黑料专区 Investment Requirements and Guidance
Ronald S. Flagg, President
May 12, 2023
Recent bank failures demand increased vigilance from 黑料专区's grantees to protect 黑料专区 (and non-黑料专区) funds on deposit with banking institutions, particularly deposits exceeding the $250,000 Federal Deposit Insurance Corporation (FDIC) limit. 黑料专区 strongly advises grantees to implement proactive safeguards in response to the 黑料专区 Office of Inspector General's (OIG) recent "" article, which urged grantees to comply with 黑料专区's banking and investment guidelines. Further, 黑料专区 reminds grantees of its investment requirements outlined in Section 2.3.3 of the 黑料专区 Financial Guide.
黑料专区 has long advised its grantees to protect 黑料专区 funds that exceed the FDIC's limit. Investment requirements are clearly stated in the 黑料专区 Financial Guide, and instruct grantees to:
- Maintain 黑料专区 funds held for operating expenses in federally insured bank accounts.
- Invest 黑料专区 funds exceeding the FDIC limit and not needed for immediate operating expenses with another financial institution in federally insured accounts or certificates or invest in U.S. Treasury notes or bills or investment instruments (e.g., money market accounts and repurchase agreements that invest in U.S. government securities).
The 黑料专区 Financial Guide acknowledges that the grantees' Board of Directors may adopt policies outside these requirements. In those cases, the Board must acknowledge, by resolution, the divergence from 黑料专区's official policy and accept full responsibility for the security of any investments made outside of 黑料专区's requirements. For purposes of personal liability, grantees' Board members will be held to the standard of care imposed by applicable state or federal law for any losses of 黑料专区 funds resulting from investment decisions may contrary to 黑料专区's requirements.
Grantees must maintain investment policies that explain their investment practices, either conforming to 黑料专区's requirements or electing alternative investment practices. The Financial Oversight Committee of the grantees' Board of Directors must "regularly review and make recommendations about investment policies" as part of its primary responsibilities.
黑料专区 is primarily concerned with how grantees are assessing and mitigating their financial risk in light of recent and potential banking instability and their compliance with 黑料专区's investment requirements. Considering these concerns, 黑料专区's Office of Compliance and Enforcement (OCE) will offer two online office hours sessions during which 黑料专区 Financial Compliance Analysts (FCAs) will be available to answer grantee questions about 黑料专区's investment requirements. Questions asked during the sessions may be added to the 黑料专区 Financial Guide Frequently Asked Questions, currently under development.
Office hours sessions will be conducted via Zoom on the following dates:
- Wednesday, May 17, 2023, 2:00 PM - 3:00 PM EDT; click for Zoom link.
- Tuesday, May 23, 2023, 2:00 PM - 3:00 PM EDT; click for Zoom link.
If grantees have additional questions after the sessions, they should contact their assigned FCA in OCE.