMENT POLICY AND GUIDELINES

The Municipal Code of Chicago (the “Municipal Code”) authorizes the City Treasurer to invest funds of the City of Chicago (the “City”) in certain authorized classes of securities. All persons involved in the investment of public funds in the Office of the City Treasurer (the “Office”) are to comply with the Municipal Code provisions relating to the deposit and investment of public funds. The purpose of this Statement of Investment Policy and Guidelines (the “Policy”) is to establish cash management and investment guidelines for the Office. This Policy has been prepared in accordance with the Public Funds Investment Act (30 ILCS 235 / 2.5) and the Municipal Code (2-32-515).

1.0 POLICYThe Office is responsible for the management of daily receipt and investment of cash and related accounting operations. The City Treasurer is the Chief Investment Officer of the City and investments may be directed by the City Treasurer, his designee, or outside professional fund managers, in accordance with this Policy. It is the policy of the City Treasurer to invest all funds under the Office’s control in a manner that provides the highest investment return using authorized instruments while meeting the City’s daily cash flow demands in conformance with the Municipal Code.

2.0 SCOPE OF POLICYThis Policy applies to all investments held within the Office and made on behalf of the City Treasurer with the exception of certain bond funds for which the City may specifically authorize other allowable investments consistent with applicable bond ordinance, trust indenture, the Municipal Code or State law.

3.0 OBJECTIVESThe primary objective in the investment of City funds under control of the City Treasurer is to ensure the safety of principal, while managing liquidity requirements of debt service and other financial obligations of the City, providing the highest investment return using authorized investment instruments, and promoting economic development in the City.

3.1 Safety. The safety of principal is the foremost objective of the investment program. City investments shall be undertaken in a manner that seeks to ensure the preservation of capital in the portfolio. To attain this objective, diversification is required to ensure that the City Treasurer prudently manages market, interest rate and credit risk. Each investment purchase shall be limited to those defined as eligible under the Municipal Code.

3.2 Liquidity. The investment portfolio shall remain sufficiently liquid to enable the City to meet all operating requirements that might be reasonably anticipated. Except as otherwise authorized by the Municipal Code or other applicable law, all investments shall be fully payable as to principal and interest within ten years from the date of purchase.

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3.3 Return on Investments. The investment portfolio shall be designed to obtain the highest available return, taking into account the City Treasurer’s investment risk constraints and cash flow needs. The City Treasurer shall seek to obtain the highest available return using authorized investments.

3.4 Economic Development and local considerations. The City Treasurer seeks to promote economic development in the City through various programs that provide incentives for community reinvestment and financial assistance.

4.0 PRUDENCETo accomplish the objectives of the City Treasurer, all authorized persons engaged in the investment process will perform their duties responsibly in accordance with the following standard:

“Investments shall be made with care, skill, prudence, and diligence under the circumstances then prevailing, specifically including, but not limited to, the general economic conditions and the anticipated needs of the City and the Board of Education of the City, Policemen’s Annuity and Benefit Fund, Firemen’s Annuity and Benefit Fund, Municipal Employees’ Annuity and Benefit Fund, and Laborers’ and Retirement Board Employee’s Annuity and Benefit Fund (“Depositors”), that a prudent person acting in a like capacity and familiarity with those matters would use in the conduct of funds of like character and with like aims, to safeguard the principal and maintain the liquidity needs of the City and the Depositors.”

The standard of prudence to be used by the Office’s investment officers shall be the “prudent investor” standard and shall be applied in the context of managing an overall portfolio. Investment officers shall: (i) act in accordance with written procedures and this Policy, (ii) exercise due diligence, (iii) prepare all reports in a timely fashion, and (iv) exercise appropriate action to control adverse developments.

5.0 OPERATIONAL GUIDELINES5.1 Particular Fund Investments. The Municipal Code requires that any investments of a particular segregate fund be credited to that fund. Principal and interest shall be credited to the particular segregate fund so invested. The City Treasurer and Comptroller jointly may transfer ownership of any security purchased with monies of a particular segregate fund to the aggregate fund in the City Treasury. The particular segregate fund originally invested shall be credited with the amount of the principal and accrued interest up to the date of the transfer of ownership of such security from the particular segregate fund to the aggregate fund.

5.2 Government Fund Accounting. The City financial record-keeping system is operated and maintained on a fund accounting basis. A Fund is an independent fiscal accounting entity with a separate set of accounting records to record cash and investment activities. Funds are either segregate or aggregate, as determined by law, special regulation, or contractual agreement. The Comptroller determines the classification of Funds in either segregate or aggregate category and City Treasurer’s records are prepared accordingly.

