HomeMy WebLinkAboutMINUTES - 06042013 - C.104RECOMMENDATION(S):
Approve amendments to the Contra Costa County Post-Employment Health Care Plan Investment Policies and
Guidelines to authorize the investment in Alternative Assets (last revised June 2011).
FISCAL IMPACT:
No specific fiscal impact.
BACKGROUND:
As a matter of best practices the Post-Retirement Health Benefits Trust Agreement Advisory Body annually reviews
the Investment Policies and Guidelines Document. Considerations are made as to whether or not:
any cleanup language is necessary to clarify meaning and application of the policies and guidelines;
any new legislation and regulations governing the investment practice of the Plan’s funds have been passed
since the last review;
new asset categories and/or allocations affecting the management and performance of the investment portfolio
have been introduced; and
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 06/04/2013 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I Supervisor
Candace Andersen, District II Supervisor
Mary N. Piepho, District III Supervisor
Karen Mitchoff, District IV Supervisor
Federal D. Glover, District V Supervisor
Contact: Lisa Driscoll, County Finance
Director (925) 335-1023
I hereby certify that this is a true and correct copy of an action taken and entered on the
minutes of the Board of Supervisors on the date shown.
ATTESTED: June 4, 2013
David Twa, County Administrator and Clerk of the Board of Supervisors
By: Stacey M. Boyd, Deputy
cc: Robert Campbell, Auditor-Controller, Russell Watts, Treasurer-Tax Collector, David Twa, County Administrator, Patrick Godley, Health Services Chief
Financial Officer, Lisa Driscoll, County Finance Director
C.104
To:Board of Supervisors
From:Post Retirement Health Benefits Trust Agreement Advisory Body
Date:June 4, 2013
Contra
Costa
County
Subject:Revisions to the CCC Post-Employment Health Care Plan Investment Policies and Guidelines (Last Revised June
2011)
BACKGROUND: (CONT'D)
new guidelines and requirements have been added to further guide and/or restrict the investing of funds.
For 2013, the following changes were reviewed by the Advisory Body and are presented to the Board of
Supervisors for approval:
1. Page 1, Added revision date
2. Page 2, Correction of the meaning PARS from Public Agency Retirement System to Public Agency Retirement
Services
3. Page 2, Update in the description of Risk Tolerance from Moderately Aggressive Objective to Balanced
Objective
4. Page 2, Adjustment to the Strategic Range of Asset Classes as follows: Cash: 0-5%, Fixed Income: 30-50%,
Equity: 45-65%, Alternatives (NEW) 5-20%.
5. Page 2, Additional language to Communication Schedule information that committee meetings are held
quarterly.
6. Page 4, Changing of the title Investment Manager to Portfolio Manager to be consistent with the intent and use
of a term throughout the document.
7. Page 5, Additional language in item 2 under Portfolio Managers Responsibilities, that the Portfolio Manager
would advise the Plan Administrator about the selection of and the allocation of asset categories every three years
or as needed.
8. Page 6, Additional language item 2 under Quarterly Reports (Portfolio Reporting Requirements), stating the
quarterly report will also include median return of peers.
9. Page 7, Addition of new asset class, Alternatives, in section VII, Asset Categories, and a description of these
securities.
10. Page 8, Adjustments in the benchmark composition in section VIII, Investment Objectives, to reflect the
addition of the Hedge Fund Research Inc (HFRI) for Alternatives.
11. Page 9, Addition of letter H under Investment Objectives describing Alternative Funds.
12. Page 9, Modification to the Target Mix and Allocation Ranges in Table 1 of the Asset Allocation.
13. Page 10, Inclusion of Alternatives category under Investment Guidelines with an explanation that the total
investment amount for any alternative fund would not exceed 5% of total Plan assets.
14. Page 11, Addition of a paragraph at the bottom of section XI, Prohibited Assets, explaining that this section
applied to the direct investment managers but not to third-party managers.
15. Page 12, Addition of bullet item (3rd) relating to when an investment mutual fund may be removed from the
portfolio, which is if the annualized return trails the benchmark or median return on a three-year basis for more
than three consecutive quarters.
The red-lined current policy and a copy of the revised policy are included as Attachments A and B. Post
Retirement Health Benefits Trust documents are available on the Post Retirement Health Benefits Trust
Agreement Advisory Body website (http://ca-contracostacounty.civicplus.com/index.aspx?NID=2915).
CONSEQUENCE OF NEGATIVE ACTION:
County's assets currently held by HighMark Capital Management will not be invested in Alternatives. This
restriction may impact the potential earning of these funds.
CHILDREN'S IMPACT STATEMENT:
None.
ATTACHMENTS
Attachment A
Attachment B
Contra Costa County Investment Policies & Guidelines February Revised June 2013
1
COUNTY OF CONTRA COSTA
POST-EMPLOYMENT HEALTH CARE
PLAN
INVESTMENT POLICIES AND
GUIDELINES DOCUMENT
Adopted February 2011
Revised June 2011
Revised June 2013
Contra Costa County Investment Policies & Guidelines February Revised June 2013
2
Contra Costa County Post-Retirement Health Care Plan
Investment Policies and Guidelines Document
In response to the Government Accounting Standards Board (GASB) Statement Number 45 disclosure
requirements for Other Post-Employment Benefit (OPEB) Plans, Contra Costa County has adopted a
Section 115 Trust Plan that seeks to satisfy these liabilities for certain eligible employees.
Executive Summary
Plan Sponsor: Contra Costa County (County)
Advisory Body: Post Retirement Health Benefits Trust Agreement Advisory Body
Plan Administrator: Contra Costa County Treasurer-Tax Collector
Trust Administrator: Public Agency Retirement Systems Services (PARS)
Trustee: U.S. Bank, N.A.
Investment Advisor: U.S. Bank, N.A., as Trustee has hired HighMark Capital
Management (Portfolio Manager) via a sub-advisory agreement
to serve as the Investment Advisor.
Investment Authority: Full Investment Authority
Account Number: To be determined
Current Assets: $95,160,073.94 (as of December 31, 2012)
Annual Contributions: Evaluated annually
Risk Tolerance: Moderately Balanced Objective
Time Horizon: Long-Term
Assumed Earnings Rate: 6.25%
Investment Objective: The primary objective is to maximize total Plan return,
subject to the risk and quality constraints set forth below. The Plan’s targeted rate of
return is 6.25%. The asset allocation ranges for the Plan is listed below:
Strategic Ranges: Cash: 0 - 5% Cash Fixed Income: 3530-5550%
Equity: 45-65% Alternatives 5 – 20%
Communication Schedule: See Portfolio Reporting Requirements
Committee meetings quarterly
Income Needs/Cash Flow Required: To be determined annually by the Plan Administrator.
