HomeMy WebLinkAboutDocumentation_Pension Public Safety_Tab 05B_08/10/2004.:
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MEMORANDUM
TO: Members of Public Safety Pension Board
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FROM: Betty Laur ~ , .rri
DATE: July 30, 2004
SUBJECT: Investment Policy Guidelines
Attached for comparison purposes is the new investment guidelines document prepared
by Mr. Bogdahn, followed by our current investment guidelines document.
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Village of Tequesta
Public Safety Officers' Retirement Plan
Investment Policy Statement
I. PURPOSE OF INVESTMENT POLICY STATEMENT
The Pension Board of Trustees maintains that an important determinant of future
investment returns is the expression and periodic review of the Fund's investment objectives.
To that end, the Trustees have adopted this statement of Investment Policy.
In fulfilling their fiduciary responsibility, the Trustees recognize that the retirement
system is an essential vehicle for providing income benefits to retired participants or their
beneficiaries. The Board also recognizes that the obligations of the Fund are long-term and
that investment policy should be made with a view toward performance and return over a
number of years. The general investment objective, then, is to obtain a reasonable total rate
of return -defined as interest and dividend income plus realized and unrealized capital gains
or losses -commensurate with the Prudent Investor Rule and any other applicable statute.
Reasonable consistency of return and protection of assets against the inroads of
inflation are paramount. However, the volatility of interest rates and securities markets make
it necessary to judge results within the context of several years rather than over short periods
of two years or less.
The Pension Board of Trustees will employ a professional Investment Management
firm to invest the assets of the fund. Within the parameters allowed in this IPS, the asset
allocation of the fund is solely at the Investment Manager's discretion, including sector
weightings and investment style.
The Trustees, in performing their investment duties shall comply with the fiduciary
standards set forth in Employee Retirement Income Security Act of 1974 (ERISA) at 29
U.S.C. s. 1104(a) (1) (A) - (C). In case of conflict with other provisions of law authorizing
investments, the investment and fiduciary standards set forth in this section shall prevail.
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II. INVESTMENT PERFORMANCE OBJECTIVES
The below listed performance measures will be used as objective criteria for
evaluating effectiveness of the investment manager.
A. Total Fund Performance
The performance of the total Fund will be measured for rolling three
and five year periods. These periods are considered sufficient to
accommodate the market cycles experienced with investments. The
performance of this portfolio will be compared to the return of a
portfolio comprised of 60% Standard & Poor's 500 Stock Index, 40%
Lehman Brothers Government /Credit Intermediate Bond Index.
2. On a relative basis, it is expected that the money manager's
performance with regard to the total return of combined equity, fixed
income, and cash portfolio, will be in the top 40% of the Mobius
Universe over three to five year periods.
3. On an absolute basis, it is expected that total return of the combined
equity, fixed income, and cash portfolio, will equal or exceed the
actuarial earnings assumption (8 %), and equal or exceed the
Consumer Price Index plus 3% over three to five year periods.
B. Equity Performance
The equity portion of the portfolio, defined as common stocks and convertible
bonds, is expected to perform at a rate at least equal to the S&P 500 Index and
be in the top 40% of the Mobius Universe.
C. Fixed Income Performance
The overall objective of the fixed income portion of the portfolio is to add
stability, consistency and safety to the total fund. The fixed income portion of
the portfolio, defined as fixed income and preferred stocks, is expected to
perform at a rate at least equal to the Lehman Brothers Government /Credit
Intermediate Bond Index, and in the top 40% of the Mobius Universe.
III. INVESTMENT GUIDELINES
A. Authorized Investments
All investments made or held in the fund shall be limited to:
1. Time, savings, and money market deposit accounts of a national
bank, a state bank or a savings and loan institution, insured by the
Federal Deposit Insurance Corporation, provided the amount
deposited does not exceed the insured amount.
2. Obligations issued by the United States Government or obligations
guaranteed as to principal and interest by the United States
Government or by an agency of the United States Government.
