HomeMy WebLinkAbout2012 12 10 Consent 200 Pension Investment Policy
COMMISSION AGENDA
Informational
Consent
ITEM200
Public Hearings
Regular
X
December 10, 2012KSSB
Regular MeetingCity ManagerDepartment
REQUEST:
The City Manager, Finance and Administrative Services Department and Board of
Trustees requests that the City Commission: consider a change in the management
approach for the Domestic Equity Portfolio of the City's Pension Plan; approve a contract
with Capital Institutional Services, Inc. to facilitate the transition to the new investment
style; modify the pension investment policy to allow for the change in the investment
approach; and authorize the
City Manager and City Attorney to coordinate and execute any and
all documents needed to facilitate these transactions.
SYNOPSIS:
The Board of Trustees voted (3-1) on December 4, 2012 to recommend that the Commission change
the investment style of the domestic equity portfolio of the City's Pension Fund from “active”
management (hiring private money managers) to “passive” management (investing through
mutual or index funds) and to terminate the active managers within the US Equity portion of the
employee pension plan and replace them with an index investment approach using the Vanguard
Total Market Index Fund and engage Capital Institutional Services, Inc. to handle the transition from
individual stock holdings of the pension plan to the Vanguard Total Market Index Fund.
CONSIDERATIONS:
Key Concepts:
Active Management –
An activemanager attempts to add value (earn their fees) through one
first strategy
of three strategies. The can be called Market Timing. This is the decision to
second
move funds in and out of the equities market in an attempt to enhance returns. The
approach
is Theme Selection. This is the attempt to choose a combination of small and large
capitalization securities, to overweight specific industries or sectors versus others that are
final strategy
underweighted, or to emphasize factors such as growth or yield. The is to add
Regular 200 PAGE 1 OF 4 - December 10, 2012
value through the selection of individual stocks known as Stock Picking.
Passive Management
– This is a strategy of holding a portfolio of generic securities, without
attempting to outperform other investors through superior market forecasting or superior
ability to find mispriced securities. The simplest type of passive portfolio is an index fund.
An index fund is a fund designed to mirror the performance of a published benchmark. A
popular benchmark is the S&P 500.
On December 4, 2012, the Board of Trustees made a recommendation to change the management
approach of the Domestic Equity portion of the pension plan for the following reasons:
Expertise
– The Board of Trustees believes that a broad market approach to Domestic
Equities allows the retirement plan to earn more consistent returns than if the board were to
attempt to choose an active management firm with the right investment strategy for any given
economy or equity cycle.
Cost and Performance –
It’s the consensus of The Board of Trustees that the active
managers are not adding value to the investment returns sufficient to justify the relatively
high administration fees. Currently, Lateef Asset Mgt. and Dalton, Greiner, Hartman, Maher
& Co. charge fees of 1% ($62,027 FY2012) and .75% ($44,888 FY2012) respectively.
Lateef (Asset Management Equity) had investment returns of 13.8% and Dalton (All Cap
Value Fund) 10.53%, however, the benchmark passive fund returns that these managers are
benchmarked against earned 14.73% and 11.83% respectively for the past three years. In
comparison, if the pension were invested in the Vanguard Total Market Index Fund over the
same period the plan would have only paid fees of $7,800 per year and had supervisor
returns.
Diversification
– Due to differences in business cycles across countries and industries, equity
portfolio returns have the potential to be enhanced and/or risks (volatility) reduced through
the inclusion broad market index funds.
Focus Affords
– The Board feels that by placing more focus on the Bond and Real Estate
portions of the portfolio they can add greater value and achieve better overall portfolio
results.
In order to facilitate the recommendation to invest in Indexed Equity Funds the Winter Springs
General Employees’ Retirement System Investment Policy Statement must be modified. Currently
the Winter Spring Pension Investment Policy states:
Current Recommended
Target Target
Current Policy Recommended Policy Change
Domestic Large Cap
Value Equity
25.0% 20%-30% 25% 20%-30%
Domestic Broad Cap
Growth Equity
25.0% 20%-30% 25% 20%-30%
Foreign
Equity
15.0% 10%-20% 15% 10%-20%
Broad Market Fixed
Income
25.0% 20%-30% 15% 15%-30%
TIPS
5.0% 0%-10% 5% 0%-10%
Real
Estate
5.0% 0%-10% 10% 0%-10%
Other 0.0% 0%-10% 0% 0%-10%
Regular 200 PAGE 2 OF 4 - December 10, 2012
Global Bonds 5.0% 0%-10% 5% 0%-10%
Total 100.0% 100%
If the Commission approves this rebalancing, the following chart will reflect the new distribution of
funds.