Unique Needs and Circumstances: None Known
HCM Portfolio Manager: Andrew Brown, CFA 415-705-7605
Andrew.Brown@highmarkcapital.com
HCM Back up -Portfolio Manager: Anne E. Wimmer, CFA 310-550-6457
Anne.Wimmer@highmarkcapital.com
U.S Bank Administrative Officer: Fran Schoenfeld, 949-224-7204
Fran.Schoenfeld@usbank.com
The managing director for HighMark Capital Management is Kevin Rogers, he can be reached at 949-553-2580
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Contra Costa County Investment Policies & Guidelines February Revised June 2013
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Portfolio Constraints
Income Needs/Cash Flow Required: Income needs are expected to be minimal in the
initial years of the Plan
Client (Signature): Date:
HCM Portfolio Manager: Date:
U.S. Bank Administrative Officer: Date:
Contra Costa County Investment Policies & Guidelines February Revised June 2013
4
I. INTRODUCTION
The Board of Supervisors (the “Board”) of the County of Contra Costa has established the
following Investment Policies and Guidelines Document (the “Document”) for the investment of
the trust fund (the “Trust”) of the Contra Costa County Post-Retirement Health Benefits Plan (the
“Plan”). The Board reserves the right at any time and from time to time to amend, supplement or
rescind this document.
II. OVERVIEW
The purpose of this Document is to assist the Board and the Investment Portfolio manager
Manager in effectively supervising, monitoring and evaluating the investment of the Plan’s
portfolio. The investment program is defined in the various sections of the Document by:
A. Stating the Board’s attitudes, expectations, objectives and guidelines for the investment
of all assets.
B. Setting forth an investment structure for managing the Plan’s portfolio. This structure
includes various asset classes, investment management styles, asset allocation and
acceptable ranges that, in total are expected to produce an appropriate level of overall
diversification and anticipated total investment return over the investment time horizon.
C. Encouraging effective communications between the Board and the Investment Portfolio
managerManager.
D. Complying with all applicable fiduciary, prudence and due diligence requirements
experienced investment professionals would utilize, and with all applicable laws, rules
and regulations of various local, state and federal entities that may impact the Plan’s
assets.
III. AUTHORITY
The investment of the assets for the Trust shall be in accord with applicable law, including but not
limited to the following:
A. Investments shall be solely in the interest of, and for the exclusive purposes of
providing benefits to the participants in the Plan and their beneficiaries, minimizing the
contributions of employers thereto, and defraying the reasonable expenses of
administering the Trust (Cal. Gov. Code Sec. 31595 (a)).
B. Investments shall be made with the care, skill prudence and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and
familiar with these matters would use in the conduct of an enterprise of a like character
and with like aims (Cal. Gov. Code Sec. 31595 (b)).
C. Investments shall be diversified so as to minimize the risk of loss and to maximize the
rate of return unless under the circumstances it is clearly prudent not to do so (Cal.
Gov. Code Sec. 31585 (c)).
D. In considering potential investment managers, it is the policy of the Board not to
exclude managers from consideration based on ethnic background or gender, and not
to arbitrarily exclude an emerging firm if, in the opinion of the Board, that firm has equal
or superior capabilities to other candidates.
E. It shall be the policy of the Board that an Economically Targeted Investment (ETI) can
be considered if and only if it has return and risk circumstances attractive in
comparison to other alternatives.
Contra Costa County Investment Policies & Guidelines February Revised June 2013
5
IV. COUNTY PLAN ADMINISTRATOR’S RESPONSIBILITIES
A. On behalf of the Board, execute all legal and administrative documents pertaining to a
trust fund, and take whatever actions are necessary to maintain the County’s
participation in the trust fund, including compliance with any relevant regulation issued
or as may be issued.
B. Oversee the investment portfolio and monitor performance by means of regular reviews
to assure objectives are met and the policy and guidelines are being followed.
C. Provide the investment manager with all relevant information on the Plan, and shall
notify him/her promptly of any changes to this information.
D. Advise the investment manager of any change in the Plan’s circumstances, such as a
change in actuarial assumptions, which could possibly necessitate a change to the
overall risk tolerance, time horizon or liquidity requirements; and thus would dictate a
change to the overall investment objective and goals of the portfolio.
V. PORTFOLIO MANAGERS’ RESPONSIBILITIES, POLICIES AND GUIDELINES
All portfolio mangers hired by the County will be registered investment advisors with the
Securities and Exchange Commission, or will be trust companies that are regulated by State and
Federal Banking authorities. Such portfolio managers will maintain proper and adequate
insurance coverage including errors & omissions, surety bond and fiduciary liability. In addition,
portfolio managers agree to notify the Board and Plan Administrator in writing if they are unable to
continue acting in the capacity of a fiduciary or investment advisor.
Portfolio Managers’ Responsibilities
The portfolio manager is expected to manage the Plan’s portfolio in a manner consistent with this
Document and in accordance with State and Federal law and the Uniform Prudent Investor Act.
The portfolio manager is a registered investment advisor and shall act as such until the Board
decides otherwise.
The portfolio manager shall be responsible for:
1. Designing, recommending and implementing an appropriate asset allocation consistent
with the investment objectives, time horizon, risk profile, guidelines and constraints
outlined in this statement.
2. Advising the Plan Administrator about the selection of and the allocation of asset
categories every three years or as needed.
3. Identifying specific assets and investment managers within each asset category.
4. Monitoring the performance of all selected assets.
5. Recommending changes to any of the above.
6. Periodically reviewing the suitability of the investments, being available to meet with the
Board and Plan Administrator at least once each year, and being available at such other
times within reason at the Board’s request.
7. Preparing and presenting appropriate reports.
8. Informing the Board and Plan Administrator of changes occurring in personnel that are
responsible for portfolio management or research.
