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HomeMy WebLinkAboutR21-044 ColoTrust Investment Partnership DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 Commissioner Chandler-Henry moved adoption of the following resolution: EAGLE COUNTY HOUSING AND DEVELOPMENT AUTHORITY COUNTY OF EAGLE, STATE OF COLORADO RESOLUTION NO. 2021-044 RESOLUTION AUTHORIZING THE EAGLE COUNTY HOUSING AND DEVELOPMENT AUTHORITY TO JOIN WITH OTHER GOVERNMENT ENTITIES AS A PARTICIPANT IN THE COLORADO LOCAL GOVERNMENT LIQUID ASSET TRUST(THE TRUST)TO POOL FUNDS FOR INVESTMENT WHEREAS,pursuant to Part 7 of Article 75 of Title 24 of the Colorado Revised Statutes, it is lawful for any local government entity to pool any monies in its treasury that are not immediately required to be disbursed with the same such monies in the treasury of any other local government entity in order to take advantage of short-term investments and maximize net interest earnings; and WHEREAS, the Trust is a statutory trust formed under the laws of the state of Colorado in accordance with the provisions of Parts 6 and 7, Article 24 and Articles 10.5 and 47 of Title 11 of the Colorado Revised Statutes regarding the investing, pooling for investment, and protection of public funds; and WHEREAS,Eagle County Housing and Development Authority desires to become a Participant in the Trust. NOW,THEREFORE, BE IT RESOLVED BY THE EAGLE COUNTY HOUSING AND DEVELOPMENT AUTHORITY OF THE COUNTY OF EAGLE, STATE OF COLORADO: THAT,Eagle County Housing and Development Authority hereby approves, adopts, and thereby joins as a Participant with other local governments pursuant to Part 7,Article 75,Title 24 of the Colorado Revised Statutes that certain Amended and Restated Indenture of Trust entitled the Colorado Liquid Government Asset Trust dated May 1, 2021 as amended from time to time, the terms of which are incorporated herein by this reference and a copy of which shall be filed with the minutes of the meeting at which this Resolution was adopted; and THAT,The Designee and Authorized Signatories are those persons listed on the Trust Registration Form attached hereto and incorporated herein.The Authorized Signatories are authorized by the Participant to direct the investment of such Participants' investment funds. THAT,The Designee and Authorized Signatories may be changed from time to time by written notice to COLOTRUST; and DocuSign Envelope ID.5E1CF77D-DFA1-455A-A6E9-157A1D3AAB41 THAT,The Trust currently has three investment portfolios: COLOTRUST PRIME, COLOTRUST PLUS+, and COLOTRUST EDGE. Details of the investment portfolios can be found in Exhibit A, which is incorporated herein by reference. Prior to investing in any of the portfolios offered by the Trust, Participants are encouraged to review the COLOTRUST Information Statements and Investment Policies for each portfolio. THAT,the Board hereby finds, determines and declares that this Resolution is necessary for the health, safety, and welfare of the citizens of Eagle County. MOVED,READ,AND ADOPTED by the Board of the Eagle County Housing and Development Authority of the County of Eagle, State of Colorado, at its regular meeting held this 13th day of July, 2021. CF EAGler EAGLE COUNTY HOUSING AND 4r °° EVELOPMENT AUTHORITY ATTEST: —DocuSigned by: • e—DocuSigned by: C 0 p' �� BY: �ttbtA 0-1fQjVtun toRAv By: S' clarr 9D6 2468 0. e�F7gapz gE0473... Clerk to the�oar�`of jw/jj�ajjj[ Jl:I1CCf County Commissioners Chair —DocuSigned by: By: L � rthx— 1'£ t hrer-Henry Commissioner By: CDocuSigned by: V7 s Jeanne Mcyueeney Commissioner Commissioner McQueeney seconded adoption of the foregoing resolution. The roll having been called,the vote was as follows: Aye Commissioner Chandler-Henry Commissioner McQueeney Aye Commissioner Scherr Aye This Resolution passed by 3/0 vote of the Board of the Eagle County Housing and Development Authority of the County of Eagle, State of Colorado. 2 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 EXHIBIT A COLO Trust Investment Policies 3 DocuSign Envelope ID:5E1CF77D-DFA1-455A-A6E9-157A1D3AAB41 .., COLO Investment Policies Effective May 1, 2021 Colorado Local Government Liquid Asset Trust 4 DocuSign Envelope ID:5E1CF77D-DFA1-455A-A6E9-157A1D3AAB41 COLD TRUST Introduction to COLOTRUST Investment Policies COLOTRUST is a statutory trust organized and existing under the laws of the state of Colorado in accordance with the provisions of the Investment Funds Local Government Pooling Act(Part 7,Article 75,Title 24, C.R.S.), the Funds Legal Investments Act(Part 6,Article 75,Title 24, C.R.S.), and the Public Deposit Protection Act (Articles 10.5 and 47 of Title 11, C.R.S.). COLOTRUST is registered with the Securities Commissioner of the State of Colorado as required by the Local Government Investment Pool Trust Fund Administration and Enforcement Act(Part 9,Article 51,Title 11, C.R.S.) COLOTRUST currently offers three portfolios, COLOTRUST PRIME, COLOTRUST PLUS+ and COLOTRUST EDGE. COLOTRUST provides a professionally managed investment program for local governments. The general