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Transcript
The Association of Healthcare Internal Auditors
Investment Policy Statement
DRAFT
January, 2012
Introduction
Mission Statement and Purpose of Funds:
For the purposes of managing investment risk and to optimize investment returns within acceptable risk
parameters, the Association of Healthcare Internal Auditors (AHIA) funds will be held in three investment
pools called the “Operating Fund,” “Short Term Fund,” and the “Long Term Investment Fund”.
To carry out the investment activities as described in this document, the responsibilities of the involved
parties are described below. These parties include, but are not limited to the Budget and Finance Committee,
the Board of Directors, the Investment Consultant, the Investment Managers and the Custodian.
Assignment of Responsibilities
Responsibility of the Finance Committee
The Budget and Finance Committee is charged with the responsibility of managing the AHIA’s investable
assets in accordance with its purpose and restrictions. The Budget and Finance Committee shall discharge its
duties solely in the interest of the Association, with the care, skill, prudence and due diligence under the
circumstances then prevailing, that a prudent person, acting in a like capacity and familiar with such matters
would use in the conduct of an enterprise of like character with like aims. The specific responsibilities of the
Budget and Finance Committee relating to the investment management of assets include:
1. Establishing reasonable and consistent investment objectives, policies and guidelines that will
direct the investment of the assets;
2. Determining the risk tolerance and investment time horizon and communicating these to the
appropriate parties;
3. Prudently and diligently selecting qualified investment professionals, including Investment
Manager(s), Investment Consultant(s), and Custodian(s);
4. Conveying the financial needs of the Association to the Investment Consultant on a timely basis;
5. Quarterly evaluation of the performance of all investments, including the Investment Consultant’s
choice of Investment Manager(s) to assure adherence to policy guidelines and monitor investment
objective progress;
6. Developing and enacting proper controls and procedures; and
7.
Ensuring compliance with asset allocation targets.
Responsibility of the Investment Consultant (The J.K. Meek Group)
The Investment Consultant’s role is to provide investment advice concerning the investment management of
the assets and will be consistent with the investment objectives, policies, guidelines and constraints as
established in this statement. Specific responsibilities of the Investment Consultant(s) include:
1. Assisting in the development and periodic review of investment policy;
2. Conducting investment manager searches;
3. Providing “due diligence”, or research, on current or prospective Investment Manager(s);
4. Providing recommendations on investment managers to hire or terminate;
5. Hiring and terminating Investment Managers or Mutual Funds;
6. Monitoring the performance of the Investment Manager(s) in regard to benchmarks and peers and
complete a tri-party performance reconciliation to provide the Budget and Finance Committee
with the ability to determine performance and the progress toward the investment objectives;
7. Communicating matters of policy, manager research, and manager performance to the Budget and
Finance Committee;
8. Monitoring the asset allocation of the Associations Long Term Fund and providing the Budget
and Finance Committee with recommendations for rebalancing;
9. Reviewing investment history, historical capital markets performance and the contents of this
investment policy statement with any newly appointed members of the Budget and Finance
Committee and The Board of Directors.
Responsibility of the Investment Manager(s)
Each Investment Manager will have full discretion to make all investment decisions within the specific
risk/asset framework for the assets placed under its management. Specific responsibilities of the Investment
Manager(s) include;
1. Discretionary investment management including decisions to buy, sell, or hold individual
securities;
2. The timely reporting of quarterly investment performance;
3. Effective management of assets with the expectation of meeting or exceed respective benchmarks
and peer performance;
4. Communicating any major changes to economic outlook, investment strategy, or any other factors
that affect implementation of investment process;
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5. Informing the Investment Consultant of any qualitative change to the investment management
organization. Examples include changes in portfolio management personnel, ownership
structure, investment philosophy, etc;
6. Voting proxies, if requested by the Budget and Finance Committee, on behalf of the Board of
Directors, and communicating such voting records to the Budget and Finance Committee on a
timely basis.