Funds classified as “segregate” by the Comptroller or the City Treasurer require that separate accounts be established related to all financial resources, investment and payment requirements. Generally, these segregate funds represent financial resources employed for specified governmental projects and are for restricted use. The Office is required and does maintain a cash and investment

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record of the segregated accounts and has monies available to pay obligations under segregate funds when due. Generally, debt service payments and investments are made through the trust accounts provided for these funds and coordinated by the Office. All other receipts and cash not allocated by law or contractual agreement and used to pay the City’s general operating expenses are pooled for investment and classified as aggregate funds. The City Treasurer disburses these operating funds on a daily basis to cover warrants issued by the City Comptroller. The Corporate (General) fund is the aggregate major operating fund of the City. All general tax revenues and ordinary receipts are aggregated into this fund. Disbursements are based on spending plans of the City departments and include items such as employee payroll and health benefit costs and operating expenditures.

5.3 Competitive Bidding: For investment transactions made by the Office, bids/quotes and markups or discounts need to be consistent with prevailing institutional trades at the time of each transaction and are to be compared to market quotations for the same type and maturity investment on the Bloomberg independent market quotation information service or a comparable service available in the Office. In certain exigent circumstances, the Office need not solicit competitive bids. The guiding principle with choosing any bid for any investment transaction made by the Office is the quality of the bid and the assurance that the bidder can complete the investment transaction.

5.4 Sale of Securities: Section 2-32-580 of the Municipal Code provides that “The comptroller and City Treasurer may sell a security prior to maturity at such price that the comptroller and City Treasurer shall deem advisable including at, above or below the purchase price of the security when in the determination of the comptroller and City Treasurer the sale of the security is necessary to: (1) ensure sufficient amount of money on hand when the balance of cash in the City treasury has for any reason become less than the amount necessary for immediate use; (2) enhance the overall portfolio yield; (3) minimize further erosion and loss of investment principal; or (4) minimize the City’s exposure to market and credit risks.

The City Treasurer shall cooperate with the comptroller in the cancellation and reissue of tax warrants sold in such a way that no duplication thereof shall take place.”

6.0 ETHICS AND CONFLICT OF INTERESTIt is the policy of the Office and in compliance with Section 2-156-080 of the Municipal Code that no person acting on behalf of the investment function in the Office shall, in any manner, have any interest, either directly or indirectly, in any investments in which the Office is authorized to invest; or receive in any manner, compensation of any kind, from any investments from the sellers, sponsors or managers of such investments. Investment officers and other staff involved in the investment process shall refrain from personal business activity that could conflict with proper execution of the investment program, or which could impair their ability to make impartial investment decisions. The City’s Governmental Ethics Ordinance, Chapter 2-156 and State law limit the gifts that employees, officials, their spouses, and /or their minor children can accept from persons who have an interest in city business.

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7.0 AUTHORIZED BROKER/ DEALERS AND QUALIFIED INSTITUTIONSThe City Treasurer will maintain a list of broker/dealers authorized to provide investment services in the City. In addition, a list will be maintained of approved financial institutions authorized to provide investment services. No public deposits shall be made except in municipal depositories approved by City Council.

Depositories. Section 2-32-400 of the Municipal Code allows only regularly organized state or national banks insured by the Federal Deposit Insurance Corporation (“FDIC”) and federal and state savings and loan associations insured by Savings Association Insurance Fund of the FDIC to be designated as possible municipal depositories. Depository institutions should be economically viable and have practices that would not impair the safety of investments.

Broker/Dealer. The Office has a Request for Information (RFI) questionnaire to facilitate annual qualification of each broker/dealer interested in working with the City investments. The Office evaluates interested broker/dealers on the basis of criteria set by the City Treasurer, including the firm’s prior experience, financial stability, and other requirements deemed necessary by the Office, the Municipal Code or other applicable government agencies. The Office on an annual basis notifies brokers/dealers of their approval in writing. The City Treasurer maintains relationships with qualified members of the broker/dealer community who understand the permitted investment constraints and goals of the Office. No broker/dealer or financial institution may present investments to the City Treasurer unless it has signed a sworn certification serving as an affidavit that the institution understands the eligible investment securities that can be purchased for the City. Only broker/dealers with offices located in the City are used to transact business for the City investment accounts.