objectives of COLOTRUST PRIME and COLOTRUST PLUS+ are to generate a high level of investment income for the Participants while maintaining liquidity and preserving capital by Investing only in investments authorized by the Statutes. COLOTRUST EDGE Is designed to complement the daily liquidity offered by COLOTRUST PRIME and COLOTRUST PLUS+.The general objective of EDGE is to seek to generate a high level of income for Participants while preserving capital by investing only in investments authorized by the Statutes. EDGE offers longer dated, fixed-income investments seeking to enhance returns while providing intermediate liquidity to its participants. EDGE is intended to be a longer-term investment and in contrast to COLOTRUST PRIME and PLUS+ is not suitable for daily liquidity needs. No assurance can be given that COLOTRUST will achieve its investment objective or that any benefits described in the information statements will result from the investment of moneys in COLOTRUST. COLOTRUST is specifically designed for Colorado local governments.Accordingly,COLOTRUST has limited its portfolios by investing only in instruments permitted under the Legal Investments Act (Permitted Investments). The COLOTRUST Board of Trustees maintains investment policies for COLOTRUST that are, by nature, more restrictive than the Legal Investments Act. Participants receive 30 days prior notice of any changes in the investment policies. 2 5 DocuSign Envelope ID.5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 Gal© TRUST PRIME Investment Policy This Investment Policy restricts the COLOTRUST PRIME portfolio to the following: Any security issued by, fully guaranteed guaranteed fixed-rate investment is by,or for which the full credit of the United 13 months(397 days). States Treasury is pledged for payment: . The maximum final maturity per • The maximum final maturity per U.S. government related/ fixed United States Treasury guaranteed floating rate investment investment is 13 months (397 is two years(762 days). days). Repurchase agreements and tri-party • The maximum final maturity per repurchase agreements with member floating United States Treasury banks of the Federal Reserve System investment is two years(762 days). and/or dealers in U.S. Government Securities in accordance with C.R.S.24-75- Any security issued by, fully guaranteed 601.1. by, or for which the full credit of the following is pledged for payment: The A Master Repurchase Agreement (e.g. The Federal Farm Credit Bank,the Federal Land Bond Market Association standard Bank, a Federal Home Loan Bank, the agreement, 1996 version) and applicable Federal Home Loan Mortgage Corporation, COLOTRUST annexes must be signed by all the Federal National Mortgage Association, parties and on file prior to executing any the Export-Import Bank, the Tennessee transaction. Valley Authority,the Government National Mortgage Association, the World Bank, or Tri party repurchase agreements are an entity/organization that is not listed in permissible with COLOTRUST Board this paragraph but that is created by,or the approved counterparties and third party creation of which is authorized by, custodians (acting for both the party and legislation enacted by the United States the counterparty). These third party Congress and that is subject to control by custodians are not permitted to hold the Federal government that is at least as deposits for COLOTRUST and are therefore extensive as that which governs an entity not required to meet the Colorado PDPA or organization listed in this paragraph. No requirements. subordinated security may be purchased Written tri-party custodian agreements (in pursuant to this paragraph. addition to The Bond Market Association The maximum exposure per U.S. 1996 standard repurchase agreement) • government related/guaranteed must be signed by all parties and on file issuer is 33%. prior to executing any transaction. Collateral (purchased securities) shall be • The maximum final maturity per limited to the following and shall be U.S. government related/ indicated as such on Schedule 1'Schedule of Eligible Securities' of the tri-party 3 6 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 OLO TRUST^ custodian agreement: U.S. Treasuries various counterparties; that accepted (bills, bonds, notes, strips), Federal practice in the industry allows minor National Mortgage Association (FNMA), deviations from strict application of Federal Home Loan Banks(FHLB), Federal margins; and that there is a cost of Home Loan Mortgage Corporation changing collateral securing repurchase (FHLMC), Federal Farm Credit Banks agreements. For those reasons, the (FFCB), GNMA I/II Single Family, GNMA portfolio manager may use discretion I/II Others-Fixed Rate, GNMA I/II Others, before directing that a counterparty supply Adjust Rate and Agency Mortgage Backed additional purchased securities until such (Pass-Through Fixed Rate and Pass- time as the margin falls below 101.5%. If Through Adjustable Rate). the aggregate collateral level of the Term repurchase agreements (TRA) are counterparty falls below 101.5%, the portfolio manager shall notify the considered eligible investments under the counterparty to provide sufficient following conditions: additional securities to restore the margin • For TRAs between two and five to at least 102%. The portfolio manager business days, a maximum of 10% will require additional collateral to return of the portfolio with any one dealer. the margin to at least 102% on the next business day. • For TRAs with maturities of more Any deposit that meets the requirements in than five business days, a the Public Deposit Protection Act under CRS maximum of 5% of the portfolio. 