Responsibilities of the Custodian
The Custodian will physically (or through agreement with a sub-custodian) maintain possession of securities
owned by the Association, collect dividend and interest payments, redeem maturing securities, and effect
receipt and delivery following purchases and sales. The Custodian will also perform regular accounting of all
assets owned, purchased or sold, as well as movement of assets within fund accounts. The Custodian will
reconcile with managers and provide related reports to the Board.
Procedures
1. The following procedures will be followed to ensure the investment policy statement is consistent
with the current mission of the Association and accurately reflects the current financial condition:
A.)
This policy statement shall be reviewed at least annually by the Budget and Finance
Committee for any necessary revisions.
B.)
Any recommendations for revisions or modifications will be made by the Budget and
Finance Committee to the Board of Directors for final approval.
2. To maintain the proper level of reserves placed in the Operating Fund (if held at MSSB), the
Budget and Finance Committee, based on cash flow projections provided by the Board of
Directors, will authorize transfer of funds from the Short Term Fund, Long Term Fund, or other
account to the Operating Fund.
3. The services of an Investment Consultant (currently The J. K. Meek Group) may be sought to
assist in the oversight of the Association’s investment assets. The following procedures shall be
followed to engage a new or replace a current Investment Consultant;
A.)
The Budget and Finance Committee will review and recommend the hiring or replacing
of an Investment Consultant.
B.)
The Board of Directors shall have final approval for the hiring or replacing of the
Investment Consultant as recommended by the Budget and Finance Committee.
4. The services of an Investment Manager(s) will be sought to manage the Association’s investable
assets. The engagement or termination of an Investment Manager will be authorized by the
Board of Directors, acting with the advice of the Investment Consultant. The same procedure
shall apply for both individually managed accounts and mutual funds (with the exception of
money market mutual funds).
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5. To remain consistent with the asset allocation guidelines established by this Investment Policy
Statement, the following rebalancing procedures shall be followed:
A.)
It is the responsibility of the Investment Consultant to monitor the asset allocation of
the Long Term Investment Fund and to make recommendations for portfolio
rebalancing to the Budget and Finance Committee.
B.)
The Budget and Finance Committee shall have final approval for the rebalancing of
the Long Term Investment Fund.
6.
Meetings of the Budget and Finance Committee shall be held for such purpose(s) and at such
time and place as may be determined by the Budget and Finance Committee Chairman. Notice
of the time, place and purpose of a meeting shall be given at least five (5) days prior to the
scheduled meeting date, either in writing or electronically. Members of the Budget and Finance
Committee may attend meetings in person or participate via conference call. Decisions by the
Committee will be achieved by consensus as determined by a simple majority.
7.
An emergency may be declared to exist requiring prompt action and with full responsibilities on
behalf of the full Budget and Finance Committee. Such emergency may be declared by the
following individual(s), and in the following order of priority: (a) the AHIA’s Board of
Directors; or the (b) the Budget and Finance Committee Chair. Emergency actions taken under
such conditions shall be deemed as acts of the full committee and should be documented with the
reasons for such action and brought to the full Budget and Finance Committee’s attention as
soon as practicable.
The Association of Healthcare Internal Auditors
OPERATING FUND (if held with MSSB)
Purpose
The purpose of the Operating Fund is to provide sufficient cash to meet at least 100% of AHIA’s annual
operating budget with at least 6 months operating expenses held in a ready liquid state.
Investment Objectives
The investment objectives of the Operating Fund are:
1. Liquidity;
2. Preservation of capital;
3. To optimize the investment return within the constraints of the policy.
Investment Guidelines
ALLOWABLE INVESTMENTS
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The Budget and Finance Committee with notification to the Board of Directors shall be authorized to invest
the Operating Liquidity Fund as follows:
1. Checking accounts in U.S. federally insured banks and savings and loans not to exceed federally
insured amounts;
2. Money market funds;
3. Federally-insured certificates of deposit not to exceed the insurable limit per institution;
4. Direct obligations of the U.S. Government, its agencies and instrumentalities;
5. Repurchase agreements in conjunction with bank sweep accounts collateralized by U.S.
Government obligations;
6. Commercial paper rated A-1/P-1 by Standard and Poor’s and Moody’s.
MATURITY
The maturities on investments for the Operating Fund shall be limited to one year or less. The Budget and
Finance Committee and the Finance Committee Chair shall be responsible for scheduling maturities.