8.0 AUTHORIZED INVESTMENTSThe City Treasurer has authorized the following types of investments subject to the provisions of Section 2-32-520 of the Municipal Code:

1. Interest-bearing general obligations of the United States and the State of Illinois;2. United States treasury bills and other non-interest bearing general obligations of the United

States or United States government agencies when offered for sale at a price below the face value of same, so as to afford the City a return on such investment in lieu of interest;

3. Tax anticipation warrants, municipal bonds, notes, commercial paper or other instruments representing a debt obligation issued by the City of Chicago;

4. Commercial paper which: (1) at the time of purchase, is rated in the two highest classifications by at least two accredited ratings agencies; (2) matures not more than 270 days after the date of purchase;

5. Reverse repurchase agreement (1) if the term does not exceed 90 days (2) and the maturity of the investment acquired with the proceeds of the reverse repurchase agreement does not exceed the expiration date of the reverse repurchase agreement: and (3) at the time of purchase, the total amount of the reverse repurchase agreement held in all funds does not exceed 5 percent of the total holdings across all funds. Reverse repurchase agreements may be transacted with primary dealers and financial institutions, provided the City has on file a master repurchase agreement;

6. Certificates of deposit of banks or savings and loan associations designated as municipal depositories which are insured by federal deposit insurance; provided that any amount of the deposit in excess of the federal deposit insurance shall be either: (1) fully collateralized at least

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102 percent by: (i) marketable U.S. government securities marked to market at least monthly; (ii) bonds, notes, or other securities constituting the direct and general obligation of any agency or instrumentality of the United States; or (iii) bonds, notes or other securities constituting a direct and general obligation of any county, township, city, village, incorporated town, municipal corporation, or school district, of the State of Illinois or of any other state, or of any political subdivision or agency of the State of Illinois or any other state which are rated in either the AAA or AA rating categories by at least two accredited ratings agencies and maintaining such rating during the term of such investments; (2) secured by a corporate surety bond issued by an insurance company licensed to do business in Illinois and having a claims-paying rating in the top rating category as rated by a nationally recognized statistical rating organization and maintaining such rating during the term of such investment; or (3) fully collateralized at least 102 percent by an irrevocable letter of credit issued in favor of the City of Chicago by the Federal Home Loan Bank, provided that the Federal Home Loan Bank’s short-term debt obligations are rated in the highest rating category by at least one accredited ratings agency throughout the term of the certificate of deposit;

7. Bankers’ acceptance of banks whose senior obligations, at the time of purchase, are rated in the AAA or AA rating categories by at least two accredited ratings agencies;

8. Tax-exempt securities exempt from federal arbitrage provisions applicable to investments of proceeds of the City’s tax-exempt debt obligations;

9. Domestic money market mutual funds regulated by and in good standing with the Securities and Exchange Commission; provided that such money market funds’ portfolios are limited to investments authorized by this section;

10. Any other suitable investment instrument permitted by state laws governing municipal investments generally, subject to the reasonable exercise of prudence in making investments of public funds;

11. Except where otherwise restricted or prohibited, a non-interest-bearing savings account, non-interest-bearing checking account or other non-interest-bearing demand account established in a national or state bank, or a federal or state savings and loan association, when, in the determination of the Treasurer, the placement of such funds in the non-interest-bearing account is used as compensating balances to offset fees associated with that account that will result in cost savings to the City;

12. (1) Bonds of companies organized in the United States with assets exceeding $1 billion that, at the time of purchase, are rated not less than two ratings above investment grade, or equivalent rating, by at least two accredited ratings agencies. Investments authorized by this subsection (1) shall, at the time of purchase, not exceed 35 percent of the total holdings across all funds (with no more than 35 percent of the total portfolio authorized by this subsection (12)(1) invested in any one market sector, out of a total market sector pool consisting of finance, energy, technology, consumer products, manufacturing, healthcare and transportation), and the maturity shall not exceed 30 years; (2) Bonds authorized by subsection (12)(1) where the principal is guaranteed with underlying assets such as bonds, currencies, and commodities. Bonds authorized by this subsection (1)(2) shall, at the time of purchase, not exceed 5 percent of the total holdings across all funds;

13. Debt instruments of international financial institutions, including but not limited to the World Bank and the International Monetary Fund, that, at the time of purchase, are rated within 4 intermediate credit ratings of the United States sovereign credit rating by at least two accredited ratings agencies, but not less than an A- rating, or equivalent rating. Investments authorized by

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this subsection (13) shall, at the time of purchase, not exceed 10 percent of the total holdings across all the funds, including principal and interest, and the maturity shall not exceed 10 years. For purposes of this subsection (13), an “international financial institution” means a financial institution that has been established or chartered by more than one country and the owners or shareholders are generally national governments or other international institutions such as the United Nations;

14. United States dollar denominated debt instruments of foreign sovereignties that, at the time of purchase, are rated within four intermediate credit ratings of the United States sovereign credit rating by at least two accredited ratings agencies, but not less than an A- rating, or equivalent rating. The investments authorized by this subsection (N) shall, at the time of purchase, not exceed five percent of the total holdings across all funds, and the maturity shall not exceed 30 years;

