Treasury Management Strategy Statement
Minimum Revenue Provision Policy Statement and Annual Investment Strategy
Maidstone Borough Council
2018/19
INDEX
1.3 Treasury Management Strategy for 2018/19
1.4 Treasury management consultants
2 THE CAPITAL PRUDENTIAL INDICATORS AND MINIMUM REVENUE PROVISION
2.2 The Council’s borrowing need (the Capital Financing Requirement)
2.3 Affordability prudential indicators
2.4 Incremental impact of capital investment decisions on council tax
3.1 Treasury Indicators: limits to borrowing activity
3.2 Prospects for interest rates
3.4 Policy on borrowing in advance of need
4.3 End of year investment report………………………………………………………………………………18
4.4 Other Items…………………………………………………………………………………………...……………………18
The Council is required to operate a balanced budget, which broadly means that cash raised during the year will meet cash expenditure. Part of the treasury management service is to ensure that this cash flow is adequately planned, with cash being available when it is needed. Surplus monies are invested in low risk counterparties or instruments commensurate with the Council’s low risk appetite, providing adequate liquidity initially before considering investment return.
The second main function of the treasury management service is the funding of the Council’s capital plans. These capital plans provide a guide to the borrowing need of the Council, essentially the longer term cash flow planning to ensure that the Council can meet its capital spending obligations. This management of longer term cash may involve arranging long or short term loans, or using longer term cash flow surpluses. On occasion any debt previously drawn may be restructured to meet Council risk or cost objectives.
The council has adopted the Treasury Management in Public Services: Code of Practice 2011 Edition (‘the Code’) issued by the Chartered Institute of Public Finance and Accountancy (CIPFA). CIPFA defines treasury management as:
“The management of the local authority’s investments and cash flows, its
banking, money market and capital market transactions; the effective control of
the risks associated with those activities; and the pursuit of optimum
performance consistent with those risks.”
The Council is required to receive and approve the Treasury Management Strategy, which incorporates a variety of policies, estimates and actuals.
Prudential and treasury indicators and treasury strategy (this report) - The first, and most important report covers:
· the capital plans (including prudential indicators);
· a minimum revenue provision (MRP) policy (how residual capital expenditure is charged to revenue over time);
· the treasury management strategy (how investments and borrowings are organised) including treasury indicators; and
· an investment strategy (the parameters for how investments are to be managed).
The following reports are not required to be approved by Council but are to be reported and scrutinised to the relevant Committee. The Council has delegated this function to the Audit, Governance and Standards Committee.
A mid year treasury management report – This will update members with the progress of the capital position, amending prudential indicators as necessary, and determining whether any policies require revision if the assumptions on which this strategy is based were to change significantly. In accordance guidance issued by Department for Communities and Local Government (DCLG), the circumstances which may require the council to revise its strategy would include, for example, a large unexpected change in interest rates, or in the council’s capital programme or in the level of its investment balance.
An annual treasury report – This provides details of a selection of actual prudential and treasury indicators and actual treasury operations compared to the estimates within the strategy.
A quarterly update on the Council’s treasury management position is also provided through budget monitoring reports presented to Policy & Resources Committee.
1.3 Treasury Management Strategy for 2018/19
The strategy for 2018/19 covers two main areas:
Capital issues
· the capital plans and the prudential indicators;
· the minimum revenue provision (MRP) policy.
Treasury management issues
· treasury indicators which limit the treasury risk and activities of the Council;
· prospects for interest rates;
· the borrowing strategy;
· policy on borrowing in advance of need;
· the investment strategy; and
· creditworthiness policy.
These elements cover the requirements of the Local Government Act 2003, the CIPFA Prudential Code, DCLG Minimum Revenue Provision Guidance, the CIPFA Treasury Management Code and DCLG Investment Guidance.
1.4 Treasury management consultants
The Council uses Arlingclose Limited as its external treasury management advisors.
Responsibility for treasury management decisions ultimately remains within the Council and officers will not place undue reliance on the advice of external service providers.
The terms of appointment and value gained through use of treasury management consultants will be subject to regular review by the Director of Finance and Business Improvement.
The CIPFA Code requires the responsible officer to ensure that members with responsibility for treasury management receive adequate training in treasury management. Training is offered to members of the Audit, Governance and Standards Committee on a regular basis.
Staff regularly attend training courses, seminars and conferences provided by Arlingclose and CIPFA. Relevant staff are also encouraged to study professional qualifications delivered by CIPFA, the Association of Corporate Treasurers and other appropriate organisations.
