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140.012 Investment Policy for General Pool

Bd. Min. 12-6-91; Amended Bd. Min. 12-9-93; Amended Bd. Min. 11-14-94; Amended Bd. Min. 12-13-96; Amended Bd. Min. 9-26-97; 1-21-98; Revised 2-01-00; Amended Bd. Min. 9-27-02; Amended Bd. Min. 11-22-02; Revised 1-5-04; Amended Bd. Min. 9-9-04; Amended Bd. Min. 1-26-07; Amended Bd. Min.2-6-09; Amended Bd. Min. 6-5-09; Amended Bd. Min.6-17-11; Revised in entirety, Bd. Min. 6-26-12. (Note: Board approval on 6-26-12 replaced previous rules 140.010, 140.011, 140.012 and 140.013 with new language and reissued new rules 140.010 through 140.016.) Amended Bd. Min. 1-31-13; Amended Bd. Min. 6-25-15; Amended Bd. Min. 10-1-15; Amended Bd. Min. 10-7-16; Amended Bd. Min. 11-15-18; Amended Bd. Min. 9-24-20; Amended Bd. Min. 4-21-22; Amended Bd. Min. 11-17-22.

  1. Introduction – The General Pool represents the University’s cash and reserves, both restricted and unrestricted, including, but not limited to, operating funds, auxiliary funds, service operations funds, self-insurance funds, debt service funds, and plant funds.
  2. Responsibilities and Authorities – See CRR 140.010, “Policy for Management and Oversight of Selected University Investment Pools
  3. Investment Objectives – The General Pool shall be managed in a way that both recognizes and balances the underlying needs of the pool, including, but not limited to, accommodation of University cash flow cyclicality, satisfaction of various ongoing liquidity needs, maximization of risk-adjusted investment returns, diversification and preservation of capital.
  4. Authorized Investments – The General Pool shall be invested as follows:
      Investment Portfolios
      Liquidity Core Strategic Portable Alpha
    Management Internal/External External External External
    Minimum Allocation 20% 0% 0% 0%
    Maximum Allocation 100% 60% 45% 15%
    Liquidity Objective High Moderate Moderate/Low Moderate
    Volatility Tolerance Low Moderate Moderate/High Low/Moderate
    Return Expectation Low Moderate Moderate/High Moderate
    1. Liquidity Portfolio
      The Liquidity portfolio is expected to have very low volatility and low (cash-like) returns. It is the primary source of liquidity for the University’s operating cash flow needs, constructed utilizing securities and investment vehicles that primarily have same day liquidity with minimal day-to-day price fluctuations. Exposures will be obtained by investing in the following:
      1. Bank deposits covered by FDIC insurance or otherwise collateralized by U.S. Government and U.S. Government Agency securities.
      2. Money market funds which are SEC 2a-7 compliant and have received the highest possible rating by at least two Nationally Recognized Statistical Rating Organizations.
      3. Commercial Paper which has received a rating of at least A1 / P1 / F1 by two of the Nationally Recognized Statistical Rating Organizations
      4. Repurchase Agreements collateralized by the U.S. Government and U.S. Government Agency securities.
      5. Yield Enhancement Strategies that seek returns higher than, or comparable to, traditional cash investments, while diversifying the risk inherent in traditional cash investments. To implement these strategies, liquid non-cash-like securities are often purchased in conjunction with a hedge instrument that substantially hedges away the non-cash-like attributes of the securities. Instruments that may be part of such transactions include: U.S. Treasury securities, sovereign bonds issued by G10 countries, and other fixed income securities and precious metals. To hedge away the non-cash like attributes, the following instruments may be used: futures contracts, asset/interest rate swaps, currency forwards, securities lending agreements, and repurchase agreements.
      6. Other short-term investment vehicles of similar quality, with an average duration of one year or less.
      7. U.S. Treasury securities, U.S. Government Agency securities and U.S. Government guaranteed securities, including but not limited to: all direct obligations of the U.S. Government, Federal Farm Credit Banks, Federal Home Loan Banks, Federal National Mortgage Association, and Federal Home Loan Mortgage Corporation.
      8. Internal short-term loans at market interest rates to the University’s Central Bank as a substitute for commercial paper which could otherwise be issued externally by the Central Bank under the University’s Commercial Paper Notes program. Such short-term loans must be approved by the Vice President for Finance.
    2. Core Portfolio
      The Core portfolio is expected to have moderate volatility with moderate returns, invested primarily in public debt securities and related investment vehicles. It will serve as a secondary source of liquidity, built utilizing excess operating funds not expected to be needed for purposes of funding the operational needs of the University under normal circumstances. This portfolio will be expected to generate higher returns than the Liquidity portfolio through the use of some combination of credit risk, interest rate risk, illiquidity risk and idiosyncratic (active) risk.
      1. Public Debt
        Specific types of debt exposures include, but are not limited to, sovereign, corporate, inflation-linked, high yield, emerging market, commercial mortgage-backed securities, and residential mortgage-backed securities.
        Exposures will be obtained through physical securities as well as derivative instruments commonly accepted by other institutional investors such as futures, swaps, options, forward contracts, and reverse repurchase agreements may be utilized. Exposures may include long/short positions.
        Legal account structures will primarily be in the form of separately managed accounts and institutional commingled funds, however, from time to time limited partnership agreements or other similar forms may also be utilized.
    3. Strategic Portfolio
      The Strategic portfolio will be built utilizing excess operating funds that should not be needed for liquidity purposes. As compared to the Core portfolio, the Strategic portfolio will have higher return expectations and a higher level of expected volatility. These are truly long-term funds and should be thought of similarly to retirement and endowment funds.
      1. Risk Balanced
        It is expected that this portfolio will be meaningfully balanced across traditional risk factors including equities, real interest rates, inflation (both actual and expected), commodities and credit.
        Additionally, non-traditional risk factors including value, momentum, carry, defensive and trend may be included. It is also expected that idiosyncratic (active) risk will be taken in this portfolio from time to time.
