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DIVERSIFICATION. <br />Reasonable precautions will be taken to avoid excessive investment concentrations to protect the portfolio <br />against unfavorable outcomes within an asset class. Specifically, the following guidelines will be in place: <br />1) With the exception of fixed income investments explicitly guaranteed by the U.S. Government, no <br />single, individual investment security (i.e., excluding pooled funds) will represent more than 5% of <br />total Portfolio assets. <br />2) With respect to fixed income investments, the minimum average credit quality of these investments <br />will be investment grade (Standard & Poor’s BBB or Moody’s Baa or higher). <br />3) Cash investments will, under normal circumstances, only be considered as temporary portfolio <br />holdings, and will be used to fund liquidity needs or to facilitate a planned program of dollar-cost <br />averaging into investment in either or both of the equity and fixed income asset classes. <br /> <br />REBALANCING. <br />VIAS will seek to rebalance the Portfolio to the target normal asset allocation described above as follows: <br /> <br />1) Utilize incoming cash flow (contributions) or outgoing money movements (disbursements) to realign <br />the current weightings closer to the target asset allocation of the portfolio. <br />2) To determine the deviation(s) from target weightings, the investment manager will review the <br />portfolio quarterly (March 31, June 30, September 30, and December 31). The following parameters <br />will be applied. <br />a) If any asset class (equity, fixed income, alternatives or cash) within the portfolio is +/- 5 <br />percentage points from its target weighting, the portfolio will be rebalanced. <br />3) The investment manager may provide a rebalancing recommendation at any time. <br />4) The investment manager shall act within a reasonable period of time to evaluate variance from these <br />ranges. <br /> <br />OTHER INVESTMENT POLICIES. <br />Unless expressly authorized in writing by the Client, VIAS will not engage in the following transactions <br />directly on behalf of the Portfolio: <br />1) Purchasing securities on margin, or executing short sales, <br />2) Pledging or hypothecating securities, except for loans of securities that are fully collateralized, <br />3) Purchasing or selling derivative securities for speculation or leverage, <br />4) Engaging in investment strategies that have the potential to amplify or distort the risk of loss <br />beyond a level that is reasonably expected given the objectives of the Portfolio. <br />* VIAS expects to invest the Portfolio in mutual funds and other pooled funds that may employ strategies that <br />include short selling, securities lending, derivatives and leverage. <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />11 <br /> <br /> <br />