11-10.5-107,et seq. • TRAs shall not exceed 30 calendar Any money market fund that is registered days. as an investment company under the Federal Investment Company Act of 1940, • TRAs shall fulfill all requirements of as amended if, at the time COLOTRUST the 1996 version of The Bond invests in such fund: Market Association master • The investment policies of the fund repurchase agreement. include seeking to maintain a The Repurchase Agreements between constant share price; COLOTRUST and the various approved counterparties require that the aggregate • No sales or load fee is added to the market value of all purchased securities purchase price or deducted from the from any particular counterparty be at least redemption price of the investment; 102% (the margin) of the aggregate purchase price of the purchased securities. • The investments of the fund consist only of securities with a maximum The Board recognizes that market remaining maturity as specified in fluctuations constantly increase or Rule 2a-7 under the Federal decrease the value of securities;that there Investment Company Act of 1940, is value in maintaining ongoing, positive as amended or any successor relationships between COLOTRUST and the 4 7 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 COLO TRUST regulation under such act regulating Adopted April 22,1985 money market funds, so long as Revised October16,1992 such Rule 2a-7 is not amended to or Revised February 19,1999 such successor regulation does not Revised May 5,2000 increase the maximum remaining maturity of such securities to a Revised October 3,2003 period that is greater than three Revised December 3,2004 years and if the fund has assets of Revised August 7,2009 one billion dollars or more or has Revised September 8,2011 the highest current credit rating from one or more NRSRO; Revised August 10,2012 Revised January 1,2016 • The dollar-weighted average Revised January 1,2018 portfolio maturity of the fund meets Revised February 6,2020 the requirements specified in Rule Revised March 5,2021 2a-7 under the Federal Investment Company Act of 1940, as amended or any successor regulation under such act regulating money market funds, so long as such Rule 2a-7 is not amended to increase the dollar weighted average portfolio maturity of a fund to a period greater than one hundred eighty days. • No more than 10% of the portfolio may be invested in any single AAAm rated money market fund that meets the above criteria. 5 8 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 CO TRUST PLUS+ Investment Policy This Investment Policy restricts the COLOTRUST PLUS+ portfolio to the following: Any security issued by, fully guaranteed • The maximum exposure per U.S. by,or for which the full credit of the United government related/guaranteed States Treasury is pledged for payment: issuer is 33%. • The maximum final maturity per • The maximum final maturity per fixed United States Treasury U.S. government related/ investment Is 13 months (397 guaranteed fixed-rate investment is days). 13 months (397 days). • The maximum final maturity per floating United States Treasury • The maximum final maturity per investment is two years(762 days). U.S. government related/ guaranteed floating rate investment No more than 10% of the portfolio is two years(762 days). • may be invested in any single AAAm Repurchase agreements and tri-party rated money market fund that repurchase agreements with member meets the above criteria. banks of the Federal Reserve System Any security issued by, fully guaranteed and/or dealers in U.S. Government by, or for which the full credit of the Securities in accordance with C.R.S.24-75- following is pledged for payment: The 601.1. Federal Farm Credit Bank,the Federal Land A Master Repurchase Agreement(e.g. The Bank, a Federal Home Loan Bank, the Bond Market Association standard Federal Home Loan Mortgage Corporation, agreement, 1996 version) and applicable the Federal National Mortgage Association, COLOTRUST annexes must be signed by all the Export-Import Bank, the Tennessee parties and on file prior to executing any Valley Authority,the Government National transaction. Mortgage Association, the World Bank, or an entity/organization that is not listed in Tri party repurchase agreements are this paragraph but is created by, or the permissible with COLOTRUST Board creation of which is authorized by, approved counterparties and third-party