Reporting
The Investment Consultant shall prepare the following reports for presentation on a quarterly basis (monthly
if there has been activity in the account) to the Budget and Finance Committee.
1. Schedule of investments;
2. Interest income year to date;
3. Current yield.
The Association of Healthcare Internal Auditors
SHORT TERM FUND
Purpose
The purpose of the Short Term Fund is to:
1. Meet expenses occurring as the result of unanticipated activities;
2. Improve the return on funds held for expenditure over the next one to five years; and
3. Manage investment risk.
Investment Objectives
The investment objectives of the Intermediate Liquidity Fund are:
1. Preservation of capital;
2. Liquidity;
3. To optimize the investment return within the constraints of the policy.
Page 5
Investment Guidelines
ALLOWABLE INVESTMENTS
The Budget and Finance Committee with ratification of the Board of Directors shall be authorized to invest
the Short Term Fund as follows:
1. Checking accounts in U.S. federally insured banks and savings and loans not to exceed federally
insured amounts;
2. Money market funds;
3. Federally-insured certificates of deposit not to exceed the insurable limit per institution;
4. Direct obligations of the U.S. Government, its agencies and instrumentalities;
5. Repurchase agreements in conjunction with bank sweep accounts collateralized by U.S.
Government obligations;
6. Commercial paper rated A-1/P-1 by Standard and Poor’s and Moody’s.
MATURITY
The maturities on investments for the Short Term Fund shall be limited to five years or less. The Budget and
Finance Committee shall be responsible for scheduling maturities.
Reporting
The Investment Consultant shall prepare the following reports for presentation on a quarterly basis to the
Budget and Finance Committee:
1. Schedule of investments;
2. Interest income year to date;
3. Current yield.
Page 6
The Association of Healthcare Internal Auditors
LONG TERM INVESTMENT FUND
Purpose
The purpose of the Association’s Long Term Investment Fund is to provide funding for current commitments,
to enhance the purchasing power of funds held for future requests, to fund programs and to help provide
additional income required to meet the operating needs of the Association.
Investment Objectives
The long term goal of the Long Term Investment Fund is to achieve appreciation of assets without exposure
to undue risk, as defined herein. It is understood that fluctuating rates of return are characteristic of the
securities markets. Recognizing that short-term market fluctuations may cause variations in the account
performance, the portfolio is expected to achieve the following objectives, net of all fees, over a five-year
moving time period:
1. In order to maintain asset levels capable of:
A.)
supporting desired spending;
B.)
providing additional growth and or income to cover operating expenses;
C.)
preserving the purchasing power of AHIA’s assets over time, the Long Term
Investment Fund’s total return is expected to exceed the Consumer Price Index by 5%.
2. In order to receive a suitable return that is consistent with the ownership of risk assets, the
Investment Fund's total return is expected to exceed the 90-Day Treasury bill Index by 5%.
3. In order to evaluate the decisions regarding manager selection and asset allocation, the
Investment Fund’s total return should outperform a composite index that is a weighted blend of
the indices referred to in the section entitled “Investment Guidelines” herein that reflects this
policy’s target asset allocation.
Understanding that a long-term positive correlation exists between performance volatility (risk) and statistical
returns in the securities markets, the following short-term objective has been established: The portfolio should
be invested to minimize the probability of large negative total returns, defined as a one-year return worse than
-6%. It is anticipated that a loss greater than this will occur no more than one out of twenty years.
Investment Guidelines
The policies and restrictions presented in this Investment Policy Statement serve as a framework to achieve
the investment objectives at the level of risk deemed acceptable. These policies and restrictions are designed
to minimize interference with efforts to attain overall objectives and to minimize the probability of excluding
appropriate investment opportunities.
Page 7
Diversification
The Investment Fund shall be diversified so the portfolio will, on average, yield higher returns and pose a
lower risk than any individual investment found within the portfolio, unless under the circumstances it is
clearly prudent not to do so.
