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notation of the City's ownership of or explicit claim on the securities. The original copy of all <br /> safekeeping receipts shall be delivered to the City. <br /> X. MANAGEMENT AND INTERNAL CONTROLS <br /> The Director of Finance shall establish a system of internal controls, which shall be reviewed by <br /> an independent auditor. The controls shall be designed to prevent losses of public funds arising <br /> from fraud, employee error, misrepresentation by third parties, unanticipated changes in financial <br /> markets, or imprudent actions by employees or Investment Officers of the City. <br /> Controls and managerial emphasis deemed most important that shall be employed where practical <br /> are: <br /> A. Control of collusion: <br /> B. Separation of duties: <br /> C. Separation of transaction authority from accounting and record keeping. <br /> D. Custodian safekeeping receipts records management: <br /> E. Avoidance of physical delivery securities: <br /> F. Clear delegation of authority to subordinate staff members: <br /> G. Documentation on investment bidding events: <br /> H. Written confirmation of telephone- transactions for investments and wire transfers: <br /> I. Reconcilement and comparisons of security receipts with the investment subsidiary records: <br /> J. Compliance with investment policies: <br /> K. Accurate and timely reports, - <br /> L. Validation of investment maturity decisions with supporting cash flow data, - <br /> M. Adequate training and development of Investment Officers: <br /> O. Review of financial condition of all brokers, dealers and depesitery- financial institutions: <br /> P. Staying informed about market conditions, changes, and trends that require adjustments in <br /> investment strategies: <br /> COMPLIANCE AUDIT The City of La Porte shall perform, in conjunction with its annual <br /> financial audit, a compliance audit of management controls on investments and adherence to the <br /> entity's established investment policies. The audit shall include a formal review of the quarterly <br /> investment reports by an independent auditor and the results reported to the governing body by <br /> the independent auditor. Also, the governing body shall review its investment policy and <br /> investment strategy not less than annually and adopt a written instrument by rule, order, <br /> ordinance, or resolution stating that it has reviewed the investment policy and strategy, and <br /> recorded any changes made to them. <br /> 12 <br />