HomeMy WebLinkAbout3.a. Review Draft Position Paper to Adopt Propsoed Revisions to BP 017 - Fiscal Reserves Page 1 of 13
Item 3.a.
Algi CENTRAL SAN BOARD OF DIRECTORS
POSITION PAPER
DRAFT
MEETING DATE: OCTOBER 22, 2019
SUBJECT: REVIEW DRAFT POSITION PAPER TO ADOPT PROPOSED REVISIONS
TO BOARD POLICY NO. BP 017 - FISCAL RESERVES
SUBMITTED BY: INITIATING DEPARTMENT:
KEVIN MIZUNO, FINANCE MANAGER ADMINISTRATION-FINANCE
PHILIP LEIBER, DIRECTOR OF FINANCE AND
ADMINISTRATION
REVIEWED BY: ANN SASAKI, DEPUTY GENERAL MANAGER
ISSUE
On September 17, 2015, the Board adopted a Fiscal Reserve Policy entitled BP 017 — Fiscal Reserves.
BP 017 was last reviewed and updated in December 2017. The policy is again being brought forward for
consideration as part of the biennial review process and includes additional recommended changes,
including the establishment of a Rate Stabilization Fund.
BACKGROUND
As part of the Board's strategic goal to ensure long-term financial stability, the Board adopted a fiscal
reserve policy in 2015, and updated the policy in December 2017. BP 017 — Fiscal Reserves has
currently specified the following targets:
1. Working capital operating reserves at five months of annual budgeted operating expenditures,
2. Sewer Construction working capital reserves at 50% of annual Capital Improvement Program (CIP)
budgeted expenditures, and
3. Self Insurance/Catastrophic Loss Emergency reserves at $5.0 million, and insurance reserves at $1.5
million to cover three losses at the current $500,000 self-insured retention per occurrence.
The policy also addresses restricted reserves including the Governmental Accounting Standards Board
(GASB)45 Other Post-Employment Benefits (OPEB) Trust, Pension Pre-Funding Trust, and the debt
service reserve.
n general, the status of the designated and restricted reserves are as follows (pre-audit estimates as of
6/30/2019 and pro-forma balances including the Board directed transfer approved on October 3, 2019
related to the FY 2018-19 variances):
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Designated Reserves
• O&M fund working capital reserve policy specifies a balance of five twelfths of upcoming year's O&M
budget, which equates to $36.5 million. The reserve is fully funded, with a balance of$41.3 million, and
after proposed variance transfers would be $36.5 million.
• SSC/CIP fund working capital reserve policy specifies six months of cash funded Capital Expenditures,
which equates to $33.1 million based on the FY 2019-20 budget. The reserve is fully funded, with a
balance of$51.6 million, and after proposed variance transfers would be $57.5 million (which includes
funding for carry forwards of$8.5 million that are expected to be spent during FY 2019-20)
• Self-Insurance reserve of$1.5 million and the Catastrophic Loss Emergency Reserves balance of$5
million. The combined reserve of$6.5 million is fully funded, with a balance of$7.09 million.
Restricted Reserves
• GASB 45 OPEB Trust: Balance of$65.76 million, and with the proposed transfer of$1.25 million would
be $67.01 million.
• Section 115 Pension Prefunding Trust: Balance of$8.39 million, and with the proposed transfer of$1.25
million would be $9.64 million.
Staff is recommending certain changes to the reserve policy as indicated below:
1. Add language related to the establishment of a Rate Stabilization Fund (RSF)which was supported by
the Finance Committee and the Board during the October 3, 2019 meeting addressing the disposition of
the FY 2018-19 variance funds. The RSF, as specified, would allow funds to be used for either meeting
debt service coverage requirements, or any other use permitted by the 2018 Bond Indenture. Any draw
from, or addition to the fund other than from interest earnings, would require Board approval.
2. Updated language to better reflect new circumstances and to clarify certain definitions as follows:
• Adding language further clarifying the definition and calculation of "working capital" reserves as
it relates to the reserve target for the O&M and Sewer Construction funds and referencing best
practice guidance published by the Government Finance Officers Association (GFOA).
• Revisions to the debt service reserve fund language, primarily to reflect that the previous
requirement to maintain a debt service reserve has been eliminated due to the refunding of the
2009 bonds.
• Specify conditions for temporary inter-fund borrowings, and noting that permanent transfers
between the funds could be directed through Board action, as has been the practice through
the year-end variance disposition process.