Asset Class Target Range Benchmark Index
Domestic Broad Cap Equity 25% 25% - 35% Russell 1000 Growth / or Domestic
Broad Market Benchmark Equivalent
25% 25%- 35% Russell 3000 Value / or Domestic
Domestic Broad Cap Equity
Broad Market Benchmark Equivalent
Foreign Equity 15% 10% - 20% MSCI-EAFE
Broad Market Fixed Income 15% 15% - 30% Barclays Int. Aggregate
TIPS 5% 0% - 10% Barclays TIPS
Global Bond 5% 0% - 10% Citigroup World Gov. Bond
Real Estate* 10% 0% - 10% NFI-ODCE Property
Targets and ranges above are based on market value of total Plan assets.
FISCAL IMPACT:
The change to a blend of passive and active managers for the Domestic Equities' portion of the
Employee Pension Fund will significantly reduce the cost of administering this portion of the
portfolio, potentially increase the portfolio's yield and consequently decrease the City’s required
funding requirements to the employee pension plan.
COMMUNICATION EFFORTS:
This Agenda Item has been electronically forwarded to the Mayor and City Commission,
City Manager, City Attorney/Staff, and is available on the City’s Website, LaserFiche, and
the City’s Server. Additionally, portions of this Agenda Item are typed verbatim on the
respective Meeting Agenda which has also been electronically forwarded to the individuals
noted above, and which is also available on the City’s Website, LaserFiche, and the City’s
Server; has been sent to applicable City Staff, Media/Press Representatives who have
requested Agendas/Agenda Item information, Homeowner’s Associations/Representatives
on file with the City, and all individuals who have requested such information. This
information has also been posted outside City Hall, posted inside City Hall with additional
copies available for the General Public, and posted at five (5) different locations around the
City. Furthermore, this information is also available to any individual requestors. City Staff
is always willing to discuss this Agenda Item or any Agenda Item with any interested
individuals.
RECOMMENDATION:
Staff recommends the Commission approve the recommendation of the Board of Trustees to:
move the domestic equity portfolio from “active” management (hiring private money
1.
managers) to “passive” management (Vanguard Total Market Index Fund),
enter into a contract with Capital Institutional Services, Inc. to handle the transition from
2.
current individual stock holdings to Vanguard Total Market Index Fund,
approve the changes to the investment policy as presented in this agenda item, and
3.
ahuthorize the City Manager and City Attorney to coordinate and execute any and all
4.
Regular 200 PAGE 3 OF 4 - December 10, 2012
documents needed to facilitate these transactions.
ATTACHMENTS:
A. Draft of New Investment Policy Changes
B. Capital Institutional Services, Inc. Contract
Regular 200 PAGE 4 OF 4 - December 10, 2012
CITY OF WINTER SPRINGS
(Plan Sponsor)
GENERAL EMPLOYEES’ RETIREMENT SYSTEM
Investment Policy Statement
I. PURPOSE OF INVESTMENT POLICY STATEMENT
The Pension Board of Trustees, as named fiduciaries, maintains that an important determinant of future
investment returns is the expression and periodic review of the Plan's investment objectives. To that end,
the Board has adopted this statement of Investment Policy and directs that it apply to all assets under their
control.
In fulfilling their fiduciary responsibility, the Board recognizes that the retirement system is an essential
vehicle for providing income benefits to retired participants or their beneficiaries. The Board also
recognizes that the obligations of the Plan are long-term and that investment policy should be made with a
view toward performance and return over a number of years. The general investment objective, then, is
to obtain a reasonable total rate of return - defined as interest and dividend income plus realized and
unrealized capital gains or losses - commensurate with the Prudent Investor Rule and any other applicable
statute.
Reasonable consistency of return and protection of assets against the inroads of inflation are paramount.
However, the volatility of interest rates and securities markets make it necessary to judge results within
the context of several years rather than over short periods of two years or less.
The Board will employ professional Investment Management firms to invest the assets of the Plan.
Within the parameters allowed in this document, the Investment Managers shall have full discretion,
including security selection, sector weightings and investment style.