Target Asset Mix
The Investment Fund shall be comprised of the asset classes listed in the table below. The target weight is the
desired weight for each asset class. The minimum and maximum weights are designed to allow for normal
market fluctuations and to allow for temporary over/under weight allocations that are believed to be desirable
by either the Budget and Finance Committee or the Investment Consultant.
The Budget and Finance Committee will monitor the asset allocation of the Investment Fund based on
quarterly reports provided by the Investment Consultant. It is the responsibility of the Investment Consultant
to monitor the Fund on an on-going basis and to make recommendations for portfolio rebalancing to ensure
that the Fund remains within Investment Policy guidelines.
Summary of Asset Allocation Study August 2011: Model 3
ASSET CLASS
MINIMUM
WEIGHT
TARGET
WEIGHT
MAXIMUM
WEIGHT
10%
3%
15%
5%
20%
7%
14%
20%
26%
7%
3%
10%
10%
5%
15%
35%
13%
7%
20%
35%
35%
50%
50%
65%
65%
35%
50%
65%
TRADITIONAL INVESTMENTS
DOMESTIC EQUITY
U.S. Large Capitalization Stocks
U.S. Mid Capitalization Stocks
TOTAL DOMESTIC EQUITY
INTERNATIONAL EQUITY
International Equity Stocks
Emerging Markets Stocks
TOTAL INTERNATIONAL EQUITY
TOTAL EQUITY
FIXED INCOME
U.S. Intermediate Investment Grade Corp
TOTAL U.S. FIXED INCOME
TOTAL FIXED INCOME
TOTAL TRADITIONAL INVESTMENTS
85%
ALTERNATIVE INVESTMENTS
ALTERNATIVE INVESTMENT STRATEGIES
TOTAL
10%
15%
20%
100%
Page 8
Traditional Investments
US Large Capitalization Stocks: A portfolio of stocks composed primarily of US-based companies having a
market capitalization, on average, exceeding $10.0 billion and whose primary shares trade on a major US
exchange. The generally accepted, nationally recognized index for this asset class is the Standard & Poor’s
500 Stock Index (S&P 500)*.
US Mid Capitalization Stocks: A portfolio of stocks composed primarily of US-based companies having a
market capitalization, on average, between $2.0 billion and $10.0 billion and whose primary shares trade on a
major US exchange. The generally accepted, nationally recognized index for this asset class is the Russell
Midcap Index.
US Small Capitalization Stocks: A portfolio of stocks composed primarily of US-based companies having a
market capitalization, on average, less than $2.0 billion. The generally accepted, nationally recognized index
for this asset class is the Russell 2000 Index.
International Stocks: A portfolio of stocks composed primarily of non-US-based companies whose primary
shares trade on a non-US exchange. American Depositary Receipts (ADRs) are considered international
stocks. The generally accepted, nationally-recognized index for this asset class is the Morgan Stanley Capital
International Europe-Australasia-Far East Index (EAFE).
Emerging Markets: A portfolio of stocks composed primarily of companies in the global emerging markets of
Europe, Asia, Africa and Latin America. The generally accepted, nationally, recognized index for this asset
class is the MSCI Emerging Markets Index. (MSCI EM)
Fixed Income Investments
Intermediate-term Government/Corporate Bonds: A portfolio consisting primarily of fixed income securities
rated investment grade or better having a weighted average maturity of less than 10 years. The portfolio also
may include, but is not limited to, other fixed income investments such as investments in Treasury Inflation
Protected Securities (TIPS), International Bonds and Non-Investment Grade Corporate securities. The
generally accepted, nationally recognized index for this asset class is the Barclays Capital
Government/Corporate Intermediate-term Bond Index.
Alternative Investments
Investment in alternatives may be considered by the Association within the context of an overall investment
plan. The objective of such investments will be to seek to diversify the portfolio, complementing traditional
equity and fixed-income investments and improving the overall performance consistency of the portfolio. It is
acknowledged that there is no guarantee that this objective will be realized.
*
Index references that are included in the definition section of this document relate to the broad asset classes as defined in
the target asset allocation table and which are used in the calculation of the composite index. Individual portfolio
managers will be compared to a unique style specific index that most appropriately reflects their investment mandate.
