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XII. BID REQUIREMENTS FOR DEBT INSTRUMENTS <br />After the investment manager, which may be the Chief Deputy Comptroller or her <br />designee, has determined the approximate maturity date based on the cash flow needs and <br />market conditions and has analyzed and selected one or more optimal types of <br />investments, a minimum of three qualified brokers and/or dealers will be contacted and <br />asked to provide bids on the securities in question. <br />In most situations the competitive bid process shall be utilized, except when securities are <br />purchased as an initial offering. The investment manager will choose the appropriate <br />brokers or dealers from among those on the approved broker/dealer list based on <br />expertise, competitiveness and the ability to execute the transaction and deliver the <br />securities on a timely basis. A minimum of three (3) bids will be obtained. <br />A broker's response that they are unable to bid on the investment can be counted as one <br />of the required bids. <br />1. Bids will be held in confidence until the best bid is determined and awarded, <br />2. Documentation will be retained for all bids, with the winning bid clearly <br />identified, <br />3. If for any reason the highest bid (on sales of investments) or the lowest bid (on <br />purchases of investments) is not selected, then the reasons leading to that decision <br />will be clearly documented, <br />4. If the maturing investment is a certificate of deposit, the present holder of the <br />funds will be one of the contacts made, subject to the portfolio diversification <br />requirements in this policy and the institutions' ability to maintain collateral. <br />XIII. INTERNAL CONTROLS <br />The OPEB Trust Board shall adopt a written set of internal controls to be implemented by <br />the Clerk of the Circuit Court or his designee, which said controls are designed to protect <br />the OPEB funds and ensure proper accounting and reporting of securities transactions. <br />Such internal controls shall consist, at a minimum, of the following: <br />1. All securities purchased or sold will be transferred only under the "delivery versus <br />payment" (DVP) method to ensure that funds or securities are not released until <br />all criteria relating to the specific transaction are met, <br />2. The Clerk of the Circuit Court or his designee is authorized to accept, on behalf of <br />and in the name of Indian River County OPEB Trust Fund, bank trust receipts or <br />confirmations as evidence of actual delivery of the obligations or securities in <br />return for investment of funds, <br />6 98 <br />