ALTERNATIVES/CONSIDERATIONS
The policy could continue unchanged from prior years, or substantive changes could be included.
Language to establish and define the operation of a RSF as described above is the major substantive
change proposed. Potential variations on this proposal include: the initial funding amount (specified by
the Board on October 3, 2019), and conditions under which funds are added or withdrawn from the fund.
A potential additional change could be to increase the targeted level of the Catastrophic Loss/ Emergency
Reserve above the current$5 million level. Due to inflation and the potentially high cost of restoration after
a major disaster, it may be prudent to increase the targeted level of the reserve over time. However, with
the establishment of the RSF and the ability to also use those funds for any legal purpose, a separate
increase in the Catastrophic Loss/ Emergency Reserve is not viewed as essential at this time.
FINANCIAL IMPACTS
Most of the proposed changes to Board Policy No. BP 017 - Fiscal Reserves, do not have a financial
impact, but are, in general, clarifications of existing practice.
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The establishment of the Rate Stabilization Fund will support the goals of mitigating the volatility of Sewer
Service Charge rate adjustments, and help to ensure debt service coverage targets are met (though such
targets are not anticipated to be constraints in the near term).
COMMITTEE RECOMMENDATION
The Administration Committee reviewed the proposed changes to Board Policy No. BP 017 Fiscal
Reserves at its meeting on October 22, 2019, and recommended Board adoption.
RECOMMENDED BOARD ACTION
Adopt proposed revisions to Board Policy No. BP 017 - Fiscal Reserves, effective immediately.
Strategic Plan Tie-In
GOAL THREE:Be a Fiscally Sound and Effective Water Sector Utility
Strategy 1 - Conduct long-range financial planning, Strategy 2- Manage costs
ATTACHMENTS:
1. BP 017 Fiscal Reserves (with tracked proposed changes)
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Number: BP 017
Authority: Board of Directors
Effective: September 17, 2015
Revised: Decornber 21,2017 / /19
Reviewed: '0/22/19 CENTRALSAN
Initiating Dept./Div.: Administration
BOARD POLICY
FISCAL RESERVES
PURPOSE
To set forth the District's policy for establishing and maintaining fund reserve targets for
each of the District's reserve funds. Fiscal reserves provide working capital for
operations and maintenance activities, funding for long-term capital improvement
requirements; fulfillment of legal, regulatory and contractual obligations and mitigation of
risk and liability exposures.
POLICY
This policy is intended to ensure that the District has sufficient cash flow to meet current
and future needs and provide transparency to its ratepayers by establishing fund
reserve targets for each of the District's reserve funds. Reserve funds are needed to
provide funding for planned and unplanned events. Planned events include, but are not
limited to:
• accumulating balances to fund operating needs
• capital improvement program needs for capacity expansion and renewal and
replacement of existing assets
• debt service obligations,
• providing funds to mitigate cash flow variances throughout the fiscal year, and
• funding for employee related pension and other post-employment benefits
Unplanned events include:
• accounting for revenue shortfalls
• unanticipated expenses
• paying for unforeseen emergency events
The established reserve targets defined herein provide guidance for long-term financial
planning and maintaining the District's long-term financial health. Adequate fund
reserves are of value to: 1) provide working capital to fund operating needs; 2) provide
working capital to fund capital improvement program needs; 3) provide a financial
cushion for dealing with unanticipated financial needs and emergencies; and 4) are a
component of achieving favorable credit ratings which can help to reduce the costs of
issuing debt.
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Number: BP 017
FISCAL RESERVES
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This policy designates specific reserve accounts and establishes certain targets that the
Board of Directors has determined to be in the best interest of the District. It also
establishes the authority of the Board and staff for the implementation and maintenance
of the reserve fund targets defined herein. For each reserve, this policy specifies a
targeted level (if applicable), the conditions and procedures for the use or replenishment
of the reserve, and authorities for the General Manager (GM) related to such.
Reserve Fund Targets
The District maintains a number of reserve funds. All funds are designated or restricted
for specific purposes and are independent of one another. Each year the Board should
review its actual and recommended reserve targets and replenish each designated
reserve fund as needed.
Definitions:
A. Designated Reserves
Established and designated for specific purposes. These funds are to be utilized
to fund such things as operations and maintenance, future capital facilities, repair
and replacement of existing assets, economic uncertainties, regulatory
requirements, local disasters and other financial hardships.