Contra Costa County Investment Policies & Guidelines February Revised June 2013
6
Investment Manager Policies and Guidelines
The investment policies governing each investment manager hired by the County are as follows:
1. The investment manager is required to accept the responsibilities stated above. These
responsibilities include acting as a prudent expert and agreeing to be a fiduciary to the
County. The manager will seek to satisfy the County’s investment objectives. If a
problem exists with these objectives, it is the manager’s responsibility to formally discuss
these problems in a written communication to the Advisory Body and Plan Administrator.
Also, the manager agrees to satisfy the County’s prescribed requirements outlined in a
subsequent section.
2. Under any and all capital market environments, the investment manager agrees to
maintain the investment approach that it is was hired to implement. Significant changes
to the manager’s investment decision-making process are to be immediately reported in
writing to the Board and Plan Administrator. It is the responsibility of the investment
manager to fully educate the Board and Plan Administrator as to the specifics of its
investment process and internal research that may lead to changes in the firm’s
investment approach.
3. An investment portfolio constructed for the Board is expected to generally conform to
other portfolios managed by the investment organization, exclusive of specific investment
guidelines. When the Board guidelines require the investment manager to manage a
portfolio significantly different than its other portfolios, it is the responsibility of the
manager to communicate in writing the potential impact of the Board’s guidelines on the
portfolio.
4. The manager will otherwise treat the Plan’s portfolio in a manner similar to other
comparable portfolios in portfolio construction trading and in all other aspects.
5. Managers shall have full discretionary power to direct the investment, exchange,
liquidation and reinvest the assets of the Plan, but must meet the provisions of the
Board’s investment objectives and policies. The Board expects the manager to
recommend changes to this document at any time when the manager views any part of it
to be at variance with overall market and economic conditions.
6. Unless otherwise specified, portfolios are to be fully invested in allowable investment
securities. Under no circumstance shall an investment manager attempt to “market time”
investments in its portfolio(s).
VI. PORTFOLIO REPORTING REQUIREMENTS
Quarterly Reports:
1. The investment objectives of the portfolio will be clearly stated. Next a narrative
description of the portfolio’s investment strategy will be provided with a discussion of the
factors that proved to be favorable and those that were unfavorable. In addition, a
concise statement of the firm’s investment decision-making process will be provided and
any changes or modifications that were made to the process.
2. Portfolio performance before and after investment management fees:
The manager shall report the quarterly total portfolio rate of return before and after
investment management fees have been deducted, as well as cumulative and annual
performance on both bases since account inception. Also included in these tables will be
the manager's performance benchmarks and ranking with median return of peers.
Contra Costa County Investment Policies & Guidelines February Revised June 2013
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3. Portfolio asset mix and asset growth:
The portfolio's allocation to the major asset classes will be specified for the beginning and
end of the quarter. Market values will be shown for the total account over the same
period.
4. Portfolio allocations according to characteristics and other classifications:
Specific portfolio characteristics will be developed and contrasted to those of the
portfolio's performance benchmark.
5. Portfolio reconciliation to the custodial bank:
As of month end, the investment manager will reconcile their portfolio market value to
that provided by the custodial bank. The custodial trustee accounts for investments on a
trade date, full accrual basis. Explanation of any discrepancies shall be provided to the
County.
Monthly Reports:
Portfolio summary report and detailed positions and transactions:
A summary report consisting of a statement of changes in market value from the preceding
month, a summarized portfolio composition using market values and portfolio performance for the
latest month, and a portfolio reconciliation to the custodial market value of the account. The
report should also include individual issues in the portfolio as of the most recent month-end along
with a list of portfolio purchases and sales.
VII. ASSET CATEGORIES
For purposes of setting objectives and guidelines for the investment of the assets of the Plan, the
assets shall be divided into four five segments described as: Global Equity, Global Fixed Income,
Real Estate, Alternative Investments, and the Incidental Cash position. The Domestic and
International Equity allocations are considered part of the Global Equity segment. The Domestic
Fixed Income allocation and the High Yield Fixed Income allocation are considered part of the
Global Fixed Income portion of the Plan.
Global Equity Portion shall consist of investments in common stock and other securities which
are convertible into common stock. The Global Equity portion may be further divided into
domestic, international, and global; large, mid and small capitalization; growth, value, and core.
Global Fixed Income Portion shall consist of investments in fixed income securities including
High-Yield bonds as well as securities including cash equivalents.
Real Estate Portion shall consist of investments in real estate through the use of publicly traded
real estate investment trusts (REITs) and through the use of commingled funds that invest in
publically traded REITs.
Incidental Cash Portion shall include short-term monies not invested in either the Real Estate,
Global Fixed Income, or the Global Equity portion of the Plan.
Alternative Investments shall consist of investments in funds that are not traditional equity,
fixed income, real estate or cash/money market. Alternative investments maintain correlations
that compliment traditional investment classes. Examples of alternative investments would
include market neutral funds, global macro funds, merger/arbitrage funds, managed futures
funds, commodity/precious metals funds, long-short funds, and absolute return funds.
Contra Costa County Investment Policies & Guidelines February Revised June 2013
8
VIII. INVESTMENT OBJECTIVES
The general investment objective of the Plan is to maximize total return, subject to the risk and
quality constraints described in the Investment guidelines. The relative return objective is a total
return on a market value basis which exceeds that of a custom index composed of appropriate
asset class indexes weighted proportionally by corresponding asset class targets. The rate of
return objective shall be the actuarial interest assumption, as determined from year to year.
A. Total Fund Benchmarks
The primary objective is to maximize total Plan return, subject to the risk and quality
constraints set forth. The Plan’s targeted rate of return is 6.25%. The relative return
objective is a total return on a market value basis which exceeds that of a custom index
composed of appropriate asset class indexes weighted proportionally by corresponding
asset class targets. The custom benchmark composition would include 1817% Russell
1000 Index, 6% Russell Mid-Cap Index, 8% Russell 2000 Index, 87% MSCI-ACWI Index,
109% MSCI-EAFE Index, 4538% Barclay’s Aggregate Index, 4% DJ Wilshire REIT Index,
10% HRFIHFRI FOF Market Defensive Index, and 1% Citigroup 3-Month T- Bill Index.
B. Domestic Equity
1. For the Domestic Large Capitalization portion of the Plan, a rate of return in excess of
the Russell 1000 Index, and a return in the upper half of the corresponding
Morningstar large capitalization style universe.
2. For the Domestic Small Capitalization portion of the Plan, a rate of return in excess of
the Russell 2000 Index, and a return in the upper half of the corresponding
Morningstar small capitalization style universe.
