R-3588-7-18RESOLUTION NO. 3588-7-18(R)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ALLEN, COLLIN
COUNTY, TEXAS, APPROVING AN AMENDED POLICY FOR THE
INVESTMENT OF MUNICIPAL FUNDS; AND PROVIDING AN EFFECTIVE
DATE.
WHEREAS, Chapter 2256 TEX. GOVT CODE requires the City Council to annually review its Investment
Policy regarding the investment of City funds and funds under its control; and,
WHEREAS, the City Council re -adopted the Investment Policy on July 11, 2017; and,
WHEREAS, the Investment Policy is hereby amended to update the maximum investment description
regarding certificates of deposit as authorized investments, and add or remove authorized
broker/dealer/Financial institutions/ and/or banks.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ALLEN,
COLLIN COUNTY, TEXAS, THAT:
SECTION 1. The Investment Policy attached hereto as Exhibit "A" ("Investment Policy") and made a part
hereof for all purposes, has been reviewed and includes any amendments thereto, is hereby adopted as the
Investment Policy of the City of Allen as required by Chapter 2256 of the Texas Government Code.
' SECTION 2. This resolution shall take effect upon its adoption.
DULY PASSED AND APPROVED BY THE CITY COUNCIL OF THE CITY OF ALLEN, COLLIN
COUNTY, TEXAS, ON THIS THE Wo' DAY OF JULY 201&
APPROVED:
Stephen Iferrell, MAYOR
ATTEST:
*Sh..If.y
��
B. G e, CITY SEILTARY
EXHIBIT A
CITY OF ALLEN, TEXAS
INVESTMENT POLICY
July 10, 2018
Resolution No. 3588-7-18(R), Page 2
' PURPOSE
The purpose of this document is to set forth specific investment policy and strategy guidelines for the City
of Allen in order to achieve the goals of safety, liquidity, yield and public trust for all investment activity.
This policy serves to satisfy the statutory requirement (specifically the Public Funds Investment Act (PFIA),
Chapter 2256, Texas Government Code, as amended, [the "Act"]) to define, adopt and review a formal
investment strategy and policy. Additionally, this policy excludes the investment of public funds that are
invested by a trustee pursuant to Chapter 172 of the Texas Local Government Code, and Chapter 113 and
Chapter 117 of the Texas Trust Code, for the City's retiree healthcare benefits program. Such funds are
invested pursuant to a separate Investment Guidelines Document as part of a Post -Retirement Health Care
Plan Trust.
INVESTMENT STRATEGY
The City of Allen maintains portfolios which utilize four specific investment strategy considerations
designed to address the unique characteristics of the fund groups represented in the portfolios. Preservation
and safety of principal shall be the foremost investment objective in each of the portfolios. Liquidity is the
second objective. Its importance to each fund group is emphasized in the following paragraphs. Yield and
diversification shall also be a consideration and shall be in compliance with the guidelines set forth in the
Investment Policy.
A. Investment strategies for operating funds have as their primary objective to assure that
anticipated cash flows are matched with adequate investment liquidity. The secondary
objective is to create a portfolio structure which will experience minimal volatility during
economic cycles. This may be accomplished by purchasing high quality, short -to -medium
term securities which will complement each other in a laddered or barbell maturity
structure.
B. Investment strategies for debt service funds shall have as the primary objective the
assurance of investment liquidity adequate to cover the debt service obligation on the
required payment date. If the annual debt service obligation is covered, then securities may
be purchased that have a stated final maturity date which exceeds the debt service payment
date.
C. Investment strategies for reserve funds shall have as the primary objective the ability to
generate a dependable revenue stream to the appropriate fund from securities with a low to
moderate degree of volatility. Securities should be of high quality and, except as may be
required by any bond ordinance specific to an individual issue, of intermediate to longer-
term maturities.
D. Investment strategies for special projects or special purpose fund portfolios shall have as
their primary objective to assure that anticipated cash flows me matched with adequate
investment liquidity. These portfolios should include at least 10% in highly liquid
securities to allow for flexibility and unanticipated project outlays. The stated final
maturity dates of securities held should not exceed the estimated project completion date.
I. SCOPE
Resolution No. 3588-7-18(R), Page 3
Funds that are invested by a trustee pursuant to Chapter 172 of the Texas Local Government Code, and
Chapter 113 and Chapter 117 of the Texas Trust Code, for the City's retiree healthcare benefits program
are excluded from this policy.