Staff training needs are assessed regularly both as part of the appraisal process and when the responsibilities of individual members of staff change.
2 THE CAPITAL PRUDENTIAL INDICATORS AND MINIMUM REVENUE PROVISION
The Council’s capital expenditure plans are the key driver of treasury management activity. The output of the capital expenditure plans is reflected in the prudential indicators, which are designed to assist members’ overview and confirm capital expenditure plans.
This prudential indicator is a summary of the Council’s capital expenditure plans; those agreed previously, as well as those forming part of this budget cycle. Capital expenditure forecasts are shown below:
2017/18 |
2018/19 |
2019/20 |
2020/21 |
2021/22 |
£,000 |
£,000 |
£,000 |
£,000 |
£,000 |
14,146 |
23,948 |
22,636 |
15,303 |
5,025 |
2.2 The Council’s borrowing need (the Capital Financing Requirement)
The second prudential indicator is the Council’s Capital Financing Requirement (CFR). The CFR is simply the total historic outstanding capital expenditure which has not yet been paid for from either revenue or capital resources. It is essentially a measure of the Council’s underlying borrowing need. Any capital expenditure above, which has not immediately been paid for, will increase the CFR.
The CFR does not increase indefinitely, as the minimum revenue provision (MRP) is a statutory annual revenue charge which broadly reduces the borrowing need in line with each asset’s life.
The CFR includes the liability for the arrangement with Serco Paisa for leisure centre improvements. Whilst these increase the CFR, and therefore the Council’s borrowing requirement, these types of scheme include a borrowing facility and so the Council is not required to separately borrow for these schemes.
CFR projections are shown in the table below:
2017/18 |
2018/19 |
2019/20 |
2020/21 |
2021/22 |
£,000 |
£,000 |
£,000 |
£,000 |
£,000 |
-18,401 |
1,547 |
19,982 |
34,486 |
38,711 |
2.3 Affordability prudential indicators
The previous sections cover the overall capital and control of borrowing prudential indicators, but within this framework prudential indicators are required to assess the affordability of the capital investment plans. These provide an indication of the impact of the capital investment plans on the Council’s overall finances.
Ratio of financing costs to net revenue stream
This indicator identifies the trend in the cost of capital (borrowing and other long term obligation costs net of investment income) against the net revenue stream.
2017/18 |
2018/19 |
2019/20 |
2020/21 |
2021/22 |
% |
% |
% |
% |
% |
-0.6 |
-0.4 |
1.1 |
2.5 |
2.9 |
2017/18 |
2018/19 |
2019/20 |
2020/21 |
2021/22 |
£000 |
£000 |
£000 |
£000 |
£000 |
-105 |
-77 |
210 |
449 |
528 |
The estimates of financing costs include current commitments and the proposals in this budget report.
2.4 Incremental impact of capital investment decisions on council tax
This indicator identifies the revenue costs associated with proposed changes to the five year capital programme recommended in this budget cycle compared to the Council’s existing approved commitments and current plans. The assumptions are based on the budget, but will invariably include some estimates, such as the level of government support.
Incremental impact of capital investment decisions on the band D council tax
|
2017/18 £.p |
2018/19 £.p |
2019/20 £.p |
2020/21 £.p |
2021/22 £.p |
Council tax - band D |
0.09 |
0.75 |
0.92 |
0.53 |
0.00 |
Where the Authority finances capital expenditure by debt, it must put aside resources to repay that debt in later years. The amount charged to the revenue budget for the repayment of debt is known as Minimum Revenue Provision (MRP), although there has been no statutory minimum since 2008. The Local Government Act 2003 requires the Authority to have regard to the Department for Communities and Local Government’s Guidance on Minimum Revenue Provision (the DCLG Guidance) most recently issued in 2012.
The broad aim of the Guidance is to ensure that debt is repaid over a period that is either reasonably commensurate with that over which the capital expenditure provides benefits, or, in the case of borrowing supported by Government Revenue Support Grant, reasonably commensurate with the period implicit in the determination of that grant.
The Council expects that its Capital Financing Requirement will be negative on 31st March 2018 and in line with the DCLG Guidance it will therefore charge no MRP in 2018/19.
The capital expenditure plans set out in Section 2 provide details of the service activity of the Council. The treasury management function ensures that the Council’s cash is organised in accordance with therelevant professional codes, so that sufficient cash is available to meet this service activity. This will involve both the organisation of the cash flow and, where capital plans require, the organisation of approporiate borrowing facilities. The strategy covers the relevant treasury / prudential indicators, the current and projected debt positions and the annual investment strategy.