3. For the Domestic Mid-cap portion of the Plan, a rate of return in excess of the Russell
Mid-Cap Index, and a return in the upper half of the corresponding Morningstar mid-
capitalization style universe.
C. Global Equity
1. For the Global Equity portion of the Plan, a rate of return in excess of the MSCI-
ACWI Index, and a return in the upper half of the corresponding Morningstar global
large capitalization style universe.
D. International Equity
1. The objective for the international equity portion of the Plan is a return in excess of
the MSCI-EAFE Index, and a return in the upper half of the corresponding
Morningstar International Equity style universe.
E. Fixed Income
1. The objective for the fixed income portion of the Plan is a return in excess of the
Barclays Aggregate Index, and a return in excess of the Morningstar Universe of
intermediate-term fixed income universe.
2. The objective for the high-yield portion of the Plan is a return in excess of the Merrill
Lynch BB/B Index, and a return in the upper half of the corresponding Morningstar
High Yield universe.
F. Real Estate
1. The objective for the real estate portion of the Plan is a return in excess of the Dow Jones
U.S. REIT Index, and a return in excess of the Morningstar Universe of REIT funds.
G. Incidental Cash
Contra Costa County Investment Policies & Guidelines February Revised June 2013
9
1. The objective of the cash portion is to achieve a return in excess of a comparable
money market universe of funds.
H. Alternative Funds
1.I. 1. The objective of the alternative portion of the Plan is to achieve a return in excess of
the HFRI Fund of Funds Market Defensive Index.
IX. ASSET ALLOCATION
Targets
The asset allocation targets and their associated ranges, which are a function of the returns and
risks from various asset classes and the nature of the Plan’s liabilities, are set forth below in
Table 1. The Board will review its asset allocation position as needed or a minimum of once
every three to five years. The Board may make tactical adjustments to the targets and ranges,
and may change the targets and ranges as appropriate.
The Investment manager is responsible for maintaining the balance between fixed income and
equity securities based on the asset allocation. The parameters shown in Table 1 shall be
adhered to in managing the portfolio:
Table 1
Allocation Ranges
Target Mix Minimum Maximum
Total Domestic Equity
Large Cap 1817% 1513% 3532%
Mid Cap 66% 2% 10%
Small Cap 88% 44% 12%
Global Equity 87% 4% 12%
International Equity (Developed) 109% 4% 16%
International Equity (Emerging) 0% 0% 3%
Fixed Income 4538% 3530% 5055%
High Yield 0% 0% 4%
Real Estate 4% 0% 8%
Cash (Money Market) 1% 0% 5%
Alternatives 10% 5% 20%
Rebalancing
1. From time to time, market conditions may cause the asset allocation to vary from the
established target. To remain consistent with the asset allocation guidelines established
by this document, the investment manager will at a minimum rebalance the portfolio on a
quarterly basis.
2. The Board and Plan Administrator have the authority to issue instructions to the
investment manager to liquidate securities for reallocation to other managers.
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Contra Costa County Investment Policies & Guidelines February Revised June 2013
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3. On an annual basis, the Board and Plan Administrator shall develop a cash flow plan for
the subsequent year. This plan will take into consideration expected cash needs both for
the payment of benefits as well as to fund under-allocated or new asset classes.
X. INVESTMENT GUIDELINES
The following guidelines apply to all Investment managers. Any further constraints, limitations or
authorities to an individual manager, which are specific to that manager and have been agreed to
by the manager and the Plan Administrator also apply.
Global Equity
1. The maximum percentage of the Plan which may be invested in the securities of a single
corporation shall be 10% of the value of the Plan.
2. The Plan shall not hold more than 5% of the equity securities of an issuer.
Alternatives
1. The total investment amount for any alternative fund will not exceed 65% of total Plan
assets.
Global Fixed Income
The Fixed Income account securities will be restricted to the following:
1. Obligations of the U.S. Treasury
2. Obligations guaranteed by an agency of the United States, including agency
Mortgage-Backed Securities
3. Government, agency, quasi-government and supranational bonds.
4. Certificates of deposit and banker’s acceptance of credit-worthy banks.
5. Individual Corporate bond investments shall be “Investment Grade” with a minimum
quality rating of Baa2/BBB at the time of purchase. In the event that quality ratings
differ among rating agencies, the higher rating will prevail.
6. Eligible instruments issued pursuant to SEC Rule 144(a) or Regulation S.
7. Commercial paper (including variable rate notes) of issuers rated P-1 by Moody’s
Investor Services and A-1 by Standard & Poor’s.
8. Lower risk planned amortization class (PAC) collateralized mortgage obligations
(“CMO”) and Sequential CMOs. CMOs other than PACs and Sequentials are limited
to a maximum of 10% of the fixed income portfolio at cost.
9. Portfolio holdings in CMOs greater than 15 years or less than negative 15 years in
duration (based on a 100 basis point move in rates) are limited to no more than a
total of 2% of the fixed income portfolio at cost.
10. High yield securities may be held, but they will be held using a high-yield mutual fund
11. Investment-grade bonds backed by the interest and principal payments on loans for
certain types of assets, such as automobiles, credit cards or student loans, known as
asset-backed securities.
Real Estate
Investments in Real Estate will be made through individual REIT securities as well as
commingled funds that invest in REITs. Separately held real estate investments are prohibited.
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Contra Costa County Investment Policies & Guidelines February Revised June 2013
11
Incidental Cash
The incidental cash portion of the Plan shall be invested in readily marketable and diversified
assets as are enumerated in the Fixed Income Portion Guidelines. Additionally money market
funds and repurchase agreements are acceptable cash oriented investments.
XI. PROHIBITED ASSETS
The Plan wishes to avoid investments in the following investment categories:
• Precious metals
• Private Equity
• Venture Capital
• Short sales
• Purchases of Letter Stock, Private
Placements, or direct payments
• Leveraged Transactions
• Commodities Transactions Puts, calls,
straddles, or other option strategies,
• Purchases of real estate, with the
exception of REITs
• Derivatives, with exception of ETFs
• Contra Costa County Issued Bonds
• Non-agency (or Private Label)
Mortgage-Back Securities
• (or Private Label) Mortgage-Back Securities
The investment manager will not make direct investments in any of the prohibited assets
listed above. However, to the extent that the Investment Manager uses a mutual or
commingled fund as an investment vehicle for County assets, that fund’s policies will
supersede the County’s policies, which can result in investments in prohibited assets.