11. OBJECTIVES
The City of Allen shall manage and invest its cash with the four objectives listed in priority order: Safety;
Liquidity; Yield and Public Trust. Safety of principal invested is always the primary objective. All
investments shall he designed and managed in a manner responsive to the public trust and consistent with
State and Local law.
' SAFETY
The primary objective of the City's investment activity is preservation of capital. Each investment
transaction shall be conducted in a manner to avoid capital losses.
LIQUIDITY
The City's investment portfolio shall remain sufficiently liquid to enable the City to meet operating
requirements that may be reasonably anticipated. To the extent possible, the City will attempt to match its
investments with anticipated cash flow requirements. Unless matched to a specific cash Flow, the City will
not directly invest in securities maturing more than five years from the date of purchase.
YIELD
The investment portfolio shall be designed with the objective of regularly exceeding the average rate of
return on a six-month U.S. Treasury Bill. The City's investment risk constraints and cash flow needs shall
be taken into consideration.
PUBLIC TRUST
All participants in the City's investment process shall seek to act responsibly as custodians of the public
trust. Investment officials shall avoid any transaction which might impair public confidence in the City's
ability to govern effectively.
Resolution No. 3588-7-18(R), Page 4
This investment policy applies to all financial assets of the City of Allen including component units repotted
'
as follows:
•
General Fund
•
Enterprise Funds
•
Debt Service Funds
•
Special Revenue Funds
•
Capital Projects Funds
•
Internal Service Fund
•
Trust and Agency Funds
•
Economic Development Corporation
•
Community Development Corporation
Funds that are invested by a trustee pursuant to Chapter 172 of the Texas Local Government Code, and
Chapter 113 and Chapter 117 of the Texas Trust Code, for the City's retiree healthcare benefits program
are excluded from this policy.
11. OBJECTIVES
The City of Allen shall manage and invest its cash with the four objectives listed in priority order: Safety;
Liquidity; Yield and Public Trust. Safety of principal invested is always the primary objective. All
investments shall he designed and managed in a manner responsive to the public trust and consistent with
State and Local law.
' SAFETY
The primary objective of the City's investment activity is preservation of capital. Each investment
transaction shall be conducted in a manner to avoid capital losses.
LIQUIDITY
The City's investment portfolio shall remain sufficiently liquid to enable the City to meet operating
requirements that may be reasonably anticipated. To the extent possible, the City will attempt to match its
investments with anticipated cash flow requirements. Unless matched to a specific cash Flow, the City will
not directly invest in securities maturing more than five years from the date of purchase.
YIELD
The investment portfolio shall be designed with the objective of regularly exceeding the average rate of
return on a six-month U.S. Treasury Bill. The City's investment risk constraints and cash flow needs shall
be taken into consideration.
PUBLIC TRUST
All participants in the City's investment process shall seek to act responsibly as custodians of the public
trust. Investment officials shall avoid any transaction which might impair public confidence in the City's
ability to govern effectively.
Resolution No. 3588-7-18(R), Page 4
III. RESPONSIBILITY AND CONTROL
' DELEGATION OF AUTHORITY AND TRAINING
Authority to manage the City's investment program is derived from a resolution of the City Council. The
Chief Financial Officer (CFO) is designated as the primary investment officer of the City. The Assistant
Chief Financial Officer is designated as secondary investment officer in the absence of the CFO. The CFO
may delegate the day-to-day activities to a responsible individual(s) who has received the appropriate
training required by state statute. The CFO shall be responsible for all transactions undertaken and shall
establish a system of controls and compliance audit to regulate the activities of subordinate officials and
persons authorized to execute investment transactions.
The investment officers and persons authorized to execute investment transactions shall attend training
sessions of at least 10 hours in compliance with Section 2256.008 of the Act within 12 months after taking
office or assuming duties and at least S hours every two years thereafter.