Examples would include, but are limited to the Russell 2000 Value index and the Russell 1000 Growth Index.
Page 9
Alternative investments, including hedge funds, managed futures, commodities, private equity, private real
estate and other non-traditional investments, shall be utilized through mutual funds or professionally managed
pools of such investments to provide for a prudent level of diversification.
Investment Manager Selection and Evaluation Criterion
Investment Manager Selection
In selecting the investment managers for the Long Term Investment Fund, the Budget and Finance Committee
will consider a variety of statistical and non-statistical factors. These factors, measured over a multi-year
period, will include the investment manager’s investment objectives, performance relative to its index and
peer group, risk characteristics, return characteristics, investment style, manager tenure and turnover, style
consistency and the degree of correlation with other fund investment managers.
Investment Manager Monitoring and Review
The on-going monitoring of investment options must be a regular and disciplined process. It is the
mechanism for revisiting the investment manager selection process and confirming that the criteria originally
selected remain so, and that an investment manager continues to be a valid offering. While frequent change is
neither expected nor desirable, the process of monitoring investment performance relative to specified
guidelines is an on-going process.
The Budget and Finance Committee will monitor, on a periodic basis, the same factors identified above under
“Investment Selection”. The placement of a manager on a “watch list” may be required if an investment
manager:
1. has a change in manager or analytical staff;
2. has experienced style drift;
3. has performed unfavorably on an absolute basis relative to its index or peer group over rolling
five year periods;
4. has performed unfavorably on a risk adjusted basis relative to its index or peer group over rolling
five year periods;
5. violated the AHIA’s’s investment policy guidelines;
6. has material litigation filed against the firm;
7. has material changes in firm ownership structure;
8. has exhibited any other factors that the Finance Committee or the Investment Consultant deems
material since the initial selection of the investment option.
Watch list status is expected to last no longer than one quarter and will be used to evaluate the factors that led
to the watch list designation. If, at the conclusion of the watch list evaluation, the Budget and Finance
Committee has overall satisfaction with the investment manager, no further action is required. If areas of
dissatisfaction exist, it is the responsibility of the Budget and Finance Committee, working with the
Investment Consultant, to consider taking steps to remedy the deficiency up to and including the removal of
the investment manager.
Page 10
Investment Manager Removal
The Budget and Finance Committee, working with the Investment Consultant may remove an investment
manager when they believe such removal is in the best interest of the Investment Fund, taking into account
for this purpose all relevant factors including, and without limitation, when the Budget and Finance
Committee has lost confidence in the investment manager’s ability to:
1. Achieve performance and risk objectives;
2. Comply with investment guidelines;
3. Maintain a stable organization and retain key relevant investment professionals.
An investment manager’s consistent failure to adhere to one or more of the above conditions and failure to
remedy the circumstances, within a reasonable time, may be grounds for termination.
The watch list is not the only route for removing an existing manager. The aforementioned events, or any
other events of concern identified by the Budget and Finance Committee or the Investment Consultant, may
prompt the immediate removal of a manager without it being watch listed. Any decision to remove an
investment manager will be treated on an individual basis, and will be made based on quantitative and
qualitative review.
Performance Reporting
The Investment Fund will be evaluated quarterly on a total return basis. Returns will be compared to:
1. The increase in the Consumer Price Index plus 5%;
2. The Ninety-day Treasury Bill Index plus 5%;
3. Nationally recognized indices measuring performance of the classes specified in the target asset
mix.
Comparisons will show risk and return performance statistics for the latest quarter, year-to-date, 3 years, 5
years, 10 years and since inception. The report will be prepared by the Investment Consultant and will be
presented to the Finance Committee.
Notes and History for this Investment Policy Statement
This policy was originally adopted by the AHIA’s Board of Directors on ___________ and revised thereafter.
This revised version of the policy was adopted by the AHIA’s on ______________.
Adoption of this Investment Policy Statement for the Association is acknowledged by:
Executive Director, Association of Healthcare Auditors
Date
Page 11