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i. Control of collusion <br />ii. Separation of transaction authority from accounting and recordkeeping <br />iii. Custodial safekeeping <br />iv. Avoidance of physical delivery securities of marketable securities <br />v. Clear delegation of authority to subordinate staff members <br />vi. Written confirmation of transactions for investments and wire transfers <br />vii. Dual authorizations of wire transfers <br />viii. Staff training and <br />ix. Review, maintenance and monitoring of security procedures both manual and <br />automated. <br />F. External Controls <br />The Office of the State Auditor requires that in accordance with Revised Code of <br />Washington 43.09.260, the City must undergo annual financial examinations performed <br />by State Examiners. Investment management is to be included as part of the annual <br />independent audit to assure compliance with this investment policy. <br />8. Authorized Financial Dealers <br />A. Broker/Dealers <br />The Finance Director or designee shall maintain and review annually a list of all authorized <br />financial institutions and broker/dealers that are approved to transact with the City for <br />investment purposes. Any firm is eligible to make an application to the City. Additions <br />and deletions to the list will be made at the City's discretion. All broker/dealers and <br />financial institutions who desire to do business with the City must supply the Finance <br />Director with the following: <br />i. Annual audited financial statements. <br />ii. Proof of FINRA (Financial Industry Regulatory Authority) certification. <br />iii. Proof of registration with the State of Washington. <br />iv. A completed Broker/Dealer questionnaire and a certification of having read the <br />City Investment Policy. <br />B. Investment Advisors <br />The City may contract with an external investment advisor to assist with the management <br />of the City's investment portfolio in a manner that is consistent with the City's objectives <br />and this policy. Advisors must be registered under the Investment Advisers Act of 1940 <br />and must act in a non -discretionary capacity, requiring approval from the City prior to all <br />transactions. <br />The Finance Director or designee may utilize the investment advisor's approved <br />broker/dealer list in lieu of the City's own approved list. The advisor must submit the <br />approved list to the City annually and provide updates throughout the year as they occur. <br />The advisor must maintain documentation of appropriate license and professional <br />credentials of broker/dealers on the list. The annual investment advisor broker/dealer <br />review procedures include: <br />City of Tukwila Investment Policy 2025 Page 8 of 18 <br />12 <br />