15. Interest-bearing bonds of any country, township, city, village, incorporated town, municipal corporation, or school district, of the State of Illinois, of any other state, or of any political subdivision or agency of the State of Illinois or of any other state, whether the interest earned thereon is taxable or tax-exempt under federal law. The bonds shall be registered in the name of the City or held under a custodial agreement at a bank. The bonds shall be rated, at the time of purchase, not less than A-, or equivalent rating, by at least two accredited rating agencies with nationally recognized expertise in rating bonds of states and their political subdivisions, The bonds authorized by this subsection shall, at the time of purchase: (1) not have a maturity of more than 30 years from the date of purchase; and (2) not exceed 25 percent of the total holdings across all funds; provided that bonds linked to infrastructure projects shall not exceed 5 percent of the total holdings across all funds

16. Bonds registered and regulated by the Security and Exchange Commission and for which the full faith and credit of the State of Israel is pledged for payment; provided that the bonds have an A- rating or above or equivalent rating by at least two accredited ratings agencies. The bonds authorized by this subsection (P) shall, at the time of purchase, not exceed 1 percent of the total holdings across all funds, and the maturity shall not exceed 30 years.

17. Bonds, notes, debentures, or other similar obligations of agencies of the United States rated, at the time of purchase, no less than AAA by at least two accredited rating agencies.

18. Interests in the Chicago Community Catalyst Fund (“CCCF”) as established by Section 2-32-622 of the Municipal Code that inure to the benefit of neighborhood economic development while generating returns that are commensurate with the City’s overall investment portfolio returns.

(1) For the purposes of this subsection, the following definitions shall apply:

“Annual Limit” shall mean the positive difference, if any, between the actual amount of investment earnings for the prior year on funds in the Corporate Fund not subject to Other Investment Restrictions and the budgeted amount of such investment earnings.

“Eligible Funds” shall mean: (1) any City funds the Treasurer is authorized to invest which are not subject to Other Investment Restrictions as determined jointly by the Comptroller and the Treasurer; and (2) any funds in the Corporate Fund or in the Service Reserve and Concession Fund, in either case which are subject to Other Investment Restrictions but only to the extent permitted by the applicable Other Investment Restrictions. Eligible Funds shall not include any proceeds of City debt obligations or any monies in any City enterprise fund.

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“Other Investment Restrictions” shall mean restrictions on eligible investments for City funds pursuant to federal law, state law, City ordinances (other than this section), or existing City contracts as determined jointly by the Comptroller and the Treasurer.

(2) Commencing in 2019, in each year, Eligible Funds may be transferred to the CCCF from time to time, provided that the aggregate amount of such transfers during a year shall not exceed the Annual Limit for such year.

All securities so purchased, excepting the bond authorized in subsection (15), investments authorized in subsection (18) and the tax anticipation warrants, municipal bonds, notes, commercial paper or other instruments representing a debt obligation of the city purchased under subsection (3), shall show on their face that they are fully payable as to principal and interest, where applicable, if any, within 30 years from the date of purchase.

9.0 INVESTMENT RESTRICTIONSExcept as provided in section 8.0, subsection (12)(2), neither the Comptroller nor Treasurer shall have authority, without the approval of the City Council, to (i) invest in financial agreements whose returns are linked to or derived from the performance of some underlying asset such as bonds, currencies or commodities products, or (ii) borrow against or otherwise obligate City investments, other than for purposes of a security lending transaction conducted under Section 2-32-575 of the Municipal Code.

10.0 MINIMUM CREDIT QUALITYExclusive of investments made pursuant to Section 2-32-520(r), the total holdings across all funds held by the Treasurer shall have no less than an overall average rating of Aa1 on a quarterly basis, as rated by two accredited rating agencies.

11.0 COLLATERALIZATIONIn order to protect the City public fund deposits, depository institutions are to maintain collateral pledges on City deposits and certificates of deposit during the term of the deposit.

Certificates of deposit of banks or savings and loan associations designated as municipal depositories which are insured by federal deposit insurance; provided that any amount of the deposit in excess of the federal deposit insurance shall be either: (1) fully collateralized at least 102 percent by: (i) marketable U.S. government securities marked to market at least monthly; (ii) bonds, notes, or other securities constituting the direct and general obligation of any agency or instrumentality of the United States; or (iii) bonds, notes or other securities constituting a direct and general obligation of any county, township, city, village, incorporated town, municipal corporation, or school district, of the State of Illinois or of any other state, or of any political subdivision or agency of the State of Illinois or any other state which are rated in either the AAA or AA rating categories by at least two accredited ratings agencies and maintaining such rating during the term of such investments; (2) secured by a corporate surety bond issued by an insurance company licensed to do business in Illinois and having a claims-paying rating in the top rating category as rated by a nationally recognized statistical rating organization and maintaining such rating during the term of such investment; or (3) fully collateralized at least 102 percent by an irrevocable letter of credit issued in favor of the City of Chicago by the Federal Home Loan Bank,

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provided that the Federal Home Loan Bank’s short-term debt obligations are rated in the highest rating category by at least one accredited ratings agency throughout the term of the certificate of deposit.