The Investment Manager is responsible for reviewing the County’s policies on at least an
annual basis and reporting back to the County on mutual and/or commingled fund
policies that are in conflict with County policies and also on any holdings of such funds
that are in conflict with County policies.
XII. FUND SELECTION PROCESS
Funds selected as investments in the Plan will be expected to have undergone a rigorous
screening process that searches for managers and styles that will produce above average returns
within acceptable risk parameters. The evaluation process will consider the following factors:
• Performance track record
• Fund assets
• Manager tenure with fund
• Expense ratios
• Market capitalization
• Style consistency
• Number of holdings
• Assets in top 10
• Portfolio turnover
• Sector weighting allocations
• Standard deviation
• Sharpe ratio
Performance evaluation of the Funds will take into consideration both performance relative to a
benchmark index as well as performance relative to a universe of the fund’s peers. Evaluation
metrics versus a representative benchmark will utilize a twelve-month rolling performance record
compared to a representative benchmark over a three, five, seven and ten-year period (if/when
available).
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Contra Costa County Investment Policies & Guidelines February Revised June 2013
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A fund is expected to rank above the median in its appropriate peer group for the three, five and
ten-year periods (if/when available).
An additional requirement for all funds utilized in the Plan is that the fund families that sponsor the
funds will have filled out and returned a request for proposal (RFP) submitted to them by the
investment manager. This RFP will highlight significant areas such as organizational factors,
composition of assets, portfolio characteristics, investment process, fee structure, internal
compliance controls, and an overview of the investment personnel.
Investment mutual funds may be removed from the investment portfolio from time to time.
Factors that the investment manager will consider in regards to removing a fund include, but is
not limited to:
• Performance that is inconsistent with the manager’s style or our expectations
• Performance that conflicts with peers and style universes
• Annualized return trails the benchmark or median return on a 3-year basis for more than
three consecutive quarters
• Security selection not in agreement with the manager’s investment philosophy/process
• Purchases that lead to abnormal portfolio concentrations
• Sector and industry exposures that are inconsistent with the manager’s guidelines
• Unusual tracking error to the benchmarks
• Inadequate transparency between the manager’s comments and portfolio holdings
• Inconsistencies related to the manager’s remarks on style, sector, and market cap
weightings
• Instability at the manager’s investment management firm
• Modifications to the investment process and/or risk controls that interfere with a firms
strategy
• Staffing adjustments that may result in poor performance
• The fund selection process described above is not required for any passive investments,
including index-based mutual funds or exchange-trade funds (ETFs).
Contra Costa County Investment Policies & Guidelines Revised June 2013
1
COUNTY OF CONTRA COSTA
POST-EMPLOYMENT HEALTH CARE
PLAN
INVESTMENT POLICIES AND
GUIDELINES DOCUMENT
Adopted February 2011
Revised June 2011
Revised June 2013
Contra Costa County Investment Policies & Guidelines Revised June 2013
2
Contra Costa County Post-Retirement Health Care Plan
Investment Policies and Guidelines Document
In response to the Government Accounting Standards Board (GASB) Statement Number 45 disclosure
requirements for Other Post-Employment Benefit (OPEB) Plans, Contra Costa County has adopted a
Section 115 Trust Plan that seeks to satisfy these liabilities for certain eligible employees.
Executive Summary
Plan Sponsor: Contra Costa County (County)
Advisory Body: Post Retirement Health Benefits Trust Agreement Advisory Body
Plan Administrator: Contra Costa County Treasurer-Tax Collector
Trust Administrator: Public Agency Retirement Services (PARS)
Trustee: U.S. Bank, N.A.
Investment Advisor: U.S. Bank, N.A., as Trustee has hired HighMark Capital
Management (Portfolio Manager) via a sub-advisory agreement
to serve as the Investment Advisor.
Investment Authority: Full Investment Authority
Account Number: To be determined
Current Assets: $95,160,073.94 (as of December 31, 2012)
Annual Contributions: Evaluated annually
Risk Tolerance: Balanced Objective
Time Horizon: Long-Term
Assumed Earnings Rate: 6.25%
Investment Objective: The primary objective is to maximize total Plan return,
subject to the risk and quality constraints set forth below.
The Plan’s targeted rate of return is 6.25%. The asset
allocation ranges for the Plan is listed below:
Strategic Ranges: Cash: 0 - 5% Fixed Income: 30-50%
Equity: 45-65% Alternatives 5 – 20%
Communication Schedule: See Portfolio Reporting Requirements
Committee meetings quarterly
Income Needs/Cash Flow Required: To be determined annually by the Plan Administrator.
Unique Needs and Circumstances: None Known
HCM Portfolio Manager: Andrew Brown, CFA 415-705-7605
Andrew.Brown@highmarkcapital.com
HCM Back up -Portfolio Manager: Anne E. Wimmer, CFA 310-550-6457
Anne.Wimmer@highmarkcapital.com
U.S Bank Administrative Officer: Fran Schoenfeld, 949-224-7204
Fran.Schoenfeld@usbank.com
The managing director for HighMark Capital Management is Kevin Rogers, he can be reached at 949-553-2580
Contra Costa County Investment Policies & Guidelines Revised June 2013
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Portfolio Constraints
Income Needs/Cash Flow Required: Income needs are expected to be minimal in the
initial years of the Plan
Client (Signature): Date:
HCM Portfolio Manager: Date:
U.S. Bank Administrative Officer: Date:
Contra Costa County Investment Policies & Guidelines Revised June 2013
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I. INTRODUCTION
The Board of Supervisors (the “Board”) of the County of Contra Costa has established the
following Investment Policies and Guidelines Document (the “Document”) for the investment of
the trust fund (the “Trust”) of the Contra Costa County Post-Retirement Health Benefits Plan (the
“Plan”). The Board reserves the right at any time and from time to time to amend, supplement or
rescind this document.
II. OVERVIEW
The purpose of this Document is to assist the Board and the Portfolio Manager in effectively
supervising, monitoring and evaluating the investment of the Plan’s portfolio. The investment
program is defined in the various sections of the Document by:
A. Stating the Board’s attitudes, expectations, objectives and guidelines for the investment
of all assets.
