FRB Investment Suggestions

Proposed Amendment – Mandatory

Factor	Current	Proposed	Notes
Concentration limits	$250K per issuer/issue	Target a 5% issue and 10% issuer maximum based on the market value of the portfolio*	Percent allocations to better reflect the size of the portfolio as well as enhancing liquidity

Proposed Amendment – Optional

Factor	Current	Proposed	Notes
Average portfolio maturity	Maximum 2.5 years	“Target” of 2.5 years with a +/- 20% average maturity band	Allows slight over/ under vs. target to allow for market actions and opportunities
Credit ratings	Aa/AA minimum per security	Expand to include all ratings of investment grade-rated securities (Baa3/BBB- minimum)	~78% of the investment grade universe is rated in the “A” or “BBB” category thereby increasing available options as well as yield
Allowable sectors	U.S. Govt U.S. Agencies Corporates CDs Municipals (taxable) Money market funds	Maintain all plus add Asset-backed Securities (ABS)	Very similar to the structure and credit quality of Agency MBS, however, are secured by loan receivables from autos, credit cards, RVs, etc.

Current Investment Policy