Investment Policy

Creative Housing, Inc.

Statement of Investment Policy, Objectives, and Guidelines

August, 2024

TABLE OF CONTENTS

IGeneral Information

  1. Scope of Investment Policy 3
  2. Purpose of Investment Policy 3
  3. Definitions 3
  4. Delegation of Authority 4

IIAssignment of Responsibility

  1. The Board of Directors 4
  • Responsibility of the Investment Consultant(s) 5
  • Responsibility of the Investment Manager(s) 5

IIIGeneral Investment Principles

  1. General Guidelines 6

B. Investment Management Policy 6

IVSpending Policy

  • Spending Rate7

VInvestment Objectives

  1. Goal of Foundation 7
  2. Capital Market Expectations 7

C. Volatility of Returns 8

D. Liquidity 8

VIInvestment Guidelines

  1. Allowable Assets 8
  • Stock Exchanges 9
  • Prohibited Assets 9

VIIAsset Allocation Guidelines

  • Aggregate Account Allocation 9
  • Diversification for Investment Managers 9
  • Guidelines for Fixed Income Managers10

VIIISelection of Investment Managers

  1. Procedures10
  2. Investment Manager Review/Evaluation10

IXInvestment Policy Review11

Statement of Investment Policy, Objectives, and Guidelines

Creative Housing, Inc.

  1. GENERAL INFORMATION
  2. Scope of This Investment Policy

This statement of investment policy reflects the investment policy, objectives, and constraints of Creative Housing, Inc.

  1. Purpose of This Investment Policy

This statement of investment policy is set forth by the Board of Directors of Creative Housing, Inc. in order to:

  1. Define and assign the responsibilities of all involved parties.
  2. Establish a clear understanding for all involved parties of the investment goals and objectives of Fund reserve assets.
  3. Offer guidance and limitations to all Investment Managers regarding the investment of Fund assets.
  4. Establish a basis for evaluating investment results.
  5. Manage Fund assets according to prudent standards as established in common trust law and the Uniform Prudent Investors Act.
  6. Establish the relevant investment horizon for which the Fund assets will be managed.

In general, the purpose of this statement is to outline a philosophy and attitude that will guide the investment management of the assets toward the desired results. It is intended to be sufficiently specific to be meaningful, yet flexible enough to be practical.

  1. Definitions
  2. “Fund” shall mean Creative Housing, Inc.
  3. “The Board of Directors” shall refer to the governing board established to administer the Fund as specified by applicable ordinance.
  4. “Fiduciary” shall mean any individual or group of individuals that exercise discretionary authority or control over fund management or any authority or control over management, disposition or administration of the Fund assets.
  5. “Investment Manager” shall mean any individual, or group of individuals, employed to manage the investments of all or part of the fund assets.
  6. “Investment Management Consultant” shall mean any individual or organization employed to provide advisory services, including advice on investment objectives and/or asset allocation, manager search, and performance monitoring.
  7. “Securities” shall refer to the marketable investment securities that are defined as acceptable in this statement.
  8.  “Investment Horizon” shall be the time period over which the investment objectives, as set forth in this statement, are expected to be met. The investment horizon for this Fund is five years.
  9. Delegation of Authority

The Fiduciary is responsible for directing and monitoring the investment management of Account assets. As such, the Fiduciary is authorized to delegate certain responsibilities to professional experts in various fields. These include, but are not limited to:

  1. Investment Management Consultant. The consultant may assist the Fiduciary in: establishing investment policy, objectives, and guidelines; selecting investment managers; reviewing such managers over time; measuring and evaluating investment performance; and other tasks as deemed appropriate.
  2. Investment Manager. The investment manager may choose the specific securities that will be used to meet the Fund’s investment objectives. Such services also include economic analysis, and deciding when to purchase, sell, or hold individual securities.

The Fiduciary will not reserve any control over investment decisions, with the exception of specific limitations described in these statements. Managers will be held responsible and accountable to achieve the objectives herein stated. While it is not believed that the limitations will hamper investment managers, each manager should request modifications that they deem appropriate.

If such experts employed are also deemed to be fiduciaries, they must acknowledge such in writing. All expenses for such experts must be customary and reasonable, and will be borne by the Account as deemed appropriate and necessary.

  1. Assignment of Responsibility
  2. Board of Directors

The Board of Directors is charged by law with the responsibility for the management of the assets of the Fund. The Board of Directors shall discharge its duties solely in the interest of the Fund, with the care, skill, prudence and diligence under the circumstances then prevailing, that a prudent man, acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character with like aims. The specific responsibilities of the Board of Directors relating to the investment management of Fund assets include:

  1. Projecting the Fund’s financial needs and communicating such needs to the Investment Managers on a timely basis.
  2. Determining the Fund’s risk tolerance and investment horizon, and communicating these to the appropriate parties.
  3. Establishing reasonable and consistent investment objectives, policies and guidelines that will direct the investment of the Fund’s assets.
  4. Prudently and diligently selecting qualified investment professionals, including Investment Manager(s) and Investment Consultant(s).
  5. Regularly evaluating the performance of the Investment Manager(s) to assure adherence to policy guidelines and monitor investment objective progress.
  6. Developing and enacting proper control procedures (e.g., replacing Investment Manager(s) due to fundamental change in investment management process, or failure to comply with established guidelines).
  1. Responsibility of Investment Consultant(s)

