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San Diego County, CA November 4, 2008 Election
Smart Voter

Proposals for Changes in Oceanside's City Treasurers Office

By James H. "Jimmy" Knott, III

Candidate for Treasurer; City of Oceanside

This information is provided by the candidate
Proposals for Changes in Oceanside's City Treasurers Office
Jimmy Knott III's Proposals for Changes in Oceanside's City Treasurers Office

(These are the same changes and upgrades I proposed in 2004, I will provide updates in () but I still desire to bring the City Treasurers Office into the 21st century instead of operating in the past 19th century mode)

Provide Alternative Points of Economic Views and Strategies: Because all expenditures will eventually affect all other expenditures, savings or investments

Open the process instead of treating the Treasurers Office like a cloistered secret society and the Citizens like Children:

1) Do like other Cities have done and come into the 21st Century via use of Technologies like the internet & Public postings and:

  • a) Post pertinent economic information like the City's Investment Policy - (after I ran in 2004 only then did the current city Treasurer do this item)
  • b) Post the City's Investment Schedule on the internet and in public
  • c) Post the Returns on Investments and provide a link to these companies-bonds-etc so everyone can equally know and understand how these investments made on behalf of the city are doing
  • d) Open the Contact with the Office of City Treasurer using the city's web site and e-mail link -(only after I ran for the City Treasurers Office in 2004 did this come about)
  • e) Treat the Office of City Treasurer as an Equal to other elected Officials and their Offices

2) Increase the public involvement with the Office of the City Treasurer:
  • a) List in the City's Advisory Groups on the City's web site the City Treasurers Investment Advisory Board instead of seemingly keeping their meetings in secret
  • b) Post the Investment Advisory Boards Agenda on the city's web site and other predominant areas - (only after I ran in 2004 did this occur)
  • c) Post contact information for members of this Investment Board
  • d) Initiate a Citizens forum of at least twice a year so the public can have direct input into the investment strategies and process. Then this input would be compiled and included into the mandated yearly report and proposal from the Treasurers Office for proposed Investment Strategies at the Annual Budget review by the City Council to consider.

3)Increase the Public Education about city funding mechanisms, budgets and investment strategies:
  • a)Use KOCT as an public educational tool in this area and
  • b)Have at every council meeting where the spending of taxpayers funds is discussed a report, verbal or written, as to alternatives, impacts &/or potential consequences of actions from the City Treasurer. This is the right and duty of citizens and all who serve the public as it can directly affect other economic areas like our city's investment portfolio and Reserves

Consider New Investment Strategies that are Secure and community supportive
  • 1)Land + less than 5 % left, acquire, use, set aside or sell if we really need to
  • 2)Local Businesses + Invest in Oceanside instead of just elsewhere- thus improving the tax base, Job creation, enhances O'side standard of living and keeps businesses/companies in Oceanside
  • 3)Cash reserves + not laying off city personnel except for due cause, not cutting city departments for reasons of budget. Use these funds here first then repay and build this reserve.(The current city Treasurer says these items can not be done but in the investment Policy that guides the Portfolio it allows the buying of Commerical paper of upto 15% of the entire portfolio, even our own Federal government is doing this to spark commerce, employment and trade. We need to do this locally as well. The Current City Treasurer says we can not Land bank or purchase land as an investment - but the City has already done just that with examples like the Collins property, th Marina Towers Property and dozens of other properties. If there is a law that gets in the way challenge that law or change it, the profits the city has made off these investments have helped the city emmensely in the past. We need to be forward looking and not be stagnating in old mind sets that have got this countrys economy in the shape it is in currently, it is time for a new economy)

Guiding Philosophies:
  • Let our Openness Confound them...
  • Most all Problems lay at the feet of Management or improper actions of decision makers...
  • Follow the money then you shall know the truth....
  • If managers, like the City Council, don't have enough background info. or potential alternatives then we are at fault for not providing that necessary information that may lead to their poor decisions.....
  • Everyone needs to be educated on basic understanding of accounting and economic flow dynamics so we all become more responsible citizens....
  • As with a picture all parts work together to achieve beauty and insight...
  • All tax monies are the Citizens possessions not the elected/appointed Officials personal cash box...
  • Elected Officials are the people's stewards and servants not their masters. ___________________________________________________

A Critical Reflection on Oceanside's Investment Policy

By Jimmy Knott III Sunday, August 29, 2004

As with my former reflection on the handling of the City's Treasury in my "Thoughts on Oceanside's Investment Policies as Compared with Other City's In San Diego County" here are some specifics and questions on Oceanside's Investment Policy alone.