SAFEKEEPING AND CUSTODY
The CFO shall establish written procedures for the operation of the investment program, consistent with
this investment policy. Procedures shall include reference to safekeeping and reporting of the portfolio
market value for securities held in safekeeping, banking service contracts and collateral. Securities and
collateral will be held by a third -party custodian designated by the City or by the Federal Reserve Bank and
held in the City's name as evidenced by safekeeping receipts of the institution with which the securities are
deposited. The market value of the securities and collateral shall be reported at least monthly by the
' custodians. Any substitutions and/or releases of collateral must be approved by the CFO or another person
qualified to execute investment transactions designated by the CFO. All collateral must have a market
value of 103% of the original purchase price of the investment (less FDIC or NCUSIF insurance) plus
accrued interest.
The standard of prudence to be applied by the investment officer shall he the "prudent investor" rule which
states: "Investments shall be made with judgment and care, under circumstances then prevailing, which
persons of prudence, discretion and intelligence exercise in the management of their own affairs, not for
speculation, but for investment, considering the probable safety of their capital as well as the probable
income to be derived."
In determining whether an investment officer has exercised prudence with respect to an investment
decision, the determination shall be made taking into consideration:
A. the investment of all funds, or funds under the entity's control, over which the officer had
responsibility rather than a consideration as to the prudence of a single investment; and
B. whether the investment decision was consistent with the written investment policy of the
entity.
All participants in the investment program will seek to act responsibly as custodians of the public trust.
' Investment staff will avoid any transaction that might impair public confidence in the City's ability to
govern effectively. Investment staff shall recognize that the investment portfolio is subject to public review
and evaluation. The overall program shall be designed and managed with adegree of professionalism which
is worthy of the public trust. Nevertheless, the City recognizes that in a marketable, diversified portfolio,
Resolution No. 3588-7-18(R), Page 5
occasional measured losses are inevitable and must be considered within the context of the overall
' portfolio's investment rate of return.
ETHICS AND CONFLICTS OF INTEREST
City 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 the ability to make impartial
investment decisions. An investment officer of the City who has a personal business relationship and/or a
relationship by blood or marriage within the second degree, as defined in the PFIA Section 2256.005, with
a financial organization seeking to sell an investment to the City, shall file a disclosure statement with the
Texas Ethics Commission, the City Council, and the City Manager.
LIABILITY
Investment and management staff acting in accordance with written procedures and this investment policy
and exercising due diligence shall be relieved of personal responsibility for market price changes, provided
deviations from expectations are reported in a timely fashion and the liquidity and the sale of the securities
are carried out in accordance with the terms of this policy.
INVESTMENT SAFEGUARDS
CASH FLOW: Investment staff of the City will maintain a cash flow analysis which identifies the
present and future cash requirements. The investment portfolio (utilizing cash flow analysis) will be
structured such that the selling of securities prior to maturity for the purpose of meeting daily cash needs
would be on an exception basis only.
SEPARATION OF DUTIES: Investment staff of the City will be responsible for maintaining the cash
flow analysis, determining the amount eligible for investment, and all other administrative duties
necessary in executing and tracking the investments. Authorized Finance management staff will be
responsible for the actual investment decisions.
INTERNAL CONTROL: The CFO shall establish an annual process of independent review by an
external auditor in conjunction with the annual audit. This review will provide internal control by
assuring compliance with policies and procedures.
IV. INVESTMENT PORTFOLIO
RISK AND DIVERSIFICATION
The City recognizes that investment risks can result from issuer defaults, market price changes or various
technical complications leading to temporary illiquidity. Risk is controlled through portfolio diversification
which shall be achieved by the following general guidelines:
A. risk of issuer default is controlled by limiting investments to those instruments allowed by
the Act, which are described herein;
B. risk of market price changes shall be controlled by avoiding over -concentration of assets
in a specific maturity sector, limitation of the weighted average maturity of operating funds
investments to less than 18 months, and avoidance of over -concentration of assets in
specific instruments other than U.S. Treasury Securities, and U.S. Agency Obligations or
Securities and authorized investment pools.
Resolution No. 3588-7-18(R), Page 6
C.
risk of illiquidity due to technical complications shall be controlled by the selection of
'
securities dealers as described herein.
D.
Concentration of credit risk is controlled by limiting the amount of investment with a single
issuer to no more than 35% of the total portfolio with the exception of State approved
investment pools and U.S. Government Securities and Agency Obligation.
E.
Custodial credit risk is minimized by requiring pledged securities to be in the name of the
City.