B. Restricted Reserves
Restrictions on the use of these funds are imposed by an outside source such as
creditors, grantors, contributors, laws, or regulations governing use.
Achieving Fund Reserve Targets
Each Designated reserve has been set at a targeted level by the Board through this
Policy. The District will update its 10-year rate model each year in order to determine
appropriate rate and fee adjustments. Rate and fee adjustments should be adopted to
achieve and maintain the District's minimum fund reserve targets over the 10-year
planning period. This can include phasing in a series of rate increases to gradually
restore reserves to target levels over a number of years. For financial planning
purposes, it is acceptable for reserves to drop below their target level on a temporary
basis, as long as the District takes action to achieve the target over the planning period
and as otherwise specified in this policy for each reserve.
Types of Reserves
A. Operations and Maintenance Fund —Working Capital Reserves (Designated)
The operations and maintenance fund provides for the general operations,
maintenance and administration of the District. Sewer Service Charge (SSC)
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Number: BP 017
FISCAL RESERVES
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revenues are collected by the Contra Cost County Tax Assessor's Office and
remitted to the District in two installments in April and December of each year.
The Government Finance Officers Association (GFOA) recommends local
governments establish a customized target amount of working capital as the
measure of available margin or buffer in enterprise funds. Accordingly I;n order
for the District to pay its ongoing expenses throughout the year, it reserves a
specified percentage of prospective budgeted gross operating expenditures at
the start of each fiscal year.. as its targeted working capital reserve The
specified percentage is 41.7% (representing 5 months of annual expenses). This
working capital reserve fund is used in the normal course of District operations.
For purposes of this policy "working capital" shall be defined as the sum of
current unrestricted cash and investments adjusted for year-end closing accruals
and other timing issues.
Provisions Regarding Usage:
Calculation of the Reserve: Projections of the reserve are made in connection
with financial planning and rate setting, where rates may be set to achieve a
targeted reserve level. The year-end reserve amount is re-calculated annually in
connection with the annual financial statement closing and audit, and compared
to the required reserve level. Any variance from the required level would be taken
into account when rates and budgets are set for the subsequent year.
Draws from the Reserve: Reductions can be made to cover normal O&M
spending up to the overall total O&M budget amount, consistent with the
GM delegation of authority.
Any O&M spending in excess of the overall approved O&M budget would
require a budget amendment by the Board.
Additions to the Reserve: The Reserve balance would increase with the
receipt of revenues. Overall net additions are made annually through
planned net income. The ending reserve balance is calculated as part of
the annual financial close process.
B. Capital Improvement Project Fund — Working Capital Reserves (Designated)
The capital projects fund provides for treatment plant and collection system asset
renewal and replacement expenditures, general improvements, and recycled
water, as well as office facilities renewal, vehicle and equipment replacement,
information systems replacement and miscellaneous capital needs. Property Tax
and SSC revenues, which comprise a significant portion of annual capital project
revenues, are also collected by the Contra Cost County Tax Assessor's Office
and remitted to the District in two installments in April and December of each
year. Hs noiea previously, the GFOA recormends local governrnenis esiauiish
a customized target amount of working capital as the measure of available
margin or buffer in enterprise funds. Accordingly, fin order to meet the cash flow
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Number: BP 017
FISCAL RESERVES
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needs of the capital improvements program, the District reserves 50% of the
annual non-bond funded capital projects budget at the start of each fiscal year
its targeieg working capitai reserve (i.e. the 50% requirement excludes projects
anticipated to be funded with available bond proceeds in that fiscal year). r u,
purposes of this, "working capital" shall be defined as the sum of current
unrestricted cash and investments adjusted for unspent capital project
carryforwards, year-end closing accruals, and other timing issues.
Provisions Regarding Usage:
This fund is used in the normal course of District operations. Funds are drawn
down on a routine basis through capital project spending, and replenished
through the receipt of revenues. In addition:
Draws from the Reserve: The reserve would be drawn down through
capital project spending.
On a planned basis (in advance of the subject year), the reserve can be
drawn down if the reserve balance is higher than the required/targeted
level. This would be done by setting rates such that contributions to the
fund are less than expenditures. Such reductions are implicitly approved
when the Board sets rates, and represent underlying assumptions in the
financial plan. A forecast of the reserve, including any draw down, is
included in the budget book provided to and adopted by the Board.