B. Setting forth an investment structure for managing the Plan’s portfolio. This structure
includes various asset classes, investment management styles, asset allocation and
acceptable ranges that, in total are expected to produce an appropriate level of overall
diversification and anticipated total investment return over the investment time horizon.
C. Encouraging effective communications between the Board and the Portfolio Manager.
D. Complying with all applicable fiduciary, prudence and due diligence requirements
experienced investment professionals would utilize, and with all applicable laws, rules
and regulations of various local, state and federal entities that may impact the Plan’s
assets.
III. AUTHORITY
The investment of the assets for the Trust shall be in accord with applicable law, including but not
limited to the following:
A. Investments shall be solely in the interest of, and for the exclusive purposes of
providing benefits to the participants in the Plan and their beneficiaries, minimizing the
contributions of employers thereto, and defraying the reasonable expenses of
administering the Trust (Cal. Gov. Code Sec. 31595 (a)).
B. Investments shall be made with the care, skill prudence and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and
familiar with these matters would use in the conduct of an enterprise of a like character
and with like aims (Cal. Gov. Code Sec. 31595 (b)).
C. Investments shall be diversified so as to minimize the risk of loss and to maximize the
rate of return unless under the circumstances it is clearly prudent not to do so (Cal.
Gov. Code Sec. 31585 (c)).
D. In considering potential investment managers, it is the policy of the Board not to
exclude managers from consideration based on ethnic background or gender, and not
to arbitrarily exclude an emerging firm if, in the opinion of the Board, that firm has equal
or superior capabilities to other candidates.
E. It shall be the policy of the Board that an Economically Targeted Investment (ETI) can
be considered if and only if it has return and risk circumstances attractive in
comparison to other alternatives.
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IV. COUNTY PLAN ADMINISTRATOR’S RESPONSIBILITIES
A. On behalf of the Board, execute all legal and administrative documents pertaining to a
trust fund, and take whatever actions are necessary to maintain the County’s
participation in the trust fund, including compliance with any relevant regulation issued
or as may be issued.
B. Oversee the investment portfolio and monitor performance by means of regular reviews
to assure objectives are met and the policy and guidelines are being followed.
C. Provide the investment manager with all relevant information on the Plan, and shall
notify him/her promptly of any changes to this information.
D. Advise the investment manager of any change in the Plan’s circumstances, such as a
change in actuarial assumptions, which could possibly necessitate a change to the
overall risk tolerance, time horizon or liquidity requirements; and thus would dictate a
change to the overall investment objective and goals of the portfolio.
V. PORTFOLIO MANAGERS’ RESPONSIBILITIES, POLICIES AND GUIDELINES
All portfolio mangers hired by the County will be registered investment advisors with the
Securities and Exchange Commission, or will be trust companies that are regulated by State and
Federal Banking authorities. Such portfolio managers will maintain proper and adequate
insurance coverage including errors & omissions, surety bond and fiduciary liability. In addition,
portfolio managers agree to notify the Board and Plan Administrator in writing if they are unable to
continue acting in the capacity of a fiduciary or investment advisor.
Portfolio Managers’ Responsibilities
The portfolio manager is expected to manage the Plan’s portfolio in a manner consistent with this
Document and in accordance with State and Federal law and the Uniform Prudent Investor Act.
The portfolio manager is a registered investment advisor and shall act as such until the Board
decides otherwise.
The portfolio manager shall be responsible for:
1. Designing, recommending and implementing an appropriate asset allocation consistent
with the investment objectives, time horizon, risk profile, guidelines and constraints
outlined in this statement.
2. Advising the Plan Administrator about the selection of and the allocation of asset
categories every three years or as needed.
3. Identifying specific assets and investment managers within each asset category.
4. Monitoring the performance of all selected assets.
5. Recommending changes to any of the above.
6. Periodically reviewing the suitability of the investments, being available to meet with the
Board and Plan Administrator at least once each year, and being available at such other
times within reason at the Board’s request.
7. Preparing and presenting appropriate reports.
8. Informing the Board and Plan Administrator of changes occurring in personnel that are
responsible for portfolio management or research.
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Investment Manager Policies and Guidelines
The investment policies governing each investment manager hired by the County are as follows:
1. The investment manager is required to accept the responsibilities stated above. These
responsibilities include acting as a prudent expert and agreeing to be a fiduciary to the
County. The manager will seek to satisfy the County’s investment objectives. If a
problem exists with these objectives, it is the manager’s responsibility to formally discuss
these problems in a written communication to the Advisory Body and Plan Administrator.
Also, the manager agrees to satisfy the County’s prescribed requirements outlined in a
subsequent section.
2. Under any and all capital market environments, the investment manager agrees to
maintain the investment approach that it is was hired to implement. Significant changes
to the manager’s investment decision-making process are to be immediately reported in
writing to the Board and Plan Administrator. It is the responsibility of the investment
manager to fully educate the Board and Plan Administrator as to the specifics of its
investment process and internal research that may lead to changes in the firm’s
investment approach.
3. An investment portfolio constructed for the Board is expected to generally conform to
other portfolios managed by the investment organization, exclusive of specific investment
guidelines. When the Board guidelines require the investment manager to manage a
portfolio significantly different than its other portfolios, it is the responsibility of the
manager to communicate in writing the potential impact of the Board’s guidelines on the
portfolio.
4. The manager will otherwise treat the Plan’s portfolio in a manner similar to other
comparable portfolios in portfolio construction trading and in all other aspects.
5. Managers shall have full discretionary power to direct the investment, exchange,
liquidation and reinvest the assets of the Plan, but must meet the provisions of the
Board’s investment objectives and policies. The Board expects the manager to
recommend changes to this document at any time when the manager views any part of it
to be at variance with overall market and economic conditions.
6. Unless otherwise specified, portfolios are to be fully invested in allowable investment
securities. Under no circumstance shall an investment manager attempt to “market time”
investments in its portfolio(s).
VI. PORTFOLIO REPORTING REQUIREMENTS
Quarterly Reports:
1. The investment objectives of the portfolio will be clearly stated. Next a narrative
description of the portfolio’s investment strategy will be provided with a discussion of the
factors that proved to be favorable and those that were unfavorable. In addition, a
concise statement of the firm’s investment decision-making process will be provided and
any changes or modifications that were made to the process.
2. Portfolio performance before and after investment management fees:
The manager shall report the quarterly total portfolio rate of return before and after
investment management fees have been deducted, as well as cumulative and annual
performance on both bases since account inception. Also included in these tables will be
the manager's performance benchmarks and ranking with median return of peers.
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3. Portfolio asset mix and asset growth:
The portfolio's allocation to the major asset classes will be specified for the beginning and
end of the quarter. Market values will be shown for the total account over the same
period.
4. Portfolio allocations according to characteristics and other classifications:
Specific portfolio characteristics will be developed and contrasted to those of the
portfolio's performance benchmark.
5. Portfolio reconciliation to the custodial bank:
As of month end, the investment manager will reconcile their portfolio market value to
that provided by the custodial bank. The custodial trustee accounts for investments on a
trade date, full accrual basis. Explanation of any discrepancies shall be provided to the
County.
Monthly Reports:
Portfolio summary report and detailed positions and transactions:
A summary report consisting of a statement of changes in market value from the preceding
month, a summarized portfolio composition using market values and portfolio performance for the
latest month, and a portfolio reconciliation to the custodial market value of the account. The
report should also include individual issues in the portfolio as of the most recent month-end along
with a list of portfolio purchases and sales.
VII. ASSET CATEGORIES
For purposes of setting objectives and guidelines for the investment of the assets of the Plan, the
assets shall be divided into five segments described as: Global Equity, Global Fixed Income, Real
Estate, Alternative Investments, and the Incidental Cash position. The Domestic and International
Equity allocations are considered part of the Global Equity segment. The Domestic Fixed Income
allocation and the High Yield Fixed Income allocation are considered part of the Global Fixed
Income portion of the Plan.
Global Equity Portion shall consist of investments in common stock and other securities which
are convertible into common stock. The Global Equity portion may be further divided into
domestic, international, and global; large, mid and small capitalization; growth, value, and core.
Global Fixed Income Portion shall consist of investments in fixed income securities including
High-Yield bonds as well as securities including cash equivalents.
Real Estate Portion shall consist of investments in real estate through the use of publicly traded
real estate investment trusts (REITs) and through the use of commingled funds that invest in
publically traded REITs.
Incidental Cash Portion shall include short-term monies not invested in either the Real Estate,
Global Fixed Income, or the Global Equity portion of the Plan.
Alternative Investments shall consist of investments in funds that are not traditional equity, fixed
income, real estate or cash/money market. Alternative investments maintain correlations that
compliment traditional investment classes. Examples of alternative investments would include
market neutral funds, global macro funds, merger/arbitrage funds, managed futures funds,
commodity/precious metals funds, long-short funds, and absolute return funds.
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VIII. INVESTMENT OBJECTIVES
The general investment objective of the Plan is to maximize total return, subject to the risk and
quality constraints described in the Investment guidelines. The relative return objective is a total
return on a market value basis which exceeds that of a custom index composed of appropriate
asset class indexes weighted proportionally by corresponding asset class targets. The rate of
return objective shall be the actuarial interest assumption, as determined from year to year.
A. Total Fund Benchmarks
The primary objective is to maximize total Plan return, subject to the risk and quality
constraints set forth. The Plan’s targeted rate of return is 6.25%. The relative return
objective is a total return on a market value basis which exceeds that of a custom index
composed of appropriate asset class indexes weighted proportionally by corresponding
asset class targets. The custom benchmark composition would include 17% Russell 1000
Index, 6% Russell Mid-Cap Index, 8% Russell 2000 Index, 7% MSCI-ACWI Index, 9%
MSCI-EAFE Index, 38% Barclay’s Aggregate Index, 4% DJ Wilshire REIT Index, 10%
HFRI FOF Market Defensive Index, and 1% Citigroup 3-Month T- Bill Index.
B. Domestic Equity
1. For the Domestic Large Capitalization portion of the Plan, a rate of return in excess of
the Russell 1000 Index, and a return in the upper half of the corresponding
Morningstar large capitalization style universe.
2. For the Domestic Small Capitalization portion of the Plan, a rate of return in excess of
the Russell 2000 Index, and a return in the upper half of the corresponding
Morningstar small capitalization style universe.
3. For the Domestic Mid-cap portion of the Plan, a rate of return in excess of the Russell
Mid-Cap Index, and a return in the upper half of the corresponding Morningstar mid-
capitalization style universe.
C. Global Equity
1. For the Global Equity portion of the Plan, a rate of return in excess of the MSCI-
ACWI Index, and a return in the upper half of the corresponding Morningstar global
large capitalization style universe.
D. International Equity
1. The objective for the international equity portion of the Plan is a return in excess of
the MSCI-EAFE Index, and a return in the upper half of the corresponding
Morningstar International Equity style universe.
E. Fixed Income
1. The objective for the fixed income portion of the Plan is a return in excess of the
Barclays Aggregate Index, and a return in excess of the Morningstar Universe of
intermediate-term fixed income universe.
2. The objective for the high-yield portion of the Plan is a return in excess of the Merrill
Lynch BB/B Index, and a return in the upper half of the corresponding Morningstar
High Yield universe.
F. Real Estate
1. The objective for the real estate portion of the Plan is a return in excess of the Dow Jones
U.S. REIT Index, and a return in excess of the Morningstar Universe of REIT funds.
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G. Incidental Cash
1. The objective of the cash portion is to achieve a return in excess of a comparable
money market universe of funds.
H. Alternative Funds
I. 1. The objective of the alternative portion of the Plan is to achieve a return in excess of
the HFRI Fund of Funds Market Defensive Index.
IX. ASSET ALLOCATION
Targets
The asset allocation targets and their associated ranges, which are a function of the returns and
risks from various asset classes and the nature of the Plan’s liabilities, are set forth below in
Table 1. The Board will review its asset allocation position as needed or a minimum of once
every three to five years. The Board may make tactical adjustments to the targets and ranges,
and may change the targets and ranges as appropriate.
The Investment manager is responsible for maintaining the balance between fixed income and
equity securities based on the asset allocation. The parameters shown in Table 1 shall be
adhered to in managing the portfolio:
Table 1
Allocation Ranges
Target Mix Minimum Maximum
Total Domestic Equity
Large Cap 17% 13% 32%
Mid Cap 6% 2% 10%
Small Cap 8% 4% 12%
Global Equity 7% 4% 12%
International Equity (Developed) 9% 4% 16%
International Equity (Emerging) 0% 0% 3%
Fixed Income 38% 30% 50%
High Yield 0% 0% 4%
Real Estate 4% 0% 8%
Cash (Money Market) 1% 0% 5%
Alternatives 10% 5% 20%
Rebalancing
1. From time to time, market conditions may cause the asset allocation to vary from the
established target. To remain consistent with the asset allocation guidelines established
by this document, the investment manager will at a minimum rebalance the portfolio on a
quarterly basis.