3.1 Treasury Indicators: limits to borrowing activity
The operational boundary. This is the limit beyond which external debt is not normally expected to exceed. In most cases, this would be a similar figure to the CFR, but may be lower or higher depending on the levels of actual debt.
Operational boundary |
2017/18 £000 |
2018/19 £000 |
2019/20 £000 |
2020/21 £000 |
Debt |
0 |
1,547 |
19,982 |
34,486 |
Other long term liabilities |
4,033 |
3,526 |
3,005 |
2,483 |
Total |
4,033 |
5,073 |
22,987 |
36,969 |
The authorised limit for external debt. A further key prudential indicator represents a control on the maximum level of borrowing. This represents a limit beyond which external debt is prohibited, and this limit needs to be set or revised by the full Council. It reflects the level of external debt which, while not desired, could be afforded in the short term, but is not sustainable in the longer term.
1. This is the statutory limit determined under section 3 (1) of the Local Government Act 2003. The Government retains an option to control either the total of all councils’ plans, or those of a specific council, although this power has not yet been exercised.
2. The Council is asked to approve the following authorised limit:
Authorised limit |
2017/18 £000 |
2018/19 £000 |
2019/20 £000 |
2020/21 £000 |
Debt |
4,000 |
5,547 |
23,982 |
38,486 |
Other long term liabilities |
4,033 |
3,526 |
3,005 |
2,483 |
Total |
8,033 |
9,073 |
26,987 |
40,969 |
3.2 Prospects for interest rates
The Council’s advisors, Arlingclose Ltd, have provided the following interest rate forecast:
Forecast:
§ The MPC has increased Bank Rate, largely to meet expectations they themselves created. Future expectations for higher short term interest rates are subdued. Ongoing decisions remain data dependant and negotiations on exiting the EU cast a shadow over monetary policy decisions.
§ The MPC minutes emphasised that any prospective increases in Bank Rate would be expected to be gradual and to a limited extent.
§ It is expected that the depreciation in sterling may assist the economy to rebalance away from spending while export volumes are likely to increase.
§ Arlingclose suggest that gilt yields will remain broadly stable across the medium term. Upward movement will be limited.
The Council is currently maintaining an under-borrowed position. This means that the capital borrowing need (the Capital Financing Requirement), has been funded using cash supporting the Council’s reserves, balances and cash flow as a temporary measure, rather than through loan debt. This strategy is prudent as currently investment returns are low and counterparty risk is relatively high and will be retained for the forthcoming financial year on the assumption that this situation is unlikely to change in the short term. However, if short term cash requirements cannot be met from balances in hand for day to day purposes, the Council has access to a range of sources of short term borrowing options, which includes other local authorities
The Authorised Limit to borrow up to £5,547m for the financing of capital expenditure and day to day cash flow liquidity within 2018/19 is included in the current capital programme and the current prudential indicators. The 2018/19 strategy includes the continuation of that authority within the calculation of the indicators. If the Council is to borrow then the affordability of the capital programme must include an assessment of the cost of borrowing along with the loss of investment income from the use of capital resources held in cash.
Should rates move more quickly than the forecast predicts, the current and proposed strategies do allow the section 151 officer to take advantage of external borrowing. The Council’s policy on borrowing in advance of need is set out at section 3.4 of this strategy.
Objectives: The Authority’s chief objective when borrowing money is to strike an appropriately low risk balance between securing low interest costs and achieving certainty of those costs over the period for which funds are required. The flexibility to renegotiate loans should the Authority’s long-term plans change is a secondary objective.
Strategy: The Authority’s borrowing strategy continues to address the key issue of affordability without compromising the longer-term stability of the debt portfolio. With short-term interest rates currently much lower than long-term rates, it is likely to be more cost effective in the short-term to either use internal resources, or to borrow short-term loans instead.
By doing so, the Authority is able to reduce net borrowing costs (despite foregone investment income) and reduce overall treasury risk. The benefits of internal / short-term borrowing will be monitored regularly against the potential for incurring additional costs by deferring borrowing into future years when long-term borrowing rates are forecast to rise modestly. Arlingclose will assist the Authority with this ‘cost of carry’ and breakeven analysis. Its output may determine whether the Authority borrows additional sums at long-term fixed rates in 2018/19 with a view to keeping future interest costs low, even if this causes additional cost in the short-term.