Repurchase agreements must also be collateralized in an amount of 102 percent of market value of principal and accrued interest. Collateral pledged for repurchase agreements shall be marked to market at least weekly during the term of the agreement. Additional collateral will be required when the ratio falls below the level required.

The collateral required to secure City funds must be held in safekeeping and pursuant to collateral agreements which would prohibit release or substitution of pledged assets without proper written notification and authorization of the City Treasurer. The final maturity of acceptable collateral pledged shall not exceed 120 months.

12.0 SAFEKEEPING AND CUSTODYAll securities and collateral will be held by a third-party custodian designated by the City Treasurer and evidenced by safekeeping receipts. Safekeeping will be documented by a written agreement, in the form of a safekeeping agreement, trust agreement, escrow agreement or custody agreement.

13.0 DIVERSIFICATIONA variety of financial instruments and maturities, properly balanced, will help to ensure liquidity and reduce risk or interest rate volatility and loss of principal. Diversifying investments and maturities will avoid incurring unreasonable risks in the investment portfolio regarding specific security types, issuers or individual financial institutions.

14.0 INTERNAL CONTROLSThe City Treasurer, as the Chief Investment Officer, shall maintain a system of internal controls and written operational procedures that shall be documented. The controls shall be designed to prevent the loss of public funds arising from fraud, employee error, and misrepresentation by third parties, unanticipated changes in financial markets or imprudent actions by authorized investment officers.In addition, the City Treasurer has established a system of internal controls to ensure that staff positions and functional duties are adequately segregated for separation of duties between the investment and accounting operations.

These controls shall be tested and reviewed periodically by external auditors during the audit.

15.0 TRAININGThose persons under the supervision of the Treasurer who are authorized to execute investment transactions shall attend at least one investment training session within twelve (12) months after assuming their duties and shall receive not less than ten (10) hours of instruction relating to investment responsibilities during a two-year period that begins on the first day of the City’s fiscal year following the initial ten (10) hours of instruction and consists of the two consecutive fiscal years after that date.  The Treasurer is authorized to engage an independent third party with no preexisting contractual relationship with the Office to provide this training, which shall include education in investment controls, security risks, market risks, diversification of investment portfolio and compliance with applicable laws.  Any failure to comply with section 2-32-615 of the Municipal Code shall not invalidate any investment transaction undertaken by any person under the supervision of the Treasurer.

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16.0 PERFORMANCE EVALUATIONThe City Treasurer will utilize the average three-month U.S. Treasury Bill return or other appropriate benchmarks to determine whether market average yields are being achieved.

17.0 TREASURER’S REVIEWS AND REPORTS RESERVED.1. The treasurer shall conduct a review on a monthly basis of the current total holdings across all

funds, including cash positions, portfolios, mark to market valuations, credit quality for each security, and additional compliance issues.

2. The treasurer shall, on or before the first day of February of each year, submit a report to the city council that details the performance of the total holdings across all funds held by the treasurer’s office, including asset allocation, cash position and overall credit quality as of December 31 of the preceding year.

3. The treasurer shall, on or before the first day of February of each year, submit a report to the city council on the written investment policy for compliance as of December 31 of the preceding year, and present any recommendations for changes.

18.0 PERIODIC REVIEWAn annual independent audit and review of the Office’s books and records will be performed to evaluate the nature of overall portfolio investment activities and to verify invested funds. The independent audit review will also examine procedures and written guidelines and established internal control mechanisms to ensure compliance with the objectives of this Policy.

19.0 MINORITY-OWNED FINANCIAL INSTITUTIONSWhen investing or depositing public funds, each custodian for the City Treasurer shall, to the extent permitted by the Public Funds Investment Act (30 ILCS 235) and by the lawful and reasonable performance of his or her custodial duties, invest or deposit such funds with or in minority-owned financial institutions within the City.

20.0 HUMAN RIGHTSIt is the policy of the City Treasurer and in compliance with Section 2-160-030 of the Municipal Code that discrimination on the basis of race, color, religion, age, national origin, gender, sexual orientation, ancestry, disability, marital status, parental status, source of income or military discharge status will not be tolerated.

21.0 POLICY ADOPTION AND AMENDMENTThis Policy may be reviewed from time to time and amended by the City Treasurer and shall be consistent with the provisions of the Municipal Code pertaining to investments. Copies of the written policy and any amendments thereto shall be kept on file with the city clerk and the comptroller, and shall be submitted annually, or if amended, no later than 30 days after such amendment, to the chairman of the city council on finance and the chief investment officer.