legislation enacted by the United States custodians (acting for both the party and Congress and that is subject to control by the counterparty). These third party the Federal government that is at least as custodians are not permitted to hold extensive as that which governs an entity deposits for COLOTRUST and are therefore or organization listed in this paragraph. No not required to meet the Colorado PDPA subordinated security may be purchased requirements. pursuant to this paragraph. Written Tri-party custodian agreements(in addition to The Bond Market Association 1996 standard repurchase agreement) 6 9 DocuSign Envelope ID:5E1CF77D-DFA1-455A-A6E9-157A1 D3AAB41 G0i0 TRUST must be signed by all parties and on file 102% (the margin) of the aggregate prior to executing any transaction. purchase price of the purchased securities. Collateral (purchased securities) shall be The Board recognizes that market limited to the following and shall be fluctuations constantly increase or indicated as such on Schedule 1'Schedule decrease the value of securities;that there of Eligible Securities' of the Trkparty is value in maintaining ongoing positive custodian agreement: U.S. Treasuries relationships between COLOTRUST and the (bills, bonds, notes, strips), Federal various counterparties; that the accepted National Mortgage Association (FNMA), practice in the industry allows minor Federal Home Loan Banks(FHLB), Federal deviations from strict application of Home Loan Mortgage Corporation margins; and that there is a cost of (FHLMC), Federal Farm Credit Banks changing collateral securing repurchase (FFCB), GNMA I/II Single Family, GNMA agreements. For those reasons, the I/II Others-Fixed Rate, GNMA I/II Others, portfolio manager may use discretion Adjust Rate and Agency Mortgage Backed before directing that a counterparty supply (Pass-Through Fixed Rate and Pass- additional purchased securities until such Through Adjustable Rate). time as the margin falls below 101.5%. If the aggregate collateral level of the Term repurchase agreements (TRA) are counterparty falls below 101.5%, the considered eligible investments under the following conditions: portfolio manager shall notify the counterparty to provide sufficient • For TRAs between two and five additional securities to restore the margin business days, a maximum of 10% to at least 102%. The portfolio manager of the portfolio with any one dealer. will require additional collateral to return the margin to at least 102% on the next • For TRAs with maturities of more business day. than five business days, a Any security that is a general or revenue maximum of 5% of the portfolio. obligation of any state of the United States, the District of Columbia, any territorial • TRAs shall not exceed 30 calendar possession of the United States, or of any days. political subdivision, institution, department, agency, instrumentality, or • TRAs shall fulfill all requirements of authority of any of such governmental the 1996 version of The Bond entities. At the time of purchase, the Market Association master security must be rated in one of its two repurchase agreement. highest rating categories by two or more The Repurchase Agreements between NRSROs that regularly rate such COLOTRUST and the various approved obligations. counterparties require that the aggregate • The maximum exposure per market value of all purchased securities municipal issuer is 5%. from any particular counterparty beat least 7 10 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 CO{:O TRUST • The maximum final maturity per • No more than 5% of the portfolio municipal investment is 13 months may be invested in any single (397 days). commercial paper issuer. • The portfolio may not own over 5% Any corporate or bank security of any issuer's total commercial denominated in United States dollars that, paper program at the time of at the time of purchase,carries at least two purchase. credit ratings from any of the NRSROs that • Any deposit that meets the is not rated below 1) Al, P1, or Fl if the security is a money market instrument or requirements in the Public Deposit 2) AA- or Aa3 or their equivalents if it is Protection Act under CR5 11 10.5 any other kind of security. These rating 107,et seq. requirements first apply to the security Any money market fund that is registered being purchased, and then, if the security as an investment company under the itself is unrated,to the issuer provided that Federal Investment Company Act of 1940, the security contains no provisions as amended if, at the time COLOTRUST subordinating it from being a senior debt invests in such fund: obligation of the issuer. • The investment policies of the fund • The maximum exposure per include seeking to maintain a corporate or bank security issuer is constant share price; 5%. • No sales or load fee is added to the • The maximum final maturity per purchase price or deducted from the corporate or bank security fixed or redemption price of the investment; Floating rate investment is 13 months(397 days). • The investments