Alternatively, the Authority may arrange forward starting loans during 2018/19, where the interest rate is fixed in advance, but the cash is received in later years. This would enable certainty of cost to be achieved without suffering a cost of carry in the intervening period.
In addition, the Authority may make use of short-term loans to cover unplanned cash flow.
Sources: The approved sources of long-term and short-term borrowing are:
• Public Works Loan Board (PWLB) and any successor body
• any institution approved for investments (see below)
• any other bank or building society authorised to operate in the UK
• capital market bond investors
• UK Municipal Bonds Agency plc and other special purpose companies created to enable local authority bond issues
• UK public and private sector pension funds (except the Kent County Council Pension Fund)
In addition, capital finance may be raised by the following methods that are not borrowing, but may be classed as other debt liabilities:
• operating and finance leases
• hire purchase
• Private Finance Initiative
• sale and leaseback
•
Other sources of debt finance: In addition, capital finance may be raised by the following methods that are not borrowing, but may be classed as other debt liabilities:
• operating and finance leases
• hire purchase
• Private Finance Initiative
• sale and leaseback
3.4 Policy on borrowing in advance of need
The Council will not borrow more than or in advance of its needs purely in order to profit from the investment of the extra sums borrowed. Any decision to borrow in advance will be within forward approved Capital Financing Requirement estimates, and will be considered carefully to ensure that value for money can be demonstrated and that the Council can ensure the security of such funds.
Risks associated with any borrowing in advance activity will be subject to prior appraisal and subsequent reporting through the mid-year or annual reporting mechanism.
The Authority holds significant invested funds, representing income received in advance of expenditure plus balances and reserves held. In the past 12 months, the Authority’s investment balance has ranged between £14.6 and £39.9 million.
Objectives: Both the CIPFA Code and the DCLG Guidance require the Authority to invest its funds prudently, and to have regard to the security and liquidity of its investments before seeking the highest rate of return, or yield. The Authority’s objective when investing money is to strike an appropriate balance between risk and return, minimising the risk of incurring losses from defaults and the risk receiving unsuitably low investment income.
Strategy: Given the increasing risk and continued low returns from short-term unsecured bank investments, the council aims to further diversify into more secure and/or higher yielding asset classes during 2018/19. This is especially the case for the proposed £5m that is estimated to be available for longer-term investment. The majority of council’s surplus cash is currently invested in Local Authority borrowing, short-term unsecured bank deposits, certificates of deposit, money market funds and cash enhanced funds. This diversification will represent a continuation of the new strategy.
Approved Counterparties: The Authority may invest its surplus funds with any of the counterparty types in the table below, subject to the cash limits (per counterparty) and the time limits shown. Additional detail regarding the different types of counterparty is provided below the table.
Approved Investment Counterparties and Limits
Credit Rating |
Banks Unsecured |
Banks Secured |
Government |
Corporates |
Registered Providers |
UK Govt |
n/a |
n/a |
£ Unlimited 50 years |
n/a |
n/a |
AAA |
£3m 5 years |
£5m 20 years |
£5m 50 years |
£3m 20 years |
£3m 20 years |
AA+ |
£3m 5 years |
£5m 10 years |
£5m 25 years |
£3m 10 years |
£3m 10 years |
AA |
£3m 4 years |
£5m 5 years |
£5m 15 years |
£3m 5 years |
£3m 10 years |
AA- |
£3m 3 years |
£5m 4 years |
£5m 10 years |
£3m 4 years |
£3m 10 years |
A+ |
£3m 2 years |
£5m 3 years |
£5m 5 years |
£3m 3 years |
£3m 5 years |
A |
£3m 13 months |
£5m 2 years |
£5m 5 years |
£3m 2 years |
£3m 5 years |
A- |
£3m 6 months |
£5m 13 months |
£5m 5 years |
£3m 13 months |
£3m 5 years |
None |
£1m 100 days |
n/a |
£5m 25 years |
£50,000 5 years |
£3m 5 years |
Pooled funds |
£8m per fund |
The time limits set out above are consistent with the recommended durations provided by the council’s treasury management advisors, Arlingclose. The cash limits have been set with reference to this guidance, although the upper limit in certain categories of investment exceeds the limit proposed by Arlingclose in order to meet the operational requirements of the council. The limits adopted within the strategy remain prudent and consistent with ensuring the security of capital and appropriate levels of liquidity.
Credit Rating: Investment limits are set by reference to the lowest published long-term credit rating from Fitch, Moody’s or Standard & Poor’s. Where available, the credit rating relevant to the specific investment or class of investment is used, otherwise the counterparty credit rating is used. However, investment decisions are never made solely based on credit ratings, and all other relevant factors including external advice will be taken into account.