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SUPPLEMENTAL REFERENCE MATERIAL B: MUNICIPAL CODE OF THE CITY OF CHICAGO

ARTICLE VI. - INVESTMENT OF CITY FUNDS AND MUNICIPAL BONDS

2-32-515 Investment policy.The treasurer shall adopt a written investment policy which shall address the safety of the principal, liquidity of funds and return on investment. The policy shall be consistent with the provisions of this Code pertaining to investments. Subject to the requirements of this section, the treasurer may amend the written policy from time to time. Copies of the written policy and any amendments thereto shall be kept on file with the city clerk and the comptroller, and shall be submitted annually, or if amended, no later than 30 days after such amendment, to the chairman of the city council on finance and the chief financial officer.

(Added Coun. J. 1-11-05, p. 40561, § 2)

2-32-520 Authorized classes of securities.The comptroller and treasurer jointly shall have authority to use any and all funds in the city treasury which are set aside for use for particular purposes and not immediately necessary for such purposes, for the purchase of the following classes of securities:   (a)   Interest-bearing general obligations of the United States and the State of Illinois;   (b)   United States treasury bills and other non-interest bearing general obligations of the United States or United States government agencies when offered for sale at a price below the face value of same, so as to afford the city a return on such investment in lieu of interest;   (c)   Tax anticipation warrants, municipal bonds, notes, commercial paper or other instruments representing a debt obligation issued by the City of Chicago;   (d)   Commercial paper which: (1) at the time of purchase, is rated in the highest classification by at least two accredited ratings agencies; and (2) matures not more than 270 days after the date of purchase;   (e)   Reverse repurchase agreements if the term does not exceed 90 days and the maturity of the investment acquired with the proceeds of the reverse repurchase agreement does not exceed the expiration date of the reverse repurchase agreement.  Reverse repurchase agreements may be transacted with primary dealers and financial institutions, provided that the city has on file a master repurchase agreement;   (f)   Certificates of deposit of banks or savings and loan associations designated as municipal depositories which are insured by federal deposit insurance; provided that any amount of the deposit in excess of the federal deposit insurance shall be either: (1) fully collateralized at least 102 percent by: (i) marketable United States government securities marked to market at least monthly; (ii) bonds, notes, or other securities constituting the direct and general obligation of any agency or instrumentality of the United States; or (iii) bonds, notes or other securities constituting a direct and general obligation of any county, township, city, village, incorporated town, municipal corporation, or school district, of the State of Illinois, of any other state, or of any political subdivision or agency of the State of Illinois or of any other state which are rated in either the AAA or AA rating categories by at least two accredited ratings agencies and maintaining such rating during the term of such investment; or (2) secured by a corporate surety bond issued by an insurance company licensed to do business in Illinois and having a claims-paying rating in the top rating category as rated by a nationally recognized statistical rating organization and maintaining such rating during the term of such investment; or (3) fully collateralized at least 102 percent by an irrevocable letter of credit issued in favor of the City of Chicago by the Federal Home

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Loan Bank, provided that the Federal Home Loan Bank's short-term debt obligations are rated in the highest rating category by at least one accredited ratings agency throughout the term of the certificate of deposit;   (g)   Bankers’ acceptance of banks whose senior obligations, at the time of purchase, are rated in either the AAA or AA rating categories by at least two accredited ratings agencies;   (h)   Tax-exempt securities exempt from federal arbitrage provisions applicable to investments of proceeds of the city's tax-exempt debt obligations;   (i)   Domestic money market mutual funds regulated by and in good standing with the Securities and Exchange Commission; provided that such money market mutual funds' portfolios are limited to investments authorized by this section;   (j)   Any other suitable investment instrument permitted by state laws governing municipal investments generally, subject to the reasonable exercise of prudence in making investments of public funds;   (k)   Except where otherwise restricted or prohibited, a non-interest-bearing savings account, non- interest-bearing checking account or other non-interest bearing demand account established in a national or state bank, or a federal or state savings and loan association, when, in the determination of the treasurer, the placement of such funds in the non-interest bearing account is used as compensating balances to offset fees associated with that account that will result in cost savings to the city;   (l)   Bonds of companies organized in the United States with assets exceeding $500 million that, at the time of purchase, are rated within 4 intermediate credit ratings of the United States’ sovereign credit rating by at least two accredited ratings agencies, but not less than an A-rating, or equivalent rating.  Investments authorized by this subsection (l) shall, at the time of purchase, not exceed 15 percent of the total holdings across all the funds, including principal and interest, and the maturity shall not exceed 10 years;   (m)   Debt instruments of international financial institutions, including but not limited to the World Bank and the International Monetary Fund, that, at the time of purchase, are rated within four intermediate credit ratings of the United States' sovereign credit rating by at least two accredited ratings agencies, but not less than an A-rating, or equivalent rating.  Investments authorized by this subsection (m) shall, at the time of purchase, not exceed 10 percent of the total holdings across all the funds, including principal and interest, and the maturity shall not exceed 10 years.  For purposes of this subsection (m), an “international financial institution” means a financial institution that has been established or chartered by more than one country and the owners or shareholders are generally national governments or other international institutions such as the United Nations;   (n)   United States dollar denominated debt instruments of foreign sovereignties that, at the time of purchase, are rated within four intermediate credit ratings of the United States’ sovereign credit rating by at least two accredited ratings agencies, but not less than an A-rating or equivalent rating.  The investments authorized by this subsection (n) shall, at the time of purchase, not exceed 5 percent of the total holdings across all funds, including principal and interest and the maturity shall not exceed 10 years;   (o)   Interest-bearing bonds of any county, township, city, village, incorporated town, municipal corporation, or school district, of the State of Illinois, of any other state, or of any political subdivision or agency of the State of Illinois or of any other state, whether the interest earned thereon is taxable or tax-exempt under federal law.  The bonds shall be registered in the name of the city or held under a custodial agreement at a bank. The bonds shall be rated, at the time of purchase, within four intermediate credit ratings of the United States’ sovereign credit rating by at least two accredited rating agencies with nationally recognized expertise in rating bonds of states and their political subdivisions, but not less than