3. Stocks, commingled funds administered by national or state banks,
mutual funds and bonds or other evidences of indebtedness, issued
or guaranteed by a corporation organized under the laws of the
United States, any state or organized territory of the United States
or the District of Columbia, provided:
a. The securities meet the following ranking criteria:
i. Fixed Income: Standard & Poor's Investment Grade
or Moody's Investment Grade
ii. Equities: Value line ranking for safety 1,2,or 3,
except that 20% of the funds assets may be
invested in securities not meeting this
requirement.
iii. Money Market: Standard & Poor's Al or Moody's Pl.
b. Not more than 5% of the Fund's assets shall be invested in the
common stock or capital stock of any one issuing company, nor
shall the aggregate investment in any one issuing company
exceed 5% of the outstanding capital stock of the company.
c. The value of bonds issued by any single corporation shall not
exceed 10% of the total fund.
4. Commingled stock, bond or money market funds whose investments
are restricted to securities meeting the above criteria.
5. Foreign securities.
B. Limitations
Investments in corporate common stock and convertible bonds shall not
exceed 60% at cost or 70% of the fund assets at market value.
2. Foreign securities shall not exceed 10% of the value at cost of the fund.
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C. Absolute Restrictions
There will be no investment activity in the following:
1. Short sales, margin purchases, or borrowing.
2. Private placement or other restricted securities (not freely marketable).
3. Commodities.
4. Puts, calls, straddles or hedging.
5. Warrants or other options, except as part of purchase of another security.
6. Tax-exempt bonds.
7. Repurchase Agreements
8. Venture capital.
9. Illiquid investments, as described in Chapter 215.47, Florida Statutes
10. Any investment prohibited by State or Federal Law.
11. Any investment not specifically allowed as part of this policy.
D. Trading Parameters
When feasible and appropriate, all securities shall be competitively bid. Except as
otherwise required by law, the most economically advantageous bid shall be selected.
Commissions paid for purchase of securities must meet the prevailing best-execution
rates.
IV. COMMUNICATIONS
A. On a monthly basis, the custodian shall supply an accounting statement that will
include a summary of all receipts and disbursements and the cost and the market value
of all assets. On a quarterly basis, the manager shall provide a written report affirming
compliance with the security restrictions of Section III above and a summary of
common stock diversification and attendant schedules. In addition, the manager shall
deliver each quarter a report detailing the Fund's performance, adherence to the
investment policy, forecast of the market and economy, portfolio analysis and current
assets of the Trust. Written reports shall be delivered to the Trustees within 60 days
of the end of the quarter. A copy of the written report shall be submitted to the Village
Manager, and shall be available for public inspection, The Investment Manager will
provide immediate written and telephone notice to the Trustees of any significant
market related or non-market related event, specifically including, but not limited to,
any deviation from the standards set forth in Section III above.
B. The manager will disclose any securities that do not comply with section III in each
quarterly report.
C. If the Fund owns investments, that complied with section III at the time of purchase,
which subsequently exceed the applicable limit or do not satisfy the applicable
investment standard, such excess or noncompliant investments may be continued until
it is economically feasible to dispose of such investment in accordance with the
prudent expert standard of care, but no additional investment may be made unless
authorized by law or ordinance.
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D. The Trustees shall retain a monitoring service to evaluate and report on a quarterly
basis the rate of return and relative performance of the Fund.
E. The Trustees will meet quarterly to review the monitoring service's Performance
Report. The Trustees will meet with the investment manager and appropriate outside
consultants to discuss performance results, economic outlook, investment strategy and
tactics and other pertinent matters affecting the Fund on a quarterly basis.
F. At least annually, the Trustees shall provide the Investment Manager with projected
disbursement needs of the plan, so that the investment portfolio can be structured in
such manner as to provide sufficient liquidity to pay obligations as they come due. To
this end, the Investment Manager should, to the extent possible, attempt to match
investment maturities with known cash needs and anticipated cash-flow requirements.
V. COMPLIANCE
A. It is the direction of the Trustees that the plan assets are held by a third party
custodian, and that all securities purchased by, and all collateral obtained by, the plan
shall be properly designated as plan assets. No withdrawal of assets, in whole or in
part, shall be made from safekeeping except by an authorized member of the board of
Trustees or their designee. Securities transactions between abroker-dealer and the
custodian involving purchase or sale of securities by transfer of money or securities
must be made on a "delivery vs. payment" basis to insure that the custodian will have
the security or money in hand at conclusion of the transaction.