of the fund consist Commercial paper or bankers'acceptances only of securities with a maximum denominated in United States dollars that, remaining maturity as specified in at the time of purchase,carry at least two Rule 2a-7 under the Federal credit ratings from any of the NRSROs and Investment Company Act of 1940, are not rated below A-1, P-1,or F-1. as amended or any successor regulation under such act regulating An Approved Commercial Paper List will be money market funds, so long as maintained by the investment advisor such Rule 2a-7 is not amended to or designating those commercial paper names such successor regulation does not that are eligible for investment by increase the maximum remaining COLOTRUST PLUS+.All additions to this list maturity of such securities to a must be approved by the Board of period that is greater than three Trustees. years,and if the fund has assets of At the time commercial paper is purchased: one billion dollars or more or has the highest current credit rating 8 11 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 COLO;. TROST from one or more NRSRO; Adopted November 10,1994 Revised February 19,1999 • The dollar weighted average Revised May 7,1999 portfolio maturity of the fund meets the requirements specified in Rule Revised November 5,1999 2a-7 under the Federal Investment Revised May 5,2000 Company Act of 1940, as amended Revised October 3,2003 or any successor regulation under Revised December 3,2004 such act regulating money market Revised August 7,2009 funds so long as such Rule 2a-7 is not amended to increase the dollar Revised September 8,2011 weighted average portfolio maturity Revised August 10,2012 of a fund to a period greater than Revised January 1,2016 one hundred eighty days. Revised January 1,2018 Revised February 6,2020 • No more than 10% of the portfolio may be invested in any single AAAm Revised August 6,2020 rated money market fund that Revised March 5,2021 meets the above criteria. 9 12 DocuSign Envelope ID:5E1CF77D-DFA1-455A-A6E9-157A1D3AAB41 CM° TRUST EDGE Investment Policy This Investment Policy restricts the COLOTRUST EDGE portfolio to the following: Any security issued by, fully guaranteed and/or dealers in U.S. Government by,or for which the full credit of the United Securities in accordance with C.R.S.24-75- States Treasury is pledged for payment: 601.1. • The maximum final maturity per A Master Repurchase Agreement(e.g. The fixed and floating United States Bond Market Association standard Treasury investment is 5 years from agreement, 1996 version) and applicable the date of trade settlement. COLOTRUST annexes must be signed by all Any security issued by, fully guaranteed parties and on file prior to executing any transaction. by, or for which the full credit of the following is pledged for payment: The Tri-party repurchase agreements are Federal Farm Credit Bank,the Federal Land permissible with COLOTRUST Board Bank, a Federal Home Loan Bank, the approved counterparties and third-party Federal Home Loan Mortgage Corporation, custodians (acting for both the party and the Federal National Mortgage Association, the counterparty). These third-party the Export-Import Bank, the Tennessee custodians are not permitted to hold Valley Authority,the Government National deposits for COLOTRUST and are therefore Mortgage Association, the World Bank, or not required to meet the Colorado PDPA an entity/organization that is not listed in requirements. this paragraph but is created by, or the creation of which is authorized by, Written Tri-party custodian agreements(in legislation enacted by the United States addition to The Bond Market Association 1996 standard repurchase agreement) Congress and that is subject to control by must be signed by all parties and on file the Federal government that is at least as extensive as that which governs an entity prior to executing any transaction. or organization listed in this paragraph. No Collateral (purchased securities) shall be subordinated security may be purchased limited to the following and shall be pursuant to this paragraph, indicated as such on Schedule 1'Schedule The maximum final maturity per of Eligible Securities' of the Tri-party • U.S. government related/ custodian agreement: U.S. Treasuries guaranteed fixed or floating-rate (bills, bonds, notes, strips), Federal investment is 5 years from the date National Mortgage Association (FNMA), of trade settlement. Federal Home Loan Banks(FHLB), Federal Home Loan Mortgage Corporation Repurchase agreements and tri-party (FHLMC), Federal Farm Credit Banks repurchase agreements with member (FFCB), GNMA I/II Single Family, GNMA banks of the Federal Reserve System I/II Others-Fixed Rate, GNMA I/II Others, Adjust Rate and Agency Mortgage Backed 10 13 DocuSign Envelope ID:5E1CF77D-DFA1-455A-A6E9-157A1D3AAB41 COLO,, TRUS (Pass-Through Fixed Rate and Pass- to at least 102%. The portfolio manager Through Adjustable Rate). The collateral will require additional collateral to return subject to the repurchase agreement may the margin to at least 1020/0 