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an A-rating or equivalent rating.  The maturity of the bonds authorized by this subsection (o) shall, at the time of purchase, not exceed 10 years; provided that a longer maturity is authorized if the city has a put option to tender the bonds within 10 years from the date of purchase;   (p)   Bonds registered and regulated by Security Exchange Commission and for which the full faith and credit of the State of Israel is pledged for payment of principal and interest; provided that the bonds have an A-rating or above or equivalent rating by at least two accredited ratings agencies.  The bonds authorized by this subsection (p) shall, at the time of purchase, not exceed 1 percent of the total holdings across all funds, including principal and interest, and the maturity shall not exceed 10 years.

All securities so purchased, excepting the bonds authorized in subsection (o) and tax anticipation warrants, municipal bonds, notes, commercial paper or other instruments representing a debt obligation of the city purchased under subsection (c), shall show on their face that they are fully payable as to principal and interest, where applicable, if any, within 10 years from the date of purchase. Neither the comptroller nor treasurer shall have authority, without the approval of the city council, to (i) invest in financial agreements whose returns are linked to or derived from the performance of some underlying asset such as bonds, currencies or commodities, or (ii) borrow against or otherwise obligate city investments for the purpose of investment, other than for purposes of a security lending transaction conducted under Section 2-32-575.

(Prior code § 7-41; Amend Coun. J. 1-11-91, p. 28759; Amend Coun. J. 7-29-92 p. 19377; Amend Coun. J. 12-21-94, p. 63416; Amend Coun. J. 11-5-03, p. 9539, § 1; Amend Coun. J. 11-7-07, p. 12472, § 1; Amend Coun. J. 11-3-10, p. 103032, § 1; Amend Coun. J. 10-5-11, p. 7950, § 1; Amend Coun. J. 11-15-12, p. 40470, § 1; Amend Coun. J. 2-5-14, p. 73625, § 1)

2-32-530 Investments from particular funds.Whenever it is deemed advisable by the comptroller and treasurer jointly to invest a particular fund, or any portion thereof, in any of the securities provided for by this chapter, or when the same is ordered by the city council, the comptroller and treasurer may make such investment for and on account of such particular fund. In such event the interest, when it becomes due, and the principal, when the same matures and is collected, shall be turned over to the credit of such particular fund so invested.

To the extent that any such particular fund is so invested, it shall not share in the pro rata distribution of interest which may accrue to the aggregate of the funds used for the purchase of securities as herein provided for; provided, however, that such particular fund, as to the surplus which may remain therein after such investment, shall be entitled to its pro rata share of the interest which may accrue to the aggregate of the funds used as aforesaid.

(Prior code § 7-42)

2-32-540 Investments from aggregate of funds.Any securities that may be in the custody of the city treasurer as a result of purchases made with monies of any particular funds, may be held by the treasurer as an investment from the aggregate of funds available in the city treasury, in accordance with the provisions of this chapter, if the comptroller and treasurer jointly deem it advisable to so change the ownership of same or any portion thereof. In case such change is so determined upon, the particular fund originally invested shall be credited with the

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amount of the principal and accrued interest up to the date of the transfer of the ownership of such securities from the particular fund to the aggregate of funds in the city treasury.