B. At the direction of the Trustees, operations of the fund shall be reviewed by
independent certified public accountants, as part of any financial audit periodically
required. Compliance with the Trustees' internal controls shall be verified. These
controls have been designed to prevent losses of funds that might arise from fraud,
error, or misrepresentation by third parties or imprudent actions by the Board or
employees of the plan sponsor, to the extent possible
C. Each member of the Board of Trustees shall participate in a continuing education
program relating to investments and the Trustee's responsibilities to the fund. It is
highly suggested that this education process begin during the Trustees' first term.
D. With each actuarial valuation, the Board of Trustees shall determine the total expected
annual rate of return for the current year, for each of the next several years and for the
long term thereafter. This determination shall be filed promptly with the Department
of Management Services, the plan's sponsor and the consulting actuary.
E. In general, proxies shall be voted in accordance with the Trustees proxy policy, which
states that "The proxy votes must be exercised for the exclusive benefit of the
participants of the Fund." On a regular basis, at least annually, each manager shall
report a record of his or her proxy vote.
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VL CRITERIA FOR INVESTMENT MANAGER REVIEW
The Board wishes to adopt standards by which judgments of the ongoing performance
of a portfolio manager may be made. With this in mind, the following are adopted:
If, at any time, any one of the following is breached, the portfolio manager will be
warned of the Board's serious concern for the Fund's continued safety and performance.
A. Four consecutive quarters of total Fund performance below the 50th percentile in
manager performance rankings.
B. Standard deviation for the Fund in excess of 120% of the Policy.
C. Loss by the manager of any senior investment personnel.
D. Any change in basic investment philosophy by the manager.
E. Failure to attain a 60% vote of confidence by the Board of Trustees.
F. Failure to observe the security quality restrictions of section III.
Nothing in this section shall limit or diminish the Trustees' right to terminate the manager at
any time for any reason.
VII. FLORIDA STATUTES AND APPLICABLE VILLAGE ORDINANCES
If, at any time, this document is found to be in conflict with Florida Statutes or the
applicable Village Ordinances, the Statutes and Ordinances shall prevail.
VIII. REVIEW AND AMENDMENTS
It is the Trustees intention to review this document periodically and to amend this
statement to reflect any changes in philosophy, objectives, or guidelines. In this regard, the
money manager's interest in consistency in these matters is recognized and will be taken into
account when changes are being considered. If, at any time, the Investment Manager feels
that the specific objectives defined herein cannot be met, or the guidelines constrict
performance, the Trustees should be notified in writing. By initial and continuing acceptance
of this Investment Policy Statement, the Investment Manager concurs with the provisions of
this document.
Date:
2004
NORTHSTAR CAPITAL MANAGEMENT
By:
As:
Date:
2004
VILLAGE OF TEQUESTA PUBLIC
SAFETY OFFICERS' RETIREMENT
PLAN
By:
As:
Chairman, Board of Trustees
r
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VILLAGE OF TEQUESTA
GENERAL EMPLOYEES' PENSION FUND
Statement of Investment Policies
and Objectives
December 8, 2003
. .
VILLAGE OF TEQUESTA GENERAL EMPLOYEES'
PENSION TRUST FUND
INVESTMENT POLICY STATEMENT
1. SCOPE & PURPOSE
The Board of Trustees maintain that an important determinant of future investment
returns is the expression and periodic review of the Fund's investment objectives. To that
end, the Trustees have adopted this statement of Investment Policy.
In fulfilling their fiduciary responsibility, the Trustees recognize that the retirement
system is an essential vehicle for providing income benefits to retired participants or their
beneficiaries. The Board also recognizes that the obligations of the Fund are long-term and
that investment policy should be made with a view toward performance and return over a
number of years. The Board of Trustees recognizes that the general investment objective
is to maximize return consistentwith risks incumbent in each investment. The risk-adjusted
return required by the Retirement System must be achieved by compliance with the
Prudent Investment Rule and any other applicable statute or requirement. The Board of
Trustees further acknowledges that section 112.661(4), Florida Statutes, shall supersede
any conflicting provisions of law guiding investments.
The purpose of this Statement is to establish a clear understanding between the
Trustees of the Fund and the Fund's investment manager(s) of the policies and objectives
of these assets. This statement will outline an overall philosophy that is specific enough
for the Fund's investment manager(s) to know what is expected, but flexible to allow for
changing economic conditions.