on the next have a maturity in excess of five years. business day. Term repurchase agreements (TRA) are Any security that is a general or revenue considered eligible investments under the obligation of any state of the United States, following conditions: the District of Columbia, any territorial TRAs shall not exceed 5 years from possession of the United States, or of any • the date of trade settlement. political subdivision, institution, department, agency, instrumentality, or • TRAs shall fulfill all requirements of authority of any of such governmental the 1996 version of The Bond entities. At the time of purchase, the security must be rated in one of its two Market Association master highest rating categories by two or more repurchase agreement. NRSROs that regularly rate such The Repurchase Agreements between obligations. COLOTRUST and the various approved counterparties require that the aggregate • The maximum final maturity per market value of all purchased securities municipal investment is 5 years from any particular counterparty be at least from the date of trade settlement. 102% (the margin) of the aggregate purchase price of the purchased securities. Any corporate or bank security The Board recognizes that market denominated in United States dollars that, fluctuations constantly increase or at the time of purchase,carries at least two decrease the value of securities; that there credit ratings from any of the NRSROs that is value in maintaining ongoing positive is not rated below 1) Al, P1, or Fl if the relationships between COLOTRUST and the security is a money market instrument or various counterparties; that the accepted 2) AA- or Aa3 or their equivalents if it is practice in the industry allows minor any other kind of security. These rating deviations from strict application of requirements first apply to the security margins; and that there is a cost of being purchased, and then, if the security changing collateral securing repurchase itself is unrated,to the issuer provided that agreements. For those reasons, the the security contains no provisions portfolio manager may use discretion subordinating it from being a senior debt before directing that a counterparty supply obligation of the issuer. additional purchased securities until such time as the margin falls below 101.5%. If • The maximum final maturity per the aggregate collateral level of the corporate or bank security fixed or counterparty falls below 101.5%, the floating rate investment is 3 years portfolio manager shall notify the from the date of trade settlement. counterparty to provide sufficient Commercial paper or bankers'acceptances additional securities to restore the margin denominated in United States dollars that, 11 14 DocuSign Envelope ID:5E1 CF77D-DFA1-455A-A6E9-157A1 D3AAB41 TRUST at the time of purchase, carry at least two as amended or any successor credit ratings from any of the NRSROs and regulation under such act regulating are not rated below A-1, P-1, or F-1. money market funds, so long as An Approved Commercial Paper List will be such Rule 2a-7 is not amended to or such successor regulation does not maintained by the investment advisor increase the maximum remaining designating those commercial paper names that are eligible for investment by maturity of such securities to a COLOTRUST EDGE. All additions to this list period that is greater than three must be approved by the Board of years,and if the fund has assets of Trustees. one billion dollars or more or has the highest current credit rating At the time commercial paper is purchased: from one or more NRSRO; • The portfolio may not own over 5% • The dollar weighted average of any issuer's total commercial portfolio maturity of the fund meets paper program at the time of the requirements specified in Rule purchase. 2a-7 under the Federal Investment • Any deposit that meets the Company Act of 1940, as amended requirements in the Public Deposit or any successor regulation under Protection Act under CRS 11-10.5- such act regulating money market 107,et seq. funds so long as such Rule 2a-7 is Any interest in any local government not amended to increase the dollar investment pool organized pursuant to the weighted average portfolio maturity Local Government Pooling Act. of a fund to a period greater than one hundred eighty days. Any money market fund that is registered as an investment company under the Federal Investment Company Act of 1940, Adopted March 5,2021 as amended if, at the time COLOTRUST invests in such fund: Contact Information • The investment policies of the fund 717 17th Street,Suite 1850 include seeking to maintain a constant share price; Denver, CO 80202 • No sales or load fee is added to the Phone: (877) 311-0219 purchase price or deducted from the Fax: (877)311-0220 redemption price of the investment; cl ientservicesftcoiotrust.com • The investments of the fund consist www.colotrust.com only of securities with a maximum remaining maturity as specified in COLO Rule 2a-7 under the Federal usT Investment Company Act of 1940, 12 15