Investment Policy Statement

Investment Policy Statement
Table of Contents
I. Scope
II. Investment Objectives
III. Standards of Care
IV. Investment Controls
V. Investment Parameters
VI. Performance Review and Reporting
VII. Record Keeping and Safekeeping
VIII. Policy Considerations
IX. Policy Adoption
I. Scope
This Investment Policy Statement (hereafter, “IPS”) provides the general
investment goals and objectives of the investment plan (hereafter “The Plan” or
“Plan”) named on the execution page and outlines the strategies that the interested
parties or Investment Committee (hereafter, “Committee”) and its leader
representative (hereafter, “Chairperson”) should employ to meet stated investment
objectives. The IPS and items outlined in it are a resource for Plan assets and are to
be consultative in nature as a resource for the Chairperson - the ultimate caretaker of
the Plan and its assets.
II. Investment Objectives
The Plan’s overall investment objective is to achieve a better than its stated actuarial
rate of return as outlined by actuarial assumptions for the Plan while taking
appropriate amounts of risk. Due to the fact that the assets are being managed as a
pool within the account, great care will be taken to analyze the portfolio, time
horizon, and risks as an omnibus account.
III. Standards of Care
The Plan will abide by any and all regulatory, ethical, moral, and professional
conventions in an effort to promote fairness and integrity in every element of Plan
investment management. Great prudence should occur in managing the assets while
maintaining ethics and mitigating conflicts of interest as they arise. Delegation of
authority may occur but the ultimate responsibility will be borne by the Chairperson.
Further, a check and balance system will be in place to minimize potential shortfalls
with respect to the Plan assets and overall investment objectives.
Only the Plan Chairperson accepts liability for investment performance and Fiduciary
(hereafter “Fiduciary”) responsibilities for Plan assets. It is worth defining what a
Fiduciary is as well as their responsibilities in light of the Plan and its assets. A Fiduciary
is a person/entity having discretionary authority over the disposition of the Plan assets
and those individuals who render investment advice sometimes for a fee (or other direct
or indirect compensation). A Fiduciary will be liable for a breach of responsibilities if
the Fiduciary participates knowingly in, or knowingly undertakes to conceal, an act or
omission of such of other investment beneficiaries, knowing such act or omission is a
breach. In addition, should the Fiduciary fail to comply with norms, mores, investment
theories, he or she will defer to an appointee.
Some interested parties include: Named person on execution page (Chairperson and
Fiduciary) and the overall plan consulere is VastSolutionsGroup.com and/or appointees.
IV. Investment Transactions
Transactions involving the Plan’s assets will be conducted by the Chairperson and
from time-to-time may be accomplished by delegated parties. Transactions by the
Chairperson will be communicated to the Committee by the 30th day after calendar
year end.
V. Investment Parameters
Plan investments may be delegated to Investment Managers (hereafter, “Managers”)
who are expected to manage investment assets in a way that conforms to Plan goals
and objectives. In doing so, the Plan can include, but be only limited to, cash and
equivalents, stocks, bonds, mutual funds, life insurance, real estate or property, fixed,
immediate, notes, cryptocurrencies, variable annuities and/or other investments the
Chairperson deems appropriate and in line with regulations and investment theories.
Managers may be placed under review or replaced if underperformance occurs as
compared to comparable respective benchmarks and peer groups for three and/or five
consecutive years on a three and/or year rolling basis. Further, great care must be
displayed in analyzing risk-adjusted returns.
For selected asset classes investment performance will be based on the comparable
benchmarks as follows:
Cash and Equivalents: Solomon 90 Day Treasury Bill Index
Bonds or Annuities: Bloomberg Barclays US Aggregate Bond Index
Domestic Stocks: FTSE Russell Company® Style Specific Indices
International Stocks: MSCI, Inc.® International Indices
Cryptocurrency: Bitcoin on Coinbase.com
Other unannounced assets: A comparable index
or other comparable indices as decided upon the Committee
For selected asset classes investment performance will be based on the respective
comparable peer group as judged by its Morningstar Category. If not deemed applicable,
the Committee may choose not to utilize peer group analysis.
Managers are to provide plan year end account valuations no later than five days after
plan year end. If requested by the Committee, these may be requested quarterly.
The overall asset allocation will attempt to maintain a general profile of 60% equities
(stocks) and a 40% fixed income (bonds or bond-like investments). The range may
deviate to 80-40% equities and 20-60% fixed income as deemed appropriate.
Reallocation of assets will be conducted by the Chairperson or appointees. Based upon
the recommendation of the Committee, these allocations may change periodically.
VI. Performance Reviews and Reporting
Ongoing performance and review will be conducted on at least an annual basis, if not
quarterly. The meeting must consist of at least one committee member(s) and the
Conselere for the Plan. The meeting must occur on a timely basis after the last day of the
Plan year.
VII. Record Keeping and Safekeeping
The Chairperson or, if appointed, Conselere will make every attempt to ensure accurate
records, meeting notes, and pertinent IPS changes are kept for at least a period of ten
years. Additionally, copies of all monies (checks) sent on behalf of the Plan must be
maintained for at least a period of 15 years. All records must be maintained in a secure
environment.
VIII. Policy Considerations
At times the policies outlined in this IPS are understood to be too onerous for practical
purposes. In selected instances, and by exception only, this document can be subservient
under certain circumstances. Further, this IPS will be reviewed at least once every five
years and therefore revisions of the document may be appropriate.
IX. Policy Adoption
I (we) the undersigned do hereby accept this Investment Policy Statement as a general
guidance to managing the assets of the Plan.