2. INVESTMENT OBJECTIVES
Reasonable consistency of return and protection of assets against the inroads of
inflation are paramount. However, the volatility of interest rates and securities markets
make it necessary to judge results within the context of several years rather than over short
periods of one or two years or less.
3. PERFORMANCE MEASUREMENT
The below listed performance measurements will be used as objective criteria for
evaluating effectiveness of the Investment Manager. Performance will be measured
quarterly:
A. Total Fund Performance
(1) The performance of the total Fund will be measured for rolling three
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and five year periods. These periods are considered sufficient to
accommodate the market cycles experienced with investments. The
performance of this portfolio will be currently compared to the return
of a portfolio comprised of 60% Standard & Poor's 500 Index and 40%
of the Lehman Brothers Intermediate Bond Index.
(2) On a relative basis, it is expected that the investment manager's
performance with regard to the total return of combined equity, fixed
income and cash portfolio, will be in the top 40% of the Russell 1000
Universe over three to five year periods.
(3) On an absolute basis, it is expected that the total return of the
combined equity, fixed income and cash portfolio, will equal or exceed
the actuarial earnings assumption, and equal or exceed the Consumer
Price Index plus 3% over three to five year periods.
B. Common Stock Performance
The Equity portion of the portfolio, defined as common stocks, is expected
to perform at a rate of at least equal to the Standard 8~ Poor's 500 Index.
C. Bond Performance
The bond portion of the portfolio, defined as fixed income securities and
preferred stock, is expected to perform at a rate at least equal to the Lehman
Brothers Intermediate Bond Index.
4. INVESTMENT AND FIDUCIARY STANDARDS
In accordance with Florida Statute 112.661 (4), the Board and its investment
managers and investment monitor shall comply with the fiduciary standards set forth in the
Employee Retirement Income Security Act of 1974 at 29 U.S.C. s. 1104 (a) (1) (A) - (C),
set forth below:
Section 1104 -Fiduciary duties
(a) Prudent Man Standard of Care
(1) Subject to Sections 1103 (c) and (d), 1342 and 1344 of the title, a
fiduciary shall discharge its duties with respect to a plan solely in the
interest of the participants and beneficiaries and -
(A) For the exclusive purpose of:
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(i) providing benefits to participants and their beneficiaries;
and
(ii) defraying reasonable expenses of administering the
plan;
(B) With the care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent man acting in a
like capacity and familiar with such matters would use in the
conduct of an enterprise of a like character and with like aim;
(C) By diversifying the investments of the plan so as to minimize
the risk of large losses, unless under the circumstances it is
clearly prudent not to do so.
5. AUTHORIZED INVESTMENTS
A. Authorized investments
All investments made or held by the fund shall be limited to:
(1) Time, savings and money market deposit accounts of a national Bank,
a state bank insured by the Bank Insurance Fund or a
savings/building and loan association, insured by the Savings
Association Insurance Fund which is administered by the Federal
Deposit Insurance Corporation or a state or federal chartered credit
union whose share accounts are insured by the National Credit Union
Share Insurance Fund and provided the amount deposited does not
exceed the insured amount.
(2) Obligations issued by the United States Government or Obligations
guaranteed as to principal and interest by the United States
Government or by an agency of the United States Government.
(3) Stocks, bonds or other evidences of indebtedness issued or
Guaranteed by a corporation organized under the laws of the United
States, any state or organized territory of the United States, or the
District of Columbia, provided that:
(a) Equities are limited to those traded on a recognized national
Exchange or NASDAQ.
(b) Fixed income securities are limited to those traded on a
recognized national exchange or through the over-the-counter
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market.
(c) The security meets the following ranking criteria:
i) Fixed income: Standard & Poor's AAA, AA, A, BAA or
Moody's Aaa, Aa, A, Baa.
ii) Cash Reserves: Short term investments due less than
1 year where overall quality and minimal risk guidelines
apply. Investments which may be used are: money
market funds of custodians, Certificates of Deposit, U.S.
Government Obligations and Commercial Paper rated
A-1(Standard & Poor's) or P-1 (Moody's).
(d) Not more than 5% of the Fund's assets shall be invested in the
common stock or capital stock of any one issuing company,
nor shall the aggregate investment in any one issuing company
exceed 5% of the outstanding capital stock of the company.
(4) Foreign stocks, bonds or other evidence of indebtedness.
(5) Commingled stock, bond or money market funds whose investments
are restricted to securities meeting the criteria in this Section 3.
B. Limitations
(1) Investments in foreign and domestic corporate common stock
(including American Depository Receipts) and convertible bonds shall
not exceed 60% of the Fund assets at cost. However, the investment
manager will promptly notify the Chairman of the Trustees if the
portion of the Fund invested in common stock declines below 40% at
market value or exceeds 70% at market value.
(2) Not more than 25% of the market value of the Bond Portfolio may be
invested in bonds rated BAA/Baa (investment grade) at time of
purchase.
(3) Not more than 10% of the market value of the equity and fixed income
portions of the assets in the fund shall be invested in foreign
securities.
(4) The following investments are expressly prohibited:
(a) Investing in Real Estate, private placements, lettered stock or
from speculating in fixed income or interest rate futures.
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(b) Repurchase agreements.
(c) Investments not specifically described in Section 3A above.
(d) Or any investments that are prohibited under Florida Statutes
112.661.
(5) If the fund owns securities, which complied with this Section 3 at time
of purchase, but which are subsequently downgraded or become non
-compliant while held, the manager will dispose of such securities
when economically feasible, but no additional investment in such
securities shall be made.
6. MATURITY AND LIQUIDITY REQUIREMENTS
It is also the obligation of the Plan and the duty of the Board of Trustees to structure
the portfolio to provide sufficient liquidity to pay obligations as they come due without
compromising the long-term investment objectives of the Plan. To achieve this goal, the
Board will attempt to match known cash needs and anticipated cash flow requirements.
The guidelines and limits on the maturities listed are designed to accomplish this goal.
7. PORTFOLIO COMPOSITION
The Trustees believe that it should be the function of the investment managers to
allocate the Fund's assets among common stocks, fixed income instruments and cash
reserves. Accordingly, it is the philosophy of the Trustees that the asset mix of the Fund
should be:
Maximum 60%
Minimum 0%
Equity
Equity
Maximum 60%
Minimum 35%
Maximum 50%
Minimum 0%
Fixed Income
Fixed Income
Cash Equivalents
Cash Equivalents
Percentages shall be based on market value at the end of each quarter.
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8. RISK AND DIVERSIFICATION
Investments held shall be diversified to the extent practicable to control the risk of
loss resulting from over concentration of assets. Diversification strategies within the
following established guidelines shall be reviewed and revised periodically, as deemed
necessary by the Board. The asset classes listed below represent the Board's policy of
investing in a broadly diversified portfolio of assets.
9. EXPECTED ANNUAL RATE OF RETURN
The Board has determined, in consultation with its actuary, consultant and
investment professionals, to use eight percent (8.0%) as the actuarial assumption for return
on this Pension Fund.
10. THIRD-PARTY CUSTODIAL AGREEMENTS
The Board has retained athird-party to custody the fund's assets. All securities shall
be designated as an asset of the Board, and no withdrawal of securities, in whole or in part,
shall be made from safekeeping except by an authorized member of the Board or the
Board's designee. Securities transactions between abroker-dealer and the custodian
involving purchase or sale of securities by transfer of money'or securities must be made
on a "delivery vs. payment" basis, if applicable, to ensure that the custodian will have the
security or money, as appropriate in hand at the conclusion of the transaction. In order to
further guarantee the safe delivery and holding of all securities and Plan assets, it is the
policy of the Board that no withdrawal of securities shall be made except by an authorized
member of the Board or the Board's designee.
11. MASTER REPURCHASE AGREEMENTS
All approved institutions that transact master repurchase agreements on behalf of
the Fund, including short term investments by the Fund's custodian, shall execute and
adhere to the requirements of the Master Repurchase Agreement.
12. BID REQUIREMENT
The Board requires that the Investment Manager(s), in accordance with their
fiduciary relationship to the Board, competitively bid securities as appropriate and to select
the most advantageous bid. The relationship between the Board and its investment
managers is documented in the agreements between the Fund and the investment
managers.
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13. INTERNAL CONTROLS
The Fund shall be governed by a set of written internal controls and operational
procedures, which shall be periodically reviewed bythe Fund's Certified PublicAccountant.