The Board, in performing their investment duties, shall comply with the fiduciary standards set forth in
Employee Retirement Income Security Act of 1974 (ERISA) at 29 U.S.C. s. 1104(a) (1) (A) – (C). In
case of conflict with other provisions of law authorizing investments, the investment and fiduciary
standards set forth in this section shall prevail.
II. TARGET ALLOCATIONS
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In order to provide for a diversified portfolio, the Board has engaged several Investment Management
firms. The manager’s are responsible for the assets and allocation of their mandate only and will be
provided an addendum to this policy with their specific performance objectives and investment criterea.
Asset Class Target Range Benchmark Index
Domestic Large Cap ValueBroad 2550% 2045% - 3055% Russell 3000V / or
Cap Equity Domestic Broad Market
Benchmark Equivalent
Domestic Broad Cap GrowthEquity 25% 20% - 30% Russell 1000G
Foreign Equity 15% 10% - 20% MSCI-EAFE
Broad Market Fixed Income 15% 15% - 30% Barclays Int. Aggregate
TIPS 5% 0% - 10% Barclays TIPS
Global Bond 5% 0% - 10% Citigroup World Gov.
Bond
Real Estate* 10% 0% - 10% NFI-ODCE Property
Targets and ranges above are based on market value of total Plan assets.
The Trustees will monitor the aggregate asset allocation of the portfolio, and will rebalance to the target
asset allocation based on market conditions. If at the end of any calendar quarter, the allocation of an
asset class falls outside of its allowable range, barring extenuating circumstances such as pending cash
flows or allocation levels viewed as temporary, the asset allocation will be rebalanced into the allowable
range. To the extent possible, cash contributions into and withdrawals from the portfolio will be executed
proportionally based on the most current market values available. The Trustees do not intend to exercise
short-term changes to the target allocation.
III. INVESTMENT PERFORMANCE OBJECTIVES
The following performance measures will be used as objective criteria for evaluating the effectiveness of
the Investment Managers.
A. Total Portfolio Performance
1. The performance of the Total Portfolio will be measured for rolling three and five year periods.
These periods are considered sufficient to accommodate the market cycles experienced with
investments. The performance of this portfolio will be compared to the return of a portfolio
comprised of 50% Russell 3000 / or Domestic Broad Market Benchmark Equivalent, 15%
MSCI EAFE and 15% Barclays Capital U.S. Intermediate Aggregate Bond Index, 5% BoA/ML
Global Broad Market, 5% Barclays Capital TIPS Index, and 10% NFI-ODCE Index.
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2. On a relative basis, it is expected that the total portfolio performance will rank in the top 40
percentile of the appropriate peer universe over three and five-year time periods.
3. On an absolute basis, it is expected that total return of the combined portfolio will equal or
exceed the actuarial earnings assumption (8.0%), and equal or exceed the Consumer Price Index
plus 3% over three to five year periods.
B. Equity Performance
The combined equity portion of the portfolio, defined as common stocks and convertible bonds, is
expected to perform at a rate at least equal to the 77% Russell 3000 Index, 23% MSCI EAFE Index.
Individual components of the equity portfolio will be compared as outlined in Schedule A. All
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portfolios are expected to rank in the top 40 percentile of the appropriate peer universe over three
and five-year time periods.
C. Fixed Income Performance
The overall objective of the fixed income portion of the portfolio is to add stability, consistency and
safety to the total portfolio. The fixed income portion of the portfolio is expected to perform at a rate
at least equal to the Barclays Capital U.S. Intermediate Aggregate Bond Index. All portfolios are
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expected to rank in the top 40 percentile of the appropriate peer universe over three and five-year
time periods.
D. Treasury Inflation Protection Securities (TIPS)
The overall objective of the TIPS portfolio, if utilized, is to provide inflation protection while adding
stability to the total portfolio. If TIPS are utilized the strategy is expected to approximate the
structure and performance of the Barclays Capital U.S Treasury TIPS Index.
E. Real Estate Performance
The overall objective of the real estate portfolio of the portfolio, if utilized, is to add diversification
and another stable income stream to the total fund. The real estate portion of the total fund, defined
as core, open ended private real estate, is expected to perform at a rate at least equal to the NFI-
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ODCE Index and rank in the top 40 50 percentile of the appropriate peer universe over three and
five-year time periods. Please also see attached addendums for performance objectives.