        Exposure will be obtained through physical securities and/or conventional derivative instruments commonly accepted by other institutional investors such as, futures, swaps, options, forward contracts and reverse repurchase agreements.
        Legal account structures will primarily be in the form of separately managed accounts, institutional commingled funds and limited partnership agreements.
      2. Real Estate/Infrastructure
        Specific types of fund investments may be structured as equity and/or debt and include categories broadly defined as core, value added, and opportunistic. In addition, investments may be made in real estate investment trusts and master limited partnerships from time to time.
        Legal account structures will primarily be in the form of limited partnership agreements with average tenure of 10-12 years. Separately managed accounts and institutional commingled funds may also be utilized from time to time.
      3. Private Debt
        Specific types of long-only and long/short strategies including, but are not limited to, distressed debt funds, distressed for control funds, whole loans and pools, levered loans and pools, and mortgage servicing rights.
        Legal account structures will primarily be in the form of limited partnership agreements.
      4. Venture Capital
        Investments shall be consistent with the University’s mission to foster innovation in support of economic development. Maximum allocation shall be $5 million.
        Investments require unanimous approval by the Executive Vice President for Finance and Operations and the Chief Investment Officer in consultation with the President.
        Utilization of external managers shall be consistent with the guidelines established in CRR 140.011, “Policy for Investment Manager Selection, Monitoring and Retention.
      5. Endowment Pool
        As part of its Strategic Portfolio, the General Pool may invest in the University’s Endowment Pool, as established and governed by CRR 140.013, “Investment Policy for Endowment Pool.”
    4. Portable Alpha Program
      When synthetic market exposures are obtained through derivative instruments, a portion of the resulting cash and cash equivalent balances may be invested in a portfolio of active alpha managers seeking to add excess returns to the General Pool.
      1. Alpha Portfolio Composition
        In aggregate, the alpha portfolio will be constructed with broadly diverse strategies/styles and is expected to produce returns that show little or no relationship to the economic environment being experienced at any given time. Furthermore, the alpha portfolio will be constructed with a goal of low/no correlation to the synthetic market exposures obtained through the derivative instruments used to fund the program. The risk drivers within the alpha portfolio should generally be well-known, empirically tested sources of return that can be actively or systematically harvested through dynamic long/short strategies. They can be thought of either as returns that underlie “classic” hedge fund strategies (hedge fund risk premia), such as arbitrage and macro or the returns from “classic” styles (style premia), such as value, momentum, carry, defensive and low volatility.
        Legal account structures will be in the form of one or a combination of separate accounts, institutional commingled funds and/or limited partnerships or other similar forms.
      2. Allowable Range
        The allowable range for the portable alpha portfolio shall be 0-15% of the total General Pool, which would represent total portfolio leverage of 100% to 115%.
      3. Management of Portable Alpha Program Liquidity Risk
        Management of liquidity risk is a critical component of the portable alpha program. If not managed appropriately, there is a risk that synthetic market exposures may need to be unwound at undesirable points in time in order to meet margin calls during volatile markets. To help mitigate this risk, prudent balances of cash and cash equivalents shall be maintained as part of the program and monitored daily.
        For purposes of this policy, Cash Margin is defined as the underlying balance of cash and cash equivalents which have not been used to fund the alpha portfolio. Using an illustration to further clarify, if futures contracts were used to obtain $100 million in US Treasury notional exposures and $90 million of the underlying cash and cash equivalents were used to fund the alpha portfolio, the remaining $10 million of cash and cash equivalents would be considered the Cash Margin. The Cash Margin percentage would be 10% ($10 million divided by $100 million notional exposure).
        The sufficiency of Cash Margin for the portable alpha program notional exposures shall be determined by the modeling of economic and market stress scenarios including, but not limited to, the fall 2008 Financial Crisis, May 2013 Taper Tantrum and March 2020 COVID Crisis. Across the stress scenarios modeled, the remaining Cash Margin shall be at least 5%. The results of these modeled stress scenarios shall be reported to the Board on a quarterly basis.
  5. Risk Management
    1. The Chief Investment Officer shall establish and implement procedures to:
      1. Regularly monitor the University’s cash flow forecasts.
      2. Maintain minimum daily liquidity (securities or investment vehicles which can be liquidated on a same-day basis) equal to 30 days operating cash outflows for the University.
      3. Maintain minimum weekly liquidity (securities or investment vehicles which can be liquidated within 5 business days) equal to 60 days operating cash outflows for the University.
      4. As applicable, maintain overall liquidity sufficient to satisfy credit rating agency guidelines for any self-liquidity needs of the University’s debt portfolio.
      5. Maintain a contingency funding plan to address unanticipated market / liquidity events, with the objective of having ready access to cash to meet the University’s operating cash flow needs at all times.
      6. Based on the level of projected risk within the General Pool, as modeled by the University's Investment Consultant, maintain appropriate reserves within the General Pool to mitigate drawdown risk, allowing the University to better manage through periods of market volatility.
  6. Excluded Instruments – The General Pool shall not be deemed to include, and the limitations contained herein shall not be deemed applicable to, any program-related funds, instruments, and assets not held primarily for investment such as interests governed by CRR 70.070, “Entrepreneurial Activity.”

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