The Board has the services of the City's retained independent Certified Public
Accountant on an annual basis and requires reports from the Fund's Investment Consultant
quarterly. This policy is designed to safeguard the Fund from losses that might arise from
fraud, error or misrepresentations by third parties, or imprudent actions by the Board or
employees of the plan sponsor.
14. CONTINUING EDUCATION
The Board acknowledges the importance of continuing education. To that end,
board members are encouraged to attend educational conferences in connection with their
investment duties and responsibilities as trustees.
15. REPORTING
The Fund's Investment Consultants shall provide quarterly reports of the Fund's
investment activities. These reports shall be public records and shall be submitted to the
plan sponsor as required by law.
16. VALUATION OF ILLIQUID INVESTMENTS
No illiquid investments shall be utilized by this Fund.
17. COMMUNICATIONS
A. The custodian shall apprise the Trustees of all transactions and shall forward
all proxies to the manager within 14 calendar days. On a monthly basis, the
custodian shall supply an accounting statementwhich will include a summary
of all receipts and disbursements and the cost and the market value of all
assets. On a quarterly basis, the manager shall provide a written report
affirming compliance with the security restrictions of Section 3 above and a
summary of common stock diversification and attendant schedules. In
addition, the manager shall deliver each quarter a report detailing the fund's
performance, adherence to the investment policy, forecast of the market and
economy, portfolio analysis and the current assets of the Trust. Written
reports and personal presentations shall be delivered to the Trustees at their
request following the end of the quarter.
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B. The manager will disclose any securities which are not in compliance with
Section 3 in each quarterly report if requested.
C. The Trustees shall retain a monitoring service to evaluate and report on a
quarterly basis the rate of return and relative performance of the Fund.
D. The Trustees will meet periodically with the monitoring service's
representative to review the Performance Report. The Trustees will meet
with the investment manager and appropriate outside consultants to discuss
performance results, economic outlook, investment strategy and tactics and
other pertinent matters affecting the Fund on a quarterly basis.
E. The equity manager shall report to the Trustees on a quarterly basis with
respect to proxies, the issues, votes and dates, and if not voted, a written
explanation.
18. DISCRETIONARY AUTHORITY
The manager(s) have full discretion to invest in any particular investment, subject
to this statement, the pension plan ordinance, and applicable State law.
19. PROXY VOTING
In general, proxies shall be voted in accordance with the Trustees proxy policy,
which is:
"The Board of Trustees of the Village of Tequesta Public Safety Pension
Trust Fund recognizes that proxy voting powers are an asset of the Fund and
must be exercised for the exclusive benefit of the participants in the Fund."
On a regular basis, no less frequently than annually, each manager shall
report a record of his or her proxy vote.
20. POLICIES AND GUIDELINES REVIEW
It is the Trustees intention to review this document periodically and to amend this
statement to reflect any changes in philosophy, objectives or guidelines. In this regard, the
investment manager's interest in consistency in these matters is recognized and will be
taken into account when changes are being considered. If at any time any portfolio
manager feels that the specific objectives defined herein cannot be met, or the guidelines
constrict performance, the Trustees should be notified in writing. By initial and continuing
acceptance of this Investment Policy Statement, the investment manager concurs with the
provisions of this document.
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21. CRITERIA FOR INVESTMENT MANAGER REVIEW
The Board wishes to adopt standards by which judgments of the ongoing
performance of a portfolio manager may be made. With this in mind, the following are
adopted:
If, at any time, any one of the following is breached, the portfolio manager will be
notified of the Board's serious concern for the Fund's continued safety and performance.
A. Four consecutive quarters of total Fund performance below the 50th
percentile in managers performance rankings.
B. Standard deviation for the Fund in excess of 120% of the benchmark index.
C. Loss by the manager of any senior investment personnel servicing the
account.
D. Any change in basic investment philosophy by the manager.
E. Failure to attain a 60% vote of confidence by the Board of Trustees.
F. Failure to observe the security quality restrictions of Section 3.
The signatures below affirm that this statement and addenda have been read,
understood, and accepted.
In witness whereof the Board of Trustees has adopted this Statement of Investment
Policies and Objectives this 9'h day of December, 2003.
TRUSTEES
n
Tye signatures below affirm that this statement and addenda have been read, understood,
and accepted.
~~ V -~C~..-,
Peter Van Beuren, Investment Manager
Northstar Capital Management, Inc.
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