F. Alternatives
The overall objective of the alternative portion of the portfolio, if utilized, is to reduce the overall
volatility of the portfolio and improve potential absolute returns. This portion of the fund is expected
to provide an absolute rate of return and will be benchmarked as outlined in the manager addendum.
IV. INVESTMENT GUIDELINES
A. Authorized Investments
Pursuant to the investment powers of the Board of Trustees set forth in the plan and trust documents;
and subject to governing Florida Statutes and the governing local ordinances of the City of Winter
Springs, the Board of Trustees sets forth the following investment guidelines and limitations on
investments:
1. Equities:
a. Traded on a national exchange.
b. Not more than 5% of the Plan’s assets, at the time of purchase, shall be invested in the
common stock, capital stock or convertible stock of any one issuing company, nor shall the
aggregate investment in any one issuing company exceed 5% of the outstanding capital
stock of the company.
2. Fixed Income:
a. All direct investment in fixed income securities shall have a minimum rating of investment
grade or higher as determined by at least one major credit rating service.
ADOPTEDDRAFT: AUGUST 2011DECEMBER 2012 Page 3
b. The value of bonds issued by any single corporation shall not exceed 3% of the total fund.
3. Money Market:
a. The money market fund or STIF provided by the Plan’s custodian.
b. Government paper backed by full faith & credit of the United States Government.
4. Real Estate:
a. Shall be limited to commingled funds. Investments must be independently appraised
annually. Commingled fund debt holdings shall be considered independently of Fixed
Income, and may include both rated and non rated debt.
5. Alternatives
a. Investments not described under any other asset class, may be utilized to reduce the
overall volatility of the portfolio and improve potential absolute returns. All alternative
investments shall be independently custodied and provide for transparency of investment.
6. Foreign Securities:
Limited to fully and easily negotiable securities, or commingled funds with investments in such
securities..
7. Commingled Funds/Mutual Funds & Exchange Traded Funds:
Investments made by the Board may include commingled funds. For purposes of this policy
such funds may include mutual funds, commingled funds, and exchange-traded funds.
a. Such funds may be governed by separate policy which may include investments not
expressly permitted in this Investment Policy Statement. In the event of investment by the
Plan into a fund the Board will adopt the prospectus or governing policy of that fund as the
stated addendum to this Investment Policy Statement.
b. The asset classification of the fund will be based upon its investment objective.
B. Trading Parameters
When feasible and appropriate, all securities shall be competitively bid. Except as otherwise
required by law, the most economically advantageous bid shall be selected. Commissions paid for
purchase of securities must meet the prevailing best-execution rates. The responsibility of
monitoring best price and execution of trades placed by each manager on behalf of the Plan will be
governed by the Portfolio Management Agreement between the Plan and the Investment Managers.
C. Limitations
1. Investments in corporate common stock and convertible bonds shall not exceed seventy-five
percent (75%) of the Fund assets at market.
2. Foreign securities shall not exceed twenty percent (25%) of the value at market of the Fund.
3. Alternative investments shall not exceed 15% of the value at market of the Fund
ADOPTEDDRAFT: AUGUST 2011DECEMBER 2012 Page 4
D. Absolute Restrictions
There will be no investment activity in the following:
1. Any investment prohibited by State or Federal Law.
2. Any investment not specifically allowed as part of this policy.
3. Illiquid investments, as described in Chapter 215.47, Florida Statutes.
V. COMMUNICATIONS
A. On a monthly basis, the custodian shall supply an accounting statement that will include a summary
of all receipts and disbursements and the cost and the market value of all assets. On a quarterly
basis, the Investment Managers shall provide a written report affirming compliance with the security
restrictions of Section IV above and a summary of common stock diversification and attendant
schedules.
B. In addition, the Investment Managers shall deliver each quarter a report detailing the Plan's
performance, adherence to the investment policy, forecast of the market and economy, portfolio
analysis and current assets of the Plan. Written reports shall be delivered to the Board within 30
days of the end of the quarter. A copy of the written report shall be submitted to the person
designated by the City, and shall be available for public inspection. The Investment Managers will
provide immediate written and telephone notice to the Board of any significant market related or
non-market related event, specifically including, but not limited to, any deviation from the standards
set forth in Section IV above.
C. The Investment Managers will disclose any securities that do not comply with section IV in each
quarterly report.