(Prior code § 7-43)

2-32-550 Investments in tax warrants.In all cases where warrants in anticipation of taxes have been duly authorized and the comptroller shall find it necessary or expedient to sell them, or any portion thereof, the comptroller may turn such tax warrants over to the treasurer. Thereupon the treasurer shall purchase the same out of the aggregate of funds held in the city treasury to the extent that such may be invested without reducing the balance on hand below the amount immediately necessary to meet warrants drawn on the city treasury in the regular course of business.

(Prior code § 7-44)

2-32-570 Custody of securities.All securities purchased under the authority herein granted, unless resold or canceled and reissued for purposes of resale as herein provided for, shall be held in the custody of the treasurer until the principal and interest shall have been entirely paid and placed to the credit of the various funds or the particular fund from which the money has been withdrawn as authorized by this chapter.(Prior code § 7-45)

2-32-575 Lending securities. (a)   The comptroller and city treasurer jointly may lend securities in the city treasury to a borrower upon such terms and conditions as may be mutually agreed in writing. Such agreement shall provide that during the period of the loan the city shall retain the right to receive, or collect from the borrower, all dividends, interest rights, or any distributions to which the city would have otherwise been entitled. The transfer of the securities shall be through a lending agent which is an approved municipal depository pursuant to Section 2-32-400. (b)   The borrower shall deposit with the city treasurer as collateral for such loan cash or United States government securities equal to 102 percent of the market value of the securities at the time the loan is made and shall increase the amount of collateral when the comptroller and the city treasurer request an additional amount because of a subsequent increase in the market value of the securities.   (c)   The period for which the securities may be lent shall not exceed one year, and the loan agreement may specify early termination by either party upon mutually agreed conditions.   (d)   The lending agent shall have the authority to invest the collateral on behalf of the city. Investment by the lending agent of the collateral shall not be subject to the restrictions of Section 2-32-520; provided however, that investment of the collateral shall be limited to investments approved by the comptroller and city treasurer in accordance with sound and prudent investment policies.

(Added Coun. J. 11-5-03, p. 9539, § 1)

2-32-580 Sale of securities.The comptroller and city treasurer may sell a security prior to maturity at such price that the comptroller and city treasurer shall deem advisable including at, above or below the purchase price of the security when in the determination of the comptroller and city treasurer the sale of the security is necessary to:

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(1) ensure sufficient amount of money on hand when the balance of cash in the city treasury has for any reason become less than the amount necessary for immediate use; (2) enhance the overall portfolio yield; (3) minimize further erosion and loss of investment principal; or (4) minimize the city's exposure to market and credit risks.The city treasurer shall cooperate with the comptroller in the cancellation and reissue of tax warrants sold in such a way that no duplication thereof shall take place.

(Prior code § 7-46; Amend Coun. J. 11-7-07, p. 12472, § 1)

2-32-590 Municipal bonds – Comptroller's endorsements.By the endorsement of the comptroller upon any bonds of the city payable to bearer, when presented for that purpose by the owner, such bonds shall become payable only to the party named in such endorsement, his assignees or legal representatives, anything on the face of such bonds to the contrary notwithstanding. The affidavit of the party presenting any such bonds, or his authorized agent or attorney, to the effect that he is the owner thereof, shall be sufficient evidence to the comptroller of such ownership.The endorsement of the comptroller may be in the following form:By virtue of the act of the general assembly of Illinois, the ordinances of the City of Chicago, and the consent of (A. B.) the owner of this bond, this bond is made payable only to said (A. B.), his assignees or legal representatives, anything on the face hereof to the contrary notwithstanding. (C. D.) Comptroller.

(Prior code § 7-47)

2-32-600 Municipal bonds – Repurchase conditions and procedures.The comptroller and treasurer shall have authority to repurchase municipal bonds, notes, commercial paper or other instruments representing a debt obligation of the city. The comptroller and treasurer are hereby authorized to use, for the purpose of making such repurchases, money out of any fund set aside for use for some particular purpose that is not immediately necessary for that purpose. Instruments repurchased under this section may be canceled or may be held in the custody of the city treasurer as provided in this chapter.

(Prior code § 7-48; Amend Coun. J. 11-5-03, p. 9539, § 1)

2-32-610 Reserved.Editor's note – Coun. J. 11-5-03, p. 9539, § 1, repealed § 2-32-610, which pertained to repurchased bonds – custody and disposition.

2-32-620 Comptroller – Authority to perform Treasurer's securities duties when.If a vacancy exists in the office of city treasurer or the treasurer is absent from the city or otherwise incapacitated to perform his duties the comptroller and the mayor or either of them alone shall have authority to perform the functions of the comptroller and treasurer jointly in the purchase, repurchase, sale or resale of any securities or the investment of city funds as provided in Sections 2-32-520 to 2-32-610, inclusive.

(Prior code § 7-49.1)

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