The Investment Consultant’s role is that of a non-discretionary advisor to the Board of Directors of Creative Housing, Inc. Investment advice concerning the investment management of Fund assets will be offered by the Investment Consultant, and will be consistent with the investment objectives, policies, guidelines and constraints as established in this statement. Specific responsibilities of the Investment Consultant include:

  1. Assisting in the development and periodic review of investment policy.
  2. Conducting investment manager searches when requested by the Board of Directors.
  3. Providing “due diligence”, or research, on the Investment Manager(s).
  4. Monitoring the performance of the Investment Manager(s) to provide the Board of Directors with the ability to determine the progress toward the investment objectives.
  5. Communicating matters of policy, manager research, and manager performance to the Board of Directors.
  6. Reviewing Fund investment history, historical capital markets performance and the contents of this investment policy statement to any newly appointed members of the Board of Directors.
  1. Responsibility of Investment Manager(s)

Each Investment Manager must acknowledge in writing its acceptance of responsibility as a fiduciary. Each Investment Manager will have full discretion to make all investment decisions for the assets placed under its jurisdiction, while observing and operating within all policies, guidelines, constraints, and philosophies as outlined in this statement. Specific responsibilities of the Investment Manager(s) include:

  1. Discretionary investment management including decisions to buy, sell, or hold individual securities, and to alter asset allocation within the guidelines established in this statement.
  2. Reporting, on a timely basis, quarterly investment performance results.
  3. Communicating any major changes to economic outlook, investment strategy, or any other factors that affect implementation of investment process, or the investment objective progress of the Fund’s investment management.
  4. Informing the Board of Directors regarding any qualitative change to investment management organization (e.g., changes in portfolio management personnel, ownership structure, investment philosophy, etc.).
  5. Voting proxies, if requested by the Board of Directors, on behalf of the Fund, and communicating such voting records to the Board of Directors on a timely basis.

III.GENERAL INVESTMENT PRINCIPLES

  1. General Guidelines
  2. The Fund shall be invested with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent man acting in like capacity and familiar with such matters would use in the investment of a fund of like character and with like aims.
  3. Investment of the Fund shall be diversified through different asset classes to minimize risk, unless under certain circumstances it is clearly prudent not to do so.
  4. The Board of Directors may employ one or more investment managers of varying styles and philosophies to attain the Fund’s objectives.
  5. Cash is to be employed productively at all times, by investment in short-term cash equivalents to provide safety, liquidity, and return.
  6. Investment Management Policy
  7. Preservation of Capital – Consistent with their respective investment styles and philosophies, investment managers should make reasonable efforts to preserve capital, understanding that losses may occur in individual securities.
  8. Risk Aversion – Understanding that risk is present in all types of securities and investment styles, the Board of Directors recognizes that some risk is necessary to produce long-term investment results that are sufficient to meet the Fund’s objectives. However, the investment managers are to make reasonable efforts to control risk, and will be evaluated regularly to ensure that the risk assumed is commensurate with the given investment style and objectives.
  9. Adherence to Investment Discipline – Investment managers are expected to adhere to the investment management styles for which they were hired. Managers will be evaluated regularly for adherence to investment discipline.
  1. SPENDING POLICY

The Board of Directors will attempt to design a spending policy that is flexible. Since expected investment returns from “riskier” portfolios are not consistent and predictable, the Board of Directors seeks to achieve a balanced return of income and modest growth of principal. Risk control is an important element in the investment of the Fund’s assets, as is liquidity.

  1. Spending Rate 

The historical spending rate for Creative Housing, Inc. has been for infrequent capital expenditures; this should continue. There will be more frequent expenditures for asset replacement issues in the future.

  • INVESTMENT OBJECTIVES
  1. Goal 

The overriding objective of this investment is to prudently invest the Fund’s reserve monies. The Board of Directors has set an investment strategy with the objective of achieving a balanced return of income and modest growth of principal. Specific investment objectives will be established later in this document.

  1. Capital Market Expectations

The specific investment goals below are based on the following expectations of return from the capital markets:

Asset ClassExpected Return
Large Cap Equity9.0%
Small Cap Equity9.2%
International Equity9.0%
Intermediate Domestic BondsInternational Bonds5.0%5.5%
Low Absolute Return Funds6.0%
90 Day Treasury Bills2.0%
CPI3.0%

Expected return calculations for capital markets indices are based on historical annualized performance, with the exception of the international indices. The expected returns of the international indices represent a return premium approach. This premium estimate is calculated comparing each international index against its domestic counterpart, since the inception of the international indexes.

  1. Volatility of Returns

It is anticipated that the aggregate Fund has a 95% probability, over a 5-year time horizon, of achieving returns ranging from .27% to 18.23%.

It is anticipated that the aggregate Fund has a 95% probability, during any single one-year period, of achieving returns ranging from –10.0% to 32.1%.