D. If the Plan owns investments at the end of a calendar quarter that complied with section IV at the
time of purchase, which do not satisfy the applicable investment standard, then such investment shall
be disposed of at the earliest economically feasible opportunity in accordance with the prudent man
standard of care and no additional investment may be made. However an action plan outlining the
disposition strategy shall be provided to the Board immediately.
E. The Investment Consutlant shall evaluate and report on a quarterly basis the rate of return and
relative performance of the Plan.
F. The Board will meet quarterly to review the monitoring service's performance report. The Board
will meet with the investment manager and appropriate outside consultants to discuss performance
results, economic outlook, investment strategy and tactics and other pertinent matters affecting the
Plan on a periodic basis.
G. At least annually, the Board shall provide the Investment Managers with projected disbursement
needs of the Plan so that the investment portfolio can be structured in such a manner as to provide
sufficient liquidity to pay obligations as they come due. To this end the Investment Managers
should, to the extent possible, attempt to match investment maturities with known cash needs and
anticipated cash-flow requirements.
VI. COMPLIANCE
A. It is the direction of the Board that the plan assets are held by a third party custodian, and that all
securities purchased by, and all collateral obtained by the plan shall be properly designated as Plan
ADOPTEDDRAFT: AUGUST 2011DECEMBER 2012 Page 5
assets. No withdrawal of assets, in whole or in part, shall be made from safekeeping except by an
authorized member of the Board or their designee. Securities transactions between a broker-dealer
and the custodian involving purchase or sale of securities by transfer of money or securities must be
made on a "delivery vs. payment" basis to insure that the custodian will have the security or money in
hand at conclusion of the transaction. Provided that all approved vendors transacting repurchase
agreements perform as stated in any Master Repurchase Agreement.
B. At the direction of the Board operations of the Plan shall be reviewed by independent certified public
accountants as part of any financial audit periodically required. Compliance with the Board’s internal
controls shall be verified. These controls have been designed to prevent losses of assets that might
arise from fraud, error, or misrepresentation by third parties or imprudent actions by the Board or
employees of the plan sponsor, to the extent possible.
C. Each member of the Board shall participate in a continuing education program relating to investments
and the Board’s responsibilities to the Plan. It is highly suggested that this education process begin
during each Trustee’s first term.
D. With each actuarial valuation, the Board shall determine the total expected annual rate of return for
the current year, for each of the next several years and for the long term thereafter. This
determination shall be filed promptly with the Department of Management Services, the plan’s
sponsor and the consulting actuary.
E. The proxy votes must be exercised for the exclusive benefit of the participants of the Plan. Each
Investment Manager shall provide the Board with a copy of their proxy voting policy for approval.
On a regular basis, at least annually, each manager shall report a record of their proxy vote.
F. Investments for which there is no generally recognized market or consistent accepted pricing
mechanism shall be valued at 50% cost. Assets without a fair market value shall be excluded from
determination of annual funding cost.
VII. CRITERIA FOR INVESTMENT MANAGER REVIEW
The Board wishes to adopt standards by which judgments of the ongoing performance of a portfolio
manager may be made. If, at any time, any three of the following is breached, the portfolio manager will
be warned of the Board's serious concern for the Fund's continued safety and performance. If any five of
these are violated the consultant will recommend a manager search for that mandate.
Four (4) consecutive quarters of relative under-performance verses the benchmark.
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Three (3) year trailing return below the top 40 percentile within the appropriate peer group
and under performance verses the benchmark.
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Five (5) year trailing return below the top 40 percentile and under performance verses the
benchmark.
Three (3) year downside volatility greater than the index (greater than 100), as measured by
down market capture ratio.
Five (5) year downside volatility greater than the index (greater than 100), as measured by
down market capture ratio.
Style consistency or purity drift from the mandate.
Management turnover in portfolio team or senior management.
Investment process change, including varying the index or benchmark.
Failure to adhere to the IPS or other compliance issues.
ADOPTEDDRAFT: AUGUST 2011DECEMBER 2012 Page 6
Investigation of the firm by the Securities and Exchange Commission (SEC).
Significant asset flows into or out of the company.
Merger or sale of firm.
Fee increases outside of the competitive range.
Servicing issues – key personnel stop servicing the account without proper notification.
Failure to attain a 60% vote of confidence by the Board.
Nothing in this section shall limit or diminish the Board’s right to terminate the manager at any time for
any reason.
VIII. APPLICABLE CITY ORDINANCES
If, at any time, this document is found to be in conflict with the City Ordinances, the Ordinances shall
prevail.