AUTHORIZED MVESTMENTS
Assets of the City may be invested in the following instruments if deemed an authorized investment
pursuant to the Public Funds Investment Act, Chapter 2256, Texas Government Code, as amended:
A.
obligations of the United States of America, its agencies and instrumentalities;
B.
direct obligations of the State of Texas or its agencies and instrumentalities;
C.
collateralized mortgage obligations directly issued by a federal agency or instrumentality
of the United States, the underlying security for which is guaranteed by an agency or
instrumentality, of the United States;
D.
other obligations, the principal and interest of which are unconditionally guaranteed or
insured by, or backed by the full faith and credit of, the State of Texas or the United States
'
or the respective agencies and instrumentalities, including obligations that are fully insured
or guaranteed by the Federal Deposit Insurance Corporation or by the explicit full faith and
credit of the United States;
E.
obligations of states, agencies, counties, cities, and other political subdivisions of any state
rated as to investment quality by a nationally recognized investment rating firm not less
than A or its equivalent;
F. Certificates of deposit issued by a depository institution that has its main office or a branch
office in Texas. The certificate of deposit must be guaranteed or insured by the Federal
Deposit Insurance Corporation (FDIC) or its successor or the National Credit Union Share
Insurance Fund (NCUSIF) or its successor and secured by acceptable collateral securities
in the name of or benefit of the City and have a market value of at least 103% of the original
purchase price (less FDIC or NCUSIF insurance) plus accrued interest. Additionally, funds
invested by the City through a broker that has a main office or branch office in Texas and
is selected from a list approved by the City as required by section 2656.025 of the Public
Funds Investment Act or a depository institution that has a main office or branch office in
Texas and is selected by the City are authorized investments if the following conditions are
met:
a. the broker or depository institution selected by the City as specified above
arranges for the deposit of the funds in certificates of deposit in one or more
' federally insured depository institutions, wherever located, for the account of the
City;
Resolution No. 3588-7-18(R), Page 7
' b. the full amount of the principal and accrued interest of each of the certificates
of deposit is insured by the United States or an instrumentality of the United States;
and
c. the City appoints a depository bank or a clearing broker registered with the
Securities and Exchange Commission Rule 15c-3 (17CFR, Section 240 15c3-3) as
custodian for the City with respect to the certificates of deposit issued for account
to the City;
G. Public Funds Investment pools in the State of Texas which follow practices allowed by the
current law and whose investments may consist of CD's, U.S. Treasuries, U.S. Government
Agency Securities, U.S. Government Sponsored Corporation's Instruments, Commercial
Paper, Repurchase Agreements, or other investment instruments permitted by law.
H. Collateralized Repurchase Agreements that are contractual agreements between the City
and commercial banks, trust companies, state or federally chartered savings and loan
associations, and federally chartered savings banks. The Repo issuer sells acceptable
securities to the City and, in turn, the City agrees to resell the securities on a specific date
at a specified amount (original cost plus interest). Repurchase agreements are required to
be backed by acceptable collateral securities in the time of or benefit of the City and have
a market value of at least 103% of the original purchase price plus accrued interest.
1. Commercial Paper and Banker's Acceptances that have met all requirements of state law,
including ratings, term, and security.
J. No-load money market mutual fund that meets the requirements of state law as an
authorized investment under Chapter 2256 of the PFIA.
K. Guaranteed investment contracts that meet the requirements of state law as an authorized
investment for bond proceeds and that the governing body of the City has specifically
authorized guaranteed investment contracts as an eligible investment in the order,
ordinance, or resolution authorizing the issuance of bonds
L. The City is not required to liquidate investments that were an authorized investment at the
time of purchase.
M. If an authorized investment in the City's portfolio is rated in a way that causes it to become
an unauthorized investment, the investment officers of the City shall review the investment
to determine whether it would be more prudent to hold the investment until its maturity, or
to redeem the investment. Officers shall consider the time remaining until maturity of the
investment, the quality of the investment, and the quality and amounts of collateral which
may he securing the investment in determining the appropriate steps to take.
N. The City requires that all City depository accounts have sufficient pledged collateral,
valued at market, held by a third -party custodian designated by the City in the City's name,
and secured at 103% of the City balances less the amount of FDIC or NCUSIF insurance
at all times.
' The following is the maximum goal for various types of authorized deposits (shown as a percentage of total
investments) for each type of investment. The percentages are based mainly on the safety and liquidity of
the investment and to obtain the overall highest rate of return with appropriate risk for the City.
Resolution No. 3588-7-18(R), Page 8
A.
Collateralized/Insured Certificates of Deposits (CD's):
50%
B.
Collateralized Repurchase Agreements:
30%
C.
U.S. Treasury Obligations:
100%
D.
Municipal Investment Pool (MIP):
100%
E.
Commercial Bank Savings Accounts:
15%
F.
U.S. Government Agency Securities: non -callable
100%
G.
U.S. Government Agency Securities: callable
70%
H.
U.S. Government Sponsored Corporation's Instruments: non -callable
75%
1.
U.S. Government Sponsored Corporation's Instruments: callable
70%
J.
Commercial Paper:
20%
K.
Banker's Acceptances:
10%
L.
Guaranteed Investment Contracts:
25%
M.
State or Local Governmental Obligations:
30%
N.
Money Market Mutual Funds
15%-
0.
Local Government Investment Pools (LGIP)
100%
• Must
comply with percentage restriction in PFIA Section 2256.014(c)
The maximum term of any investment may not exceed five (5) years.
' Transaction bids may be obtained orally, in writing, electronically, or in any combination of these methods.
At least three competitive bids for individual security purchases are required, however, this provision
excludes transactions involving money market mutual funds, local government investment pools, securities
issued and deemed to be made at prevailing market rates, or a reinvestment of funds from a called security
with the original broker.
TRANSACTION SETTLEMENTS
The settlement of all transactions, except investment pool funds and mutual funds, shall be on a delivery
versus payment basis.
V. REPORTING
The CFO shall submit a signed quarterly investment report to the City Council that contains the information
required by the Public Funds Investment Act including but not limited to:
A. describing in detail the investment position of the entity on the date of the report;
B. stating the book value and market value of each separately invested asset at the beginning
and end of the reporting period by the type of asset and fund type invested;
C. stating the maturity date of each separately invested asset that has a maturity date; and
' D. stating the compliance of the investment portfolio of the City as it relates to the investment
strategy stated in the City's Investment Policy.
Resolution No. 3588-7-18(R), Page 9
' VI. SELECTION OF BROKERS AND SECURITY DEALERS
For brokers and dealers of govemment securities the City may select only those dealers reporting to the
Market Reports Division of the Federal Reserve Board of New York also known as the 'Primary
Government Security Dealers;' unless a comprehensive credit and capitalization analysis reveals that other
firms are adequately financed to conduct public business. Investment officials shall not knowingly conduct
business with any firm with whom public entities have sustained losses on investments. All securities
dealers shall provide the City with references from public entities which they are currently serving. The
City shall review the list of brokers on an annual basis pursuant to Section 2256.025 of the Public Funds
Investment Act.
All financial institutions and broker/dealers who desire to become qualified bidders for investment
transactions must supply the following as appropriate:
A. audited financial statements
B. proof of National Association of Securities Dealers (NASD) certification
C. proof of state registration
D. certification of having read the City's Investment Policy signed by a qualified
representative of the organization
E. acknowledgement that the organization has implemented reasonable procedures and
' control in an effort to preclude investment activities not authorized by this policy arising
out of investment transactions conducted between the City and the organization.
The list of brokers/dealers, financial institutions, banks, and investment pools shown are authorized to
conduct investment business with the City.
VII. INVESTMENT POLICY ADOPTION
The City of Allen Investment Policy shall be adopted by resolution of the City Council. The City Council
shall review this Investment Policy and investment strategies annually and any modifications made thereto
must be approved by the City Council.
Resolution No. 3588-7-18(R), Page 10
Authorized Broker/Dealer/Financial InstitutionsBanks/Investment Pools
American National Bank
Colleen Biggerstaff
972-727-5785
colleenbieeersmff@anlnx com
720 S. Greenville Ave.,
Admin. Officer
Ext 5929
GreeJebsen@anbtx.com
Allen, TX 75002
Greg Jebsen
214-863-6179 F
Cantor Fitzgerald & Co.
John Baldo
713-599-5192
gilbert.ramon@cantor.com
110 East 59a Street, 40
Gilbert Ramon
Floor
Chino Ammerman
New York, NY 10022
Comerica Bank
Vicky Weatherby
713-507-7022
vmweatherbv@comerica.com
MC6548
1508 West Mockingbird Ln
Dallas, TX 75235
Comerica Securities, Inc.
Chris Them
248-645-4173
clheut@u merica.eom
39400 Woodward Avenue
Institutional Sales
800-327-7058
ksrademaker@comenca.com
#160, MC: 7951
Kyle Rademaker
248-6454167 F
Bloomfield Hills, MI 48304
Financial Northeastern
Samuel Vaughan
973-396-1052
svauehan@financialnortheastern com
8717 Ken Aaron Court
512-550-7671 C
Austin, Texas 78717
866-328-3560 F
First Empire Securities
Luke Donenfeld
800-645-5424 Ext
Idonemeld@ lemione com
100 Motor Parkway
SVP—Fixed Income
4471
www lentnrc.com
2ntl Floor
Strategies
Hauppauge, NY 11788
FTN Financial
Zach Brewer
713-435-4351
Zach.Brewer@Bntinanciakcom
845 Crossover Ln., Ste. 150
281-642-4350 C
Memphis, TN 38117
Independent Bank
Amy Feagin
214-720-1205
nelrod@ibtx.com
1600 Redbud Blvd.
Noah Elrod
469-301-2796
McKinney, TX 75069
Interbank
Bill Lawrence
214-584-2417
Bill.Lawrence@imerbank.com
5307 E. Mockingbird Ln.
Treasury Services Officer
Dallas, TX 75260
Ladenburg Thalmann &
Steve Ned
800-540-7000
SNeri@ladenbure.com
Company
949-223-2911
2020 West Main Street
949-292-2580 C
Suite 650
Irvine, CA 92614
Legacy Texas Bank
Linda McMurtry
214-217-7024
linda.mcmurtry@?leeacvrexas.com
5000 Legacy Drive
214-843-2242 C
Suite 120
972-801-5797
Plano, TX 75024
Resolution No. 3588-7.18(R), Page 11
C
Pershing, LLC
Samuel Vaughan
201-413-3330
s_vau,han@financialnortheasterncom
One Pershing Plaza
Jersey City, NJ 07399
Southside Bank
Mary McLarry
903-535-4504
mary.melmy@southside.com
1201 S. Beckham Ave.
Tyler, TX 75701
Slifel Nicolaus & Co , Inc.
Michael B Bell
Michael
bellm@stifel.com
Fixed Income Inst Sales
Director
214-706-9469
Mhcl123@ blwmbere nct
5956 Sherry Lane
Nancy Grass
866-779-2415
crussni0 tifelenm
Suite 875
214-3684292
ngruss@hloombere net
Dallas, TX 75225
F
Nancy
515-661-6271
515-661-6334 F
Texas Class
Karen Proctor
2144734224
Karen.vi ctor@texawlass.com
2435 N. Central
Regional Director
Expressway
Suite 1200
Richardson, TX 75080
Texas Security Bank
Bonnie Nichols
469-398-4804
bonnie.nichols@texassecurilvbank co n
1212 Turtle Creek Blvd
Senior Vice President
214-571-9595 F
Dallas, TX 75207
Chief Compliance
Officer
TexPool Participant
Dianne Parker
866-839-7665
dparker@federatedmv cum
Services
866-839-3291
c/o Federated Investors
1001 Texas Avenue
Suite 1400
Houston, TX 77002
TexSTAR
Mary Ann Dunda
214-953-4086
MarvAnn.DundaC'HilltonSecurities com
1201 Elm Street
Managing Director
800.839-7827
Suite 3500
214-753-8878 F
Dallas, TX 75270
Wells Fargo Brokerage
Susan T Ward
Dallas
wmdst@wellsfareo.com
Services, LLC
Huey Scott
800-937-0998
Huev.H.Scort@welisfareo.com
1445 Ross Avenue
Susan
Suite 210
214-740-1586
Dallas, TX 75202
214-740-9990
F
Huey
214-777-4033
Zions First National Bank
Kathleen Sullivan
801-5244819
mmo@hloomberu.net
Capital Markets
Assistant Vice President
801-5244659 F
One South Main Street
17' Floor
Sall Lake City, UT 84111
Resolution No. 3588-7-18(R), Page 12