The reserve is also drawn down during a fiscal year related to timing of
SSC and ad valorem tax collections; capital expenditures can occur in
advance of such revenues. No specific authorization is required related
to this normal use of this reserve.
The reserve may also be drawn down during the year due to:
(1) Planned capital expenditures that exceed the total approved capital
budget (which includes the current year CIB plus prior year
carryforward). This would generally be possible if there were
additional funds from an unallocated prior year variance or
revenues have surpassed the current year's projection.
(2) Planned capital expenditures due to construction contracts
awarded by the Board that exceed the project budget for the
subject year; whereas funds are available for that project in the
subsequent year's budget, and funds are not otherwise available to
be transferred from the CIB contingency account or another
project(s).
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Board/Committee approval of such draws described in items (1) and
(2) would be required, unless provided for in the GM Delegation of
Authority.
Additions to the Reserve: The Reserve balance would increase with the
receipt of revenues.
Overall net additions to the Reserve are made when sewer construction
fund revenues (including planned transfers) exceed expenses over the
course of a year. This can occur on a planned or unplanned basis. On a
planned basis, rates would be set to provide additions to the reserve when
the reserve balance is below the targeted level. On an unplanned basis,
additions to the reserve occur through favorable O&M or capital budget
variances.
C. Self-Insurance Fund Reserves (Designated)
The Self-Insurance Fund (SIF) was established in 1986 to allow the District to
self-insure a portion of its risks. This reduces the cost of insurance premiums
and gives the District greater control over its retained losses. The Board
establishes the amount of risk retained and reviews the self-insured retention
periodically to align it with the Board's risk tolerance, the District's loss
experience, and insurance market conditions.
Government Accounting Standards Board Statement No. 10 (GASB-10)
established requirements on how public agencies must fund their self-insured
risks. To comply with GASB-10, reserves for certain types of liability risks were
segregated into a sub-fund that must be actuarially reviewed at least every two
years. In order to fund GASB-10 retained risks this sub-fund ("A") shall maintain
a minimum reserve of at least three times the amount of the District's self-insured
retention, which is currently $500,000, and accordingly the fund presently has a
targeted level of$1,500,000. The Self-insurance Fund Reserves and Self-
Insurance Catastrophic Loss/Emergency Reserves are comprised of cash and
investments within the Self Insurance fund, adjusted for year-end closing
accruals and other timing issues.
Provisions Regarding Usage:
Draws from the Reserve: Reserve funds are used to pay claims and
claims expenses within the self-insured retention during the fiscal year.
Individual payments are reported to the Finance Committee in the monthly
expenditures report and to the Administration Committee in Risk
Management Reports. Total fund expenditures are reported to the Board
in the Risk Management Annual Report. Payments are governed by the
limits set in the GM Delegation of Authority.
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Additions to the Reserve: Annually, upon the Board's adoption of the SIF
and O&M budgets, this reserve is replenished with O&M funds in an
amount needed to meet the minimum reserve requirements stated above.
D. Self-Insurance Catastrophic Los Emergency Reserves (Designated)
In order to mitigate the financial impacts and maintain uninterrupted service in
the event of an emergency or catastrophic event the, District maintains ate_
Catastrophic Loss/Emergency Reserve balance of$5 million in the SIF. The
Self-insurance Fund Reserves and Self-Insurance Catastrophic Loss/Emergency
Reserves are comprised of cash and investments within the Self Insurance fund
adjusted for year-end closing accruals and other timing issues.
This reserve (housed in the SIF (Sub Fund C)), holds funds for the following
purposes:
1. Insurance premium payments and related expenses
2. Claims settlements and expenses for self-insured losses not governed by
GASB 10
3. Costs to initiate claims against others
4. Funds reserved to respond to emergency conditions as determined by the
Director of Emergency Services.
Provisions Regarding Usage:
Draws from the Reserve:
• Draws for items 1, 2, and 3 shall be made in accordance with the
GM's authority outlined in Resolution 2016-046 or updates thereto.
• Draws for item 4 shall be made in accordance with the authority
granted to the Director of Emergency Services as outlined in
Resolution 2010-089 or updates thereto.
Additions to the Reserve:
This fund is replenished annually upon the Board's adoption of the
SIF Budget. O&M funds are transferred in the amount needed to
maintain a reserve of$5 million..
E. Debt Service Reserves "Bond Reserve" (Restricted)
The District has the capacity to finance capital projects through the issuance of
bonds and various types of debt financing. A requirement of a '�,loan-ssome types
of debt may include the establishment and maintenance of a contingency reserve
that is defined in the feaR documents. The f Rd balaRG8If required, the Bond
Reserve funding levE will be set at the amount required in the leandebt
documents, typiGally ene annual payment per loan. Changes to the reserve
amount typically only occur due to: (1) additional debt being issued; (2) the
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required reserve amount changes due to normal amortization and repayment of
debt; and (3) the debt is fully amortized and the reserve is extinguished.
AS of Octuucr 2019, there is no ueDt Service r,,caerve/bona Kebui vc ii i place.
Provisions Regarding Usage:
Draws from the Reserve: Use of the reserve to pay debt service would
occur if the funding requirement decreased, in this case, excess funds
would be applied to next required debt payment; or funds were otherwise
unavailable to pay debt service and would only occur in extraordinary
situations. In such circumstances, the GM would notify the Board of the
planned use of the reserve, and report via GM written announcement at a
subsequent next upcoming Board meeting.
Additions to the Reserve: are made in connection with a Board approved
bond issuance during the bond closing process.
F. Rate Stabilization Fund "RSF" (Designated)
The District aims to establish rates that are stable and not unduly volatile, while
meeting necessary financial metrics and providing adequate funding for the
District's programs (the revenue requirement). The 2018 Bond Indenture allows
for the establishment of a Rate Stabilization Fund (RSF) that can be used
towards ends. The 2018 Bond Indenture allows for draws from the RSF for the
purpose of paying debt service on the Bonds or any lawful purpose of the
Wastewater System.
The Rate Stabilization Fund level shall be considered by the Board of Directors
concurrent with Sewer Service Charge rate proposals and reviews of the long-
term Financial Plan.
Provisions Regarding Usage:
Draws from the Reserve:
• Any draw from the RSF shall require Board of Directors approval:
o The RSF may be drawn down during or after the close of a
fiscal year in order to meet a specified Debt Service
Coverage level (either 1.00x, 1.25x per bond covenants, or
the Debt Management policy specified level of 2.0x).
o The RSF may be drawn down on a planned basis (during
rate setting) to avoid the need for higher than desired rate
increase.
o The RSF may be drawn down for any legal use specified by
the Board of Directors, as permitted by the 2018 Bond
Indenture of Trust.
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• As provided for in the 2018 Bond Indenture of Trust, amounts so
transferred from the Rate Stabilization Fund to the Wastewater
System Funds shall constitute Gross Revenues for such Fiscal
Year for purposes of the Debt Service Coverage requirements of
the Bond Indenture. Such transfers may be made until (but not
after) 180 days after the end of such Fiscal Year.
Additions to the Reserve:
• Additions (other than interest earnings) to the RSF shall require
Board of Directors approval, and may take place:
o After the close of a fiscal year through the disposition of
year-end variances.
o When rates are set to contribute a specified amount to the
RSF.
• Amounts transferred from Wastewater System Funds to the Rate
Stabilization Fund shall constitute a reduction in Gross Revenues
for the Fiscal Year such funds were budgeted.
GASB 45 OPEB Trust (Restricted)
The District has negotiated and provides Other Post Employment Health Care
Benefits (OPEB) for retired employees that meet certain criteria. Biannually, the
District updates funding requirements needed to provide these benefits by
conducting an actuarial study. While the OPEB Trust is not a District reserve, the
District's funding intent is to perform biennial actuarial studies and deposit into
the trust the recommended actuarially determined contribution. The investments
in the OPEB Trust are managed by an investment advisor with oversight by
District staff and the Board Finance Committee.
Provisions Regarding Usage:
Draws from the Trust: A planned draw from the OPEB Trust may be
included in a Board adopted budget and executed by the GM. Only
premiums, claims, and/or administrative costs for OPEB related expenses
paid for by the District for the current year or one year back are eligible for
reimbursement or distribution through the OPEB Trust. Health care costs
or other premiums for current active employees are not eligible.
Additions to the Trust: An amount may be included in a Board adopted
budget to pay down unfunded employee related liabilities for pension or
OPEB obligations. If specifically designated for OPEB, the GM may direct
such funds be deposited into the OPEB Trust. The Board may also direct
that other funds, such as those available from favorable budget variances
are also directed to the OPEB Trust.