IX. REVIEW AND AMENDMENTS
It is the Board’s intention to review this document at least annually subsequent to the actuarial report and
to amend this statement to reflect any changes in philosophy, objectives, or guidelines. In this regard, the
Investment Manager's interest in consistency in these matters is recognized and will be taken into account
when changes are being considered. If, at any time, the Investment Manager feels that the specific
objectives defined herein cannot be met, or the guidelines constrict performance, the Board should be
notified in writing. By initialing and continuing acceptance of this Investment Policy Statement, the
Investment Managers concur with the provisions of this document.
City of Winter Springs General Employees’ Retirement System
_______________________ __________
Chairperson, Board of Trustees Date
ADOPTEDDRAFT: AUGUST 2011DECEMBER 2012 Page 7
TRANSITIONMANAGEMENTAGREEMENTLETTER
The purpose of this correspondence is to confirm our understanding with regard to the portfolio
transition resulting from the termination of {LEGACY MANAGER} (“Manager”). Specifically,
at the request of City of Winter Springs General Employees’ Pension (“Client”), Capital
Institutional Services, Inc (“CAPIS”) will, as agent, act as the Transition Manager to facilitate the
liquidation, buy-in and in-kind transfers associated with this transition.
CAPIS represents to Client the following:
1. Acting as agent for Client, CAPIS will execute equity portfolio transactions at a rate of
$0.0125 cents per share which will be the only form of remuneration CAPIS receives for
the event. The transition will be executed by CAPIS in accordance with the timeframe and
objectives, subject to delivery, set by Client.
2. CAPIS confirms that, as a registered broker-dealer under the Securities Exchange Act of
1934 and as a member firm of the NYSE, FINRA, and NFA it has an obligation to protect
the best interests of its Client. Further, CAPIS will perform each transaction in accordance
with the appropriate statutes and regulations governing the securities industry.
3. CAPIS will request the target portfolio from the new manager(s) if applicable. CAPIS will
determine any in-kind transfers based upon the current portfolio holdings and the target
portfolio.
4. After execution, CAPIS will work with {CUSTODIAN} (“Custodian”) to report and settle
all trades.
5. CAPIS will prepare pre and post trade analytics and other reporting as requested by Client.
6. CAPIS shall carry out its duties with care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and familiar
with such matters would use. An audit trail of major transition activity as well as time-
stamped executions will be made available upon request.
7. CAPIS will keep all information, documents, and lists of securities confidential and made
available only to members directly involved with the transition unless ordered to produce,
by law, in connection with government or self-regulatory organization request.
1601 Elm Street, Suite 3900, Dallas, Texas 75201 214.720.0055 800.247.6729 Fax 214.954.0040 www.capis.com
Member: NYSE, FINRA, NFA, SIPC
With regard to this request, Client represents to CAPIS the following:
1. Client will notify Manager of their termination prior to the initiation of the liquidation and
will request a halt to trading in the related accounts. Client will also determine a
termination date to be announced to all necessary parties.
2. Client will charge {TARGET MANAGER} with the responsibility for investment
decision(s) based on their mandate. This will occur prior to the initiation of the transition.
3. Client, through Custodian, will provide CAPIS with a certified holdings list and corporate
action summary prior to initiation of the transition and will instruct Custodian to work with
CAPIS on the settlement of all transactions.
4. Client will provide CAPIS with appropriate contacts of each manager involved in the
transition and the Custodian bank. (Please attach a list with the executed copy of this
correspondence.) Each of these parties will be instructed by Client to work with CAPIS
during the duration of the transition.
5. Client will notify CAPIS of any specific objectives, restrictions or timeframe that must be
followed during the transition.
This agreement constitutes the entire Transition Management Agreement between the parties and
shall supersede all previous communications or agreements, which have been made between the
parties. No change to the terms and conditions of this Agreement will be valid unless made by
supplemental written amendment executed by both parties.
Please indicate your agreement with and acceptance of the foregoing by signing and returning a
copy of this letter to CAPIS prior to the initiation of the transition.
Approved and Accepted for CAPIS by:
_____________________________________ __________________________
Name / Title Date
Approved and Accepted for Client by:
__________________________________ ________________________
Name / Title Date
1601 Elm Street, Suite 3900, Dallas, Texas 75201 214.720.0055 800.247.6729 Fax 214.954.0040 www.capis.com
Member: NYSE, FINRA, NFA, SIPC