  1. Liquidity

To minimize the possibility of a loss occasioned by the sale of a security forced by the need to meet a required payment, the Board of Directors will periodically provide investment counsel with an estimate of expected net cash flow. The Board of Directors will notify the investment consultant in a timely manner, to allow sufficient time to build up necessary liquid reserves.

  1. INVESTMENT GUIDELINES
  1. Allowable Assets
  2. Cash Equivalents
  • Treasury Bills, Commercial Paper, CD’s, Bankers’ Acceptance Notes
  • Money Market Funds
  • Repurchase Agreements
  1. Fixed Income Securities
  • U.S. Government and Agency Securities
  • Corporate Notes and Bonds
  • Mortgage Backed Bonds
  • Preferred Stock
  • Fixed Income Securities of Foreign Governments and Corporations
  1. Equity Securities
  • Common Stocks
  • Convertible Notes and Bonds
  • Convertible Preferred Stocks
  • American Depository Receipts (ADRs) of Non-U.S. Companies
  • Stocks of Non-U.S. Companies (Ordinary Shares)
  • Stocks of Non-U.S. Companies in emerging markets
  1. Mutual Funds

Mutual Funds which invest in securities as allowed in this statement.

  1. Other Assets
  • Alternatives
  • Real Estate Investment Trusts (REITs)
  • Commodities
  1. Stock Exchanges

To ensure marketability and liquidity, with the exception of absolute return managers, investment advisors will execute equity transactions through the following exchanges: New York Stock Exchange; American Stock Exchange; NASDAQ; over-the-counter market and foreign exchange markets. In the event that an Investment Manager determines that there is a benefit or a need to execute transactions in exchanges other than those listed in this statement, written approval is required from the Board of Directors.

  1. C. Prohibited Assets

Prohibited investments include, but are not limited to the following:

  1. Private Placements
  2. Venture-Capital Placements
  3. Individual Real Estate Properties
  4. Managed Futures

VII.ASSET ALLOCATION GUIDELINES

  1. Aggregate Account Allocation

To achieve its investment objective, assets are considered as divided into three asset classes: absolute return assets, equity, and fixed income. The target allocations, or long-term commitments, to these broad asset classes are established at a target ratio as shown below. The ranges within which the allocations will be allowed to vary from their respective targets are also shown below:

  1. Aggregate Fund Asset Allocation Guidelines (at market value)
Asset ClassMinimumMaximumPreferred
Cash and Equivalents0%100%0%
Alternatives0%30%15%
Fixed Income0%100%35%
Equity0%75%50%
  1. The Board of Directors may employ investment managers whose investment disciplines require investment outside the established asset allocation guidelines. However, taken as a component of the aggregate Fund, such disciplines must fit within the overall asset allocation guidelines established in this statement.
  2. Diversification For Investment Managers

The Board of Directors does not believe it is necessary that securities held in the Fund represent a cross section of the economy. However, in order to achieve a prudent level of portfolio diversification, the securities of any one company or government agency should not constitute an unusually heavy weighting within the portfolio.

  1. Guidelines For Fixed Income Managers
  2. The Fund’s bond portfolio should have an average A rating (or equivalent) or better.
  3. Fund assets may be invested in commercial paper at the manager’s discretion.
  4. Money Market Funds selected shall contain securities whose credit rating at the absolute minimum would be rated investment grade by Standard and Poors, and/or Moody’s.

VIII.SELECTION OF INVESTMENT MANAGERS

  1. Procedures

The Board of Directors’ selection of Investment Manager(s) must be based on prudent due diligence procedures. A qualifying investment manager must be a registered investment advisor under the Investment Advisors Act of 1940, or a bank or insurance company. The Investment Committee of the Board of Directors requires that each investment manager provide, in writing, acknowledgment of fiduciary responsibility.

  1. Investment Manager Review/Evaluation

Performance reports generated by the Investment Consultant shall be compiled at least quarterly and communicated to the Board of Directors for review. The investment performance of total portfolios, as well as asset class components, will be measured against commonly accepted performance benchmarks. Consideration shall be given to the extent to which the investment results are consistent with the investment objectives, goals, and guidelines as set forth in this statement. The Board of Directors intends to evaluate the portfolio(s) over at least a three-year period, but reserves the right to terminate a manager for any reason including the following:

  1. Investment performance which is significantly less than anticipated given the discipline employed and the risk parameters established, or unacceptable justification of poor results.
  2. Failure to adhere to any aspect of this statement of investment policy, including communication and reporting requirements.
  3. Significant qualitative changes to the investment management organization.

Investment managers shall be reviewed regularly regarding performance, personnel, strategy, research capabilities, organizational and business matters, and other qualitative factors that may impact their ability to achieve the desired investment results.

  1. INVESTMENT POLICY REVIEW

To assure continued relevance of the guidelines, objectives, financial status and capital markets expectations as established in this statement of investment policy, the Board of Directors plans to review investment policy at least annually.

This statement of investment policy is adopted on ____________, 2024, by the Board of Directors of Creative Housing, Inc., whose signatures appear below: