MDTA Board Meeting Materials

Policy No..: MDTA 7010 Effective: August 16, 2005

i. Investments and investment practices shall be in compliance with applicable provisions of the Annotated Code of Maryland and to the extent applicable to the MDTA, guidelines established by the State Treasurer and the GASB. Section 6-222 of the State Finance and Procurement Article of the Annotated Code of Maryland does not govern the investment of the MDTA’s revenues. This State law applies to political subdivisions, municipal corporations and other specified governmental entities, but not to agencies or units of the government of the State of Maryland. Section 4- 311 of the Transportation Article of the Annotated Code of Maryland gives the MDTA statutory authority to enter into a Trust Agreement and to pledge its revenues. Permitted investments are primarily driven by the definition of Investment Obligations contained in the Second Amended and Restated Trust Agreement dated as of September 7, 2007, with some additional consideration of any other obligations that constitute legal investments for State agencies such as the MDTA. ii. The CFO or the Director of Treasury and Debt Management shall report to the Finance Committee any material deviations from this policy. iii. The CFO or the Director of Treasury and Debt Management shall immediately report to the Finance Committee any security holding credit rating downgrade initiated by at least two Nationally Recognized Statistical Ratings Organization (NRSRO) or one NRSRO for securities with only one credit rating.

II. Ethics

a. Policy Statements 2. Employees involved in the investment process shall refrain from personal business activity that may create conflicts of interest. Furthermore, employees: i. Are prohibited from undertaking personal investment transactions with the same individual with whom business is conducted on behalf of the MDTA. ii. Must provide annual financial disclosures in accordance with the requirement of the State Ethics Commission, and as otherwise required by law. III. Delegation of Authority a. Policy Statement 3. The MDTA’s power to manage investment of public MDTA funds is subject to any applicable State and federal law, including Title 4 of the Transportation Article of the Annotated Code of Maryland and Title 6 of the State Finance and Procurement Article of the Annotated Code of Maryland, the MDTA’s Master Trust Agreement, Article V, Section 5.02 and applicable provisions of any other MDTA Trust Agreements. i. Responsibility for the operation of the investment program has been delegated by resolution to the CFO and certain Directors of the Finance Division, who shall establish and maintain written administrative procedures and internal controls for the operation of the investment program, consistent with this Investment Policy. Such procedures shall include: 1. Explicit designation of the person(s) responsible for investment transactions.

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