2. The Board and Plan Administrator have the authority to issue instructions to the
investment manager to liquidate securities for reallocation to other managers.
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3. On an annual basis, the Board and Plan Administrator shall develop a cash flow plan for
the subsequent year. This plan will take into consideration expected cash needs both for
the payment of benefits as well as to fund under-allocated or new asset classes.
X. INVESTMENT GUIDELINES
The following guidelines apply to all Investment managers. Any further constraints, limitations or
authorities to an individual manager, which are specific to that manager and have been agreed to
by the manager and the Plan Administrator also apply.
Global Equity
1. The maximum percentage of the Plan which may be invested in the securities of a single
corporation shall be 10% of the value of the Plan.
2. The Plan shall not hold more than 5% of the equity securities of an issuer.
Alternatives
1. The total investment amount for any alternative fund will not exceed 5% of total Plan
assets.
Global Fixed Income
The Fixed Income account securities will be restricted to the following:
1. Obligations of the U.S. Treasury
2. Obligations guaranteed by an agency of the United States, including agency
Mortgage-Backed Securities
3. Government, agency, quasi-government and supranational bonds.
4. Certificates of deposit and banker’s acceptance of credit-worthy banks.
5. Individual Corporate bond investments shall be “Investment Grade” with a minimum
quality rating of Baa2/BBB at the time of purchase. In the event that quality ratings
differ among rating agencies, the higher rating will prevail.
6. Eligible instruments issued pursuant to SEC Rule 144(a) or Regulation S.
7. Commercial paper (including variable rate notes) of issuers rated P-1 by Moody’s
Investor Services and A-1 by Standard & Poor’s.
8. Lower risk planned amortization class (PAC) collateralized mortgage obligations
(“CMO”) and Sequential CMOs. CMOs other than PACs and Sequentials are limited
to a maximum of 10% of the fixed income portfolio at cost.
9. Portfolio holdings in CMOs greater than 15 years or less than negative 15 years in
duration (based on a 100 basis point move in rates) are limited to no more than a
total of 2% of the fixed income portfolio at cost.
10. High yield securities may be held, but they will be held using a high-yield mutual fund
11. Investment-grade bonds backed by the interest and principal payments on loans for
certain types of assets, such as automobiles, credit cards or student loans, known as
asset-backed securities.
Real Estate
Investments in Real Estate will be made through individual REIT securities as well as
commingled funds that invest in REITs. Separately held real estate investments are prohibited.
Contra Costa County Investment Policies & Guidelines Revised June 2013
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Incidental Cash
The incidental cash portion of the Plan shall be invested in readily marketable and diversified
assets as are enumerated in the Fixed Income Portion Guidelines. Additionally money market
funds and repurchase agreements are acceptable cash oriented investments.
XI. PROHIBITED ASSETS
The Plan wishes to avoid investments in the following investment categories:
• Precious metals
• Private Equity
• Venture Capital
• Short sales
• Purchases of Letter Stock, Private
Placements, or direct payments
• Leveraged Transactions
• Commodities Transactions Puts, calls,
straddles, or other option strategies,
• Purchases of real estate, with the
exception of REITs
• Derivatives, with exception of ETFs
• Contra Costa County Issued Bonds
• Non-agency (or Private Label)
Mortgage-Back Securities
• (or Private Label) Mortgage-Back Securities
The investment manager will not make direct investments in any of the prohibited assets
listed above. However, to the extent that the Investment Manager uses a mutual or
commingled fund as an investment vehicle for County assets, that fund’s policies will
supersede the County’s policies, which can result in investments in prohibited assets.
The Investment Manager is responsible for reviewing the County’s policies on at least an
annual basis and reporting back to the County on mutual and/or commingled fund
policies that are in conflict with County policies and also on any holdings of such funds
that are in conflict with County policies.
XII. FUND SELECTION PROCESS
Funds selected as investments in the Plan will be expected to have undergone a rigorous
screening process that searches for managers and styles that will produce above average returns
within acceptable risk parameters. The evaluation process will consider the following factors:
• Performance track record
• Fund assets
• Manager tenure with fund
• Expense ratios
• Market capitalization
• Style consistency
• Number of holdings
• Assets in top 10
• Portfolio turnover
• Sector weighting allocations
• Standard deviation
• Sharpe ratio
Performance evaluation of the Funds will take into consideration both performance relative to a
benchmark index as well as performance relative to a universe of the fund’s peers. Evaluation
metrics versus a representative benchmark will utilize a twelve-month rolling performance record
compared to a representative benchmark over a three, five, seven and ten-year period (if/when
available).
A fund is expected to rank above the median in its appropriate peer group for the three, five and
ten-year periods (if/when available).
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An additional requirement for all funds utilized in the Plan is that the fund families that sponsor the
funds will have filled out and returned a request for proposal (RFP) submitted to them by the
investment manager. This RFP will highlight significant areas such as organizational factors,
composition of assets, portfolio characteristics, investment process, fee structure, internal
compliance controls, and an overview of the investment personnel.
Investment mutual funds may be removed from the investment portfolio from time to time.
Factors that the investment manager will consider in regards to removing a fund include, but are
not limited to:
• Performance that is inconsistent with the manager’s style or our expectations
• Performance that conflicts with peers and style universes
• Annualized return trails the benchmark or median return on a 3-year basis for more than
three consecutive quarters
• Security selection not in agreement with the manager’s investment philosophy/process
• Purchases that lead to abnormal portfolio concentrations
• Sector and industry exposures that are inconsistent with the manager’s guidelines
• Unusual tracking error to the benchmarks
• Inadequate transparency between the manager’s comments and portfolio holdings
• Inconsistencies related to the manager’s remarks on style, sector, and market cap
weightings
• Instability at the manager’s investment management firm
• Modifications to the investment process and/or risk controls that interfere with a firms
strategy
• Staffing adjustments that may result in poor performance
• The fund selection process described above is not required for any passive investments,
including index-based mutual funds or exchange-trade funds (ETFs).