Oceanside has a mandate that the Treasury must meet the City's budgetary expenditures for at least a six (6) month period of time. This presents some questions and concerns:

  • 1) What values and standards are these expenditures being considered for in this period of time?
  • 2) Is it full total operations or barebones operations? There are neither specifics listed nor referral to any other reference ordinances, codes, reference material or guidance given as to this point and as such it can be loosely interpreted to mean many things.
  • 3) And is a 6 month period of time really logically needed? What basis is there for this time mandate? Why not 45 days or longer or whatever period of time? Should this be altered to reflect the needs of /for a realistic crisis or emergency period of time only? Or should this be based upon better clearly, specifically defined values and standards?
  • 4) Is this a mandate to have 6 months worth of callable investments or not? Or can it be expressed in other potential investments?
  • 5) Since this is limited to "budgeted" expenditures. With the ability of the city to adjust budgets as needed should this also include all budgeted programs? CIP's and other special projects included?
  • 6) Since the Federal and State Governments have in the recent past taken city anticipated revenues for their needs and/or have altered the regulations/implementation/structure of programs or laws that have reduced potential returns on governmental and private investments and have given the city "Unfunded Mandates" should these factors be included into the projection of sums needed to cover this 6 month period of time?
  • 7) And are the sources of the city's income, expenditures for these callable investments secure and realistic anymore?
  • 8) And should the city include all potential transfers of mandates from both the State and Federal Governments?

Oceanside has a self mandate of generating the maximum amount of investment income within the parameters of prudent risk management and required liquidity. This presents some concerns and questions:
  • 1) Should the City only consider certain money markets of investments that isolate the city's diversity of its portfolio? Right now the City owns no Commercial Paper in local expanding companies, nor do we consider land a prudent investment, yet both of these are secure and the values and returns of each have been far greater than the money markets we are invested with. Just today this benefit of investing in local companies was confirmed in the North County times with the graph of comparison of local companies contrasted with the listed market for the nation in general. If we had of had included in our investment portfolio just these two (2) far broader investment concepts we could have generated a far greater investment return income.
  • 2) Should the City buy some sizeable Commercial Paper from local companies or local large employers? The returns in this type of invest can be expressed in a far broader concept because in addition to short term fiscal gains on the investment, strictly monetarily, we could as well locally generate returns in additional jobs, increased local business trade, increased local tax generation, and future security in case of a money market failure, further state or federal take backs or restrictions on returns or collapse as in the case of the ability of taping Pension funds by various parties.
  • 3) Property holdings are part of the prudent investment policy of most families, businesses, corporations and even the county, state and federal governments. In some cases they are called land reserves, resource or mineral holdings, home sites, vacation property, farming enterprises, etc. but in any case land is a severely limited commodity in especially coastal southern California. The Current City Treasurers office denies that this is an allowable investment strategy but the City has used this recently as an investment strategy with the Collins property contrary to this stance, and it worked to the benefit of the City and it has occurred many times in the past. Almost every government entity uses this strategy as well. Soon the El Corazon property may generate on part of it similar benefits in sale or lease of the property. And with less than 5% buildable land left we are only investing in Money Markets and federally "secure" investments. Should we invest in property as a prudent risk? If it isn't used as investment now it can be sold or used at a higher value in the future, and by the future we need to look 100 or more years ahead like in most major Cities unless we anticipate a total overturn of our governmental system or catastrophic disaster that has been used in other world cities to redevelop their land and holdings.
  • 4) Seeing the temporal benefits and not the long term benefits. Should this section of the Investment policy be adjusted to include both short term and long term investments? We need a wider view of the economic system and what is prudent and secure. Former legislation was based upon former economic realities. Gold at one time was the only secure investment and any other holding was consider foolish, commodities were considered the only investment as well, then property was, then money exchanges and transfers were, then armaments was, then it was based for a while on the nuclear power, then at time industrial output and production, then technological innovation, on and on I can go. Even today many of these are of value, but the City of Oceanside's Treasury Department seems to concentrate on just 2 investments even though there are others. In light of this our City's authorized and actual investments may not be meeting the primary investment goals and need to be revamped.

Should the Management of the city's funds be non-responsive to the directions and desires of the Citizens? The City's Investment Policy gives almost full authority to invest the Citizens contributions to only the City Treasurer, Treasury Manager, Investment Officer and Deputy Treasurer with a "Citizen's Investment Oversight Committee" to help discuss the investments.
The City's Investment Policy only recognizes the funds that are being invested as "the Monies" and City Treasurer, being a publicly elected official, is only guided by a semi-vague philosophy that is economically biased and slanted towards money markets that benefit mainly global investments and government bonds. They have forgotten whose funds are these, these funds, these "investment pools" are the taxpayers funds not the City's, the Councils or Treasurers and we need to include the public in most every step we can as part of the intent of the sun shining laws and the desire to be as transparent as possible to avoid even the sense of impropriety. When the funds are referred to in the investment policy they need to be given the source and ownership of those funds, the Citizen Taxpayers/Ratepayers!
The Citizens Investment Oversight Committee is suppose to be one of those Citizens links, with the duties of discussing "current market conditions and future trends and how each of these affects the fund and the city." but the composition of the Committee is not reflective of the Citizens at large and their contact information is not easily accessible. Also they seem to have presented to them only the money market and government bonds as investments as options and when they have inquired about national or global ramifications and impacts, that go against mainly the Republican Political party mainstays of investments, the answers and options that they are given seem only to follow this party's political lines of investment thoughts. There are little, if any, alternatives given or potentially original ideas or strategies, discussed, considered or explored. This maybe due to the disconnect the Treasurers Office has with the public and mainstream flow of information, as information is a two way street listening and talking, thus fully and effectively communicating as for examples:
  • 1) Neither the City Treasurers Office purpose, vision, the Investment Policy, who the City is invested with, links to those investment sites, the Treasurers full contact information, nor even the Investment Oversight Committees Agendas, work plans or even meeting times and locations are posted on the internet to provide enhancements of this communication pathway According to the Current City Treasurer there has been a request for such but there are imposed barriers to these postings by our city's I.T. department who is controlled by the City Manager and who is directed by the City Council. In the past the City Manager proposed to merge the City's CFO office with the City Treasurers Office as many of the activities and duties overlap, the Council after input by the City Treasurer and City Manager decided against this. Could this failure be at the root cause of this slow inclusion of the City Treasurer and the Treasurers Office inclusion on the City's Web site or is it due to Item #4 in this list?
  • 2) The Treasurers office is not required to hold even a yearly public meeting to gain information, concerns or ideas. This is an optional choice of an elected official and can be scheduled into the working of the office and even be formalized and codified included into city's ordinances and codes, but it isn't. After all it is the taxpayers funds not the City's or Treasurers and we need to include the public in most ever step we can as part of the intent of the sun shining laws and the desire to be as transparent as possible to avoid even the sense of impropriety.
  • 3) When one approaches the Counter of the Treasurers Office it is intimidating, a window and Telephone unlike most all other city Departments. This problem could easily be solved by either stationing a person at this location or combining the Clerks Counter and Treasurers Counters Service areas with someone there to greet folks and help with their problems, ideas or concerns.
  • 4) And the City Treasurer has not asked that these and other types of open and public communication enhancements be included onto the City Councils agenda for consideration either nor were they allocated for in the yearly budget process/review as a goal or planned public service of the City Treasurers Office.
  • 5) The composition of the Citizens Oversight Investment Committee is solely at the Choice of the City Treasurer with little public input, concurrence or recommendations even by the City Council. And since these folks serve at the pleasure of the City Treasurer alone, this board is unlikely to disagree with the suppositions of the City Treasurer or bring forth alternative perspectives or ideas in an actual real review of the investment portfolio and budgetary impacts. This oversight board is not really an oversight board as it has no power to do anything except discuss items and is merely advisory. And since their membership is not commonly disclosed again the public has reasonable input.