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GH. Section 115 Pension Prefunding Trust (Restricted)
The District has established an IRS Code Section 115 Pension Prefunding Trust
to allow for voluntary contributions toward pension obligations. The name of the
Trust per the resolution is the "Public Agencies Post-Employment Benefits Trust",
which is a multi-employer trust administered by PARS. This Pension Prefunding
Trust allows contributions to count toward the unfunded liability (and as a result
the funded ratio) while not placing the contributions with the Contra Costa County
Employee's Retirement Association (CCCERA). Only premiums, claims, and/or
administrative costs for pension related expenses paid for by the District for the
current year or one year back are eligible for transfer, payment, or
reimbursement from the Prefunding Pension Trust.
The Pension Prefunding Trust may be withdrawn by the District and contributed
to CCCERA at a time convenient for the District. Uses for this Trust may include
mitigating rate volatility, or to offset normal cost expenses that are required even
when all liabilities have been met. The District may make budgeted and planned
contributions to the Pension Prefunding Trust, or may make contributions based
on the availability of funds from favorable budget variances in either case,
subject to Board approval. The investments in the Pension Prefunding Trust are
managed by an investment advisor with oversight by District staff and the Board
Finance Committee. The Section 115 Pension Prefunding Trust is not a District
reserve.
Provisions Regarding Usage:
Draws from the Trust: A planned draw from the Pension Prefunding Trust
may be included in a Board adopted budget to pay required CCCERA
pension contributions, and withdrawals up to that amount may be
executed by the GM. Withdrawals in excess of that amount would require
additional Board authorization.
Transfers, payment and reimbursement from the Pension Trust are
allowed for the following:
• Transfer to a Qualified Trust for employer contribution (e.g.
retirement system);
• Distribution directly to insurer, third party administrator, service
provider or other entities providing services in connection with
determining the employer's pension obligation; and
• Reimbursement to the employer for employer contributions made to
a Qualified Trust and/or related pension administrative costs paid
by the employer.
Additions to the Trust: An amount may be included in a Board adopted
budget to pay down unfunded employee related liabilities for pension or
OPEB obligations. If specifically designed for pension liabilities, the GM
may direct such funds be deposited into the Pension Prefunding Trust.
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The Board may also direct that other funds, such as those available from
favorable budget variances are also directed to the Pension Prefunding
Trust.
Management Responsibility
The GM is authorized to establish and implement procedures to support this policy.
Management will ensure that these funds and reserves are reviewed during the annual
budget cycle and are adjusted as necessary to remain within the guidelines outlined in
this document. Management will report on the use of the reserve funds as required
above, and through recurring financial reporting mechanisms.
Investing Reserve Funds
Reserve Funds will be invested according to the District's Statement of Investment
Policy, BP 005. Furthermore, the Restricted fund investments are managed by Public
Agency Retirement Services (PARS) the Trust Administrator, Highmark Capital
Management is the Investment Manager, and US Bank is the Trustee Custodian of
assets.
Inter Sub-Fund Borrowings and Transfers of Reserve Funds
• Temporary borrowings: tr�rsiviovemei i of cash or investments between sub-
funds (Running Expense, Sewer Construction, and Self-Insurance) on an interim
basis for cash management purposes may be effectuated by the GM consistent
with the GM delegation of authority.. dnd are not "inter-fund transfers" pursuant to
generally accepted accounting principles with the condition said funds must be
repaid in full. Such temporary borrowings are recorded as a due to/due from in
each sub-fund and are typically cleared when monies are available in the
recipient sub-fund in a timeframe not to exceed one year from the fiscal year-end
balance sheet date. Pursuant to generally accepted accounting principles,
balances unpaid beyond one year are considered inter-fund borrowings and must
be approved by the Board and should bear interest.
• Permanent transfers: Inter-fund transfers between sub-funds on a permanent
basis may be specified in the District's financial plan and budget, and would must
be approved by the Board through the adoption of the annual budget.,orates or
other specific Board action. Inter-fund transfers may be authorized by the Board
following the adoption of the annual budget through the authorized disposition of
annual budgetary favorable variances or other Board action. Such inter-fund
transfers do not require an appropriation amendment as the action only
constitutes a transfer of reserves from one of the District's sub-funds to another.
[Original Retained by the Secretary of the District]
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