The Investment Policy says the "the Treasury Manager and staff will observe, review and react to changing conditions that affect the fund." One condition that really affects the funds is that there are many other delineated duties and the staffing of this department and the Treasurers Office is lean almost to the point of being anorexic. The City Treasurer and Investment Manager have both publicly stated repeatedly to seemingly the deaf ears of the City Council and others their extensive nature of their duties and burdens. But again as in item #4 above the City Treasurer has not asked that these and other types of needs be included onto the City Councils agenda for consideration either nor were they allocated for in the yearly budget process/review as a goal or planned public service of the City Treasurers Office. There are many paths to this solution in addition to the option of only hiring more staff, as the work being done does overlap at times the City's Financial Office and duties of the CFO and it does give some credence to the City managers proposal to merge areas of overlapping considerations and duties, thus providing a larger work force to get the job done. But this is a strictly political issue as the voters have determined the Office of the City Treasurer shall be an elected Official and the common misperception of the public is that the City treasurer guides both the expenditures and investments of the city. So another course that can be taken is mutual cross training of employees and a professional examination of the structure that is currently being used to accomplish tasks, is what currently being accomplished the most effective use of the taxpayers funds? This has not even been considered. Another point is the vagueness of "react to changing conditions that affect the fund". Here we find an open interpretive process that can be guided by the whim of the Treasury Manager and staff. And the only person the treasury manager has to report to is the City Treasurer according to the Investment policy. The Treasury Manager is thusly bound by the risk management scenario as it says "to concentrate only on maximizing yield would be imprudent" however the primary goal 3 of the investment policy is "to generate the maximum amount of investment income within the parameters of prudent Risk management and required liquidity." Now this presents a form of a conflict at times as the City Treasurer and Treasury Manager are to go for the "maximum amount of investment income" however they can't due to the imprudence of concentrating "only on maximum yield" written into the same Investment policy. So precisely how, by City Council direction and edict of the City Treasurer, is the management of the Treasury to occur? I believe these sections need to be reworked a little. The policy we have in the City of Oceanside is to also have mixed fruit salad as all unexpended cash is to be mixed together except employee retirement, deferred compensation funds and bonds for investment purposes. This has presented some problems in that both the Utilities Commission and the Integrated Waste Commission have heard the citizen ratepayers and they know their unexpended cash is in this mix but they have questioned what is the real interest on their ratepayers funds and what happens to the interest off these funds and shouldn't that interest go to reduce or stabilize the service costs or be returned to the ratepayers and not dumped into the general fund for other than the purposes delineated (and throughout the state and nation many communities are beginning to ask the same question) ? Some legislators are also questioning the retention of Capital Project and Agency dispersed funds for excessively long periods of time and are now demanding that these funds be expended in a dramatically short period of time or returned to the State or Federal Government. Therefore we need to consider separating these funds and use them for the purposes they were intended. It may make some sense to group them together and keep them as long as possible to gain interest benefits but the public generally wants their money to show them benefit directly. So the investment strategy should reflect the public interest and not the governments only. And this attitude should be respected and evaluated from time to time. The objectives of the investment portfolio are excellent:
  • a) Safety of Principal
  • b) Liquidity
  • c) Return on Investment Each of these can be interpretive as well as long as capital loses are avoided, the risks are not extreme, the liquidity basically is based upon having sufficient funds to operate the city via immediate call ability and structured maturity dates, and its returns are above market average limited by economic cycles. So again we see the potential for expanding our scope of investment strategies. However there is an absence of long term investments due to state law and by this Investment Policy that provides only limited choices of investments unless creative methodologies are used.
Another section of this Investment Policy is good but it has a severe lacking in potential ethical standards. This lacking is a form of secondary Pay for play scenarios. This lacking presents a potential of huge problems especially with PACs and donations to campaigns through other organizations and political parties and other favors under the guise of political education from those who have had business transactions with the city funds and its investment portfolio. This is a common factor of issues before the City Council and being the city council is the final approval and certification body of this Investment portfolio they should act according to this section of the policy but often they do not and they accept donations from providers and clients of the City especially in preparation and during election season. In the Investment Policy there is only a requirement of disclosure and as such also there is no measure in this section for reclusal from any further association in dealings and a lack of other interests impacts than only "personal business activity". So the impartiality potential is at risk for any and all who transact or govern the City's Treasury.
As to actual investments governed by the City's Investment Policy it appears as this:
  • US Treasury Bills, Bonds and Notes Unlimited
  • US Government Agencies Obligations Unlimited (Except that only 25%can be with a singular agency investment of the total invested in this area)
  • Bankers Acceptances up to 20% of the portfolio (For no more than 180 Days, with 5% in any one bank)
  • Time Deposits up to 15% of the Portfolio
(Real Estate Mortgages may not be accepted as collateral, but there is no prohibition of investments in property or property holdings)
  • Repurchase Agreements up to 30% of the portfolio
(For no more than 30 days)
  • Reverse Repurchase Agreements up to 15% of the portfolio
(For no more than 60 days)
  • Commercial Paper up to 15% of the portfolio
(For no more than 270 days and no more than 5% of the Portfolio in any one company)
  • Medium Term Notes up to 15% of the portfolio
(For A rated companies a limit of 24 months, for AA rated companies no more than 36 months and no more than 5% of the portfolio in any one company)
  • LAIF up to the maximum amount allowed by LAIF
  • Restricted Investments no more than 10% of the portfolio
_____________________________________________________
For a loose Total of:
120% plus
I've poised the question about this figure and areas of investment before, is this structure too loose? Do the Council and public want or believe in a more restrictive investment scenario or should other forms of Investment take place? If some areas of allowable investments are occurring and others are not being taking advantage of, the scenario of the current Investment Strategy deems and requires an answer and regular reporting as to why not the broad diversification plan that has been adopted isn't being fully abided by as diversification is one of the key primary Objective standards of both the Safety of the Principal and Liquidity. Diversification is a mandate as well under both Credit Risks and Market Risks and as the City has adopted a broad Investment Strategy

The pathway the world of economics is taking involves extensive electronic transfers and there is a concept that is taking hold in our society of a cashless society. There are no provisions in the Investment Policy for this advancement or for the safe and prudent electronic transactions, such as:
  • a) long term data storage,
  • b) Duplication back and storage of real time and daily transaction records,
  • c) Electronic Recordings of transactions made
  • d) Safeguarding procedures and policies against an inside or outside party manipulation of the funds and their transfers,
  • e) Requirements for insurance on the transactions to cover the city in case of hacking, intrusion, manipulation, entry errors or unauthorized access
  • f) Responsibility of the City Treasurer to have a regular review and certification of the electronic-calculating systems and programs used either internally by the City's IT Department for the Treasurers office or externally supplied certification by those entities the City is invested with.

The Policy allows for changes to be made "at least annually" therefore it can be reviewed at other times. I believe it is time to revisit our City's Investment Policy to ascertain the answers to these concerns, ideas and issues. I believe we also need to see how Oceanside stacks up with other Cities in the County to gain a broader understanding of our strengths and weaknesses and then adjust our Investment Policy accordingly. I hope this helps everyone gain insight into the way the City does its economic investment business and how it can be improved.

Thank You, Jimmy Knott III

Thank You....Jimmy Knott for Oceanside City Treasurer

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