Banks Unsecured: Accounts, deposits, certificates of deposit and senior unsecured bonds with banks and building societies, other than multilateral development banks. These investments are subject to the risk of credit loss via a bail-in should the regulator determine that the bank is failing or likely to fail. See below for arrangements relating to operational bank accounts.
Banks Secured: Covered bonds, Tri Party Repos, reverse repurchase agreements and other collateralised arrangements with banks and building societies. These investments are secured on the bank’s assets, which limits the potential losses in the unlikely event of insolvency, and means that they are exempt from bail-in. Where there is no investment specific credit rating, but the collateral upon which the investment is secured has a credit rating, the higher of the collateral credit rating and the counterparty credit rating will be used to determine cash and time limits. The combined secured and unsecured investments in any one bank will not exceed the cash limit for secured investments.
Government: Loans, bonds and bills issued or guaranteed by national governments, regional and local authorities and multilateral development banks. These investments are not subject to bail-in, and there is an insignificant risk of insolvency. Investments with the UK Central Government may be made in unlimited amounts for up to 50 years.
Corporates: Loans, bonds and commercial paper issued by companies other than banks and registered providers. These investments are not subject to bail-in, but are exposed to the risk of the company going insolvent. Loans to unrated companies will only be made as part of a diversified pool in order to spread the risk widely.
Registered Providers: Loans and bonds issued by, guaranteed by or secured on the assets of Registered Providers of Social Housing, formerly known as Housing Associations. These bodies are tightly regulated by the Homes and Communities Agency and, as providers of public services, they retain the likelihood of receiving government support if needed.
Pooled Funds: Shares in diversified investment vehicles consisting of the any of the above investment types, plus equity shares and property. These funds have the advantage of providing wide diversification of investment risks, coupled with the services of a professional fund manager in return for a fee. Short-term Money Market Funds that offer same-day liquidity and very low or no volatility will be used as an alternative to instant access bank accounts, while pooled funds whose value changes with market prices and/or have a notice period will be used for longer investment periods.
Bond, equity and property funds offer enhanced returns over the longer term, but are more volatile in the short term. These allow the Authority to diversify into asset classes other than cash without the need to own and manage the underlying investments. Because these funds have no defined maturity date, but are available for withdrawal after a notice period, their performance and continued suitability in meeting the Authority’s investment objectives will be monitored regularly.
Operational bank accounts: The Authority may incur operational exposures, for example though current accounts, collection accounts and merchant acquiring services, to any UK bank with credit ratings no lower than BBB- and with assets greater than £25 billion. These are not classed as investments, but are still subject to the risk of a bank bail-in, and balances will therefore be kept below £500,000 per bank. The Bank of England has stated that in the event of failure, banks with assets greater than £25 billion are more likely to be bailed-in than made insolvent, increasing the chance of the Authority maintaining operational continuity.
Risk assessment and credit ratings: Credit ratings are obtained and monitored by the Authority’s treasury advisers, who will notify changes in ratings as they occur. Where an entity has its credit rating downgraded so that it fails to meet the approved investment criteria then:
• no new investments will be made,
• any existing investments that can be recalled or sold at no cost will be, and
• full consideration will be given to the recall or sale of all other existing investments with the affected counterparty.
Where a credit rating agency announces that a credit rating is on review for possible downgrade (also known as “rating watch negative” or “credit watch negative”) so that it may fall below the approved rating criteria, then only investments that can be withdrawn [on the next working day] will be made with that organisation until the outcome of the review is announced. This policy will not apply to negative outlooks, which indicate a long-term direction of travel rather than an imminent change of rating.
Other information on the security of investments: The Authority understands that credit ratings are good, but not perfect, predictors of investment default. Full regard will therefore be given to other available information on the credit quality of the organisations in which it invests, including credit default swap prices, financial statements, information on potential government support and reports in the quality financial press. No investments will be made with an organisation if there are substantive doubts about its credit quality, even though it may meet the credit rating criteria.
When deteriorating financial market conditions affect the creditworthiness of all organisations, as happened in 2008 and 2011, this is not generally reflected in credit ratings, but can be seen in other market measures. In these circumstances, the Authority will restrict its investments to those organisations of higher credit quality and reduce the maximum duration of its investments to maintain the required level of security. The extent of these restrictions will be in line with prevailing financial market conditions. If these restrictions mean that insufficient commercial organisations of high credit quality are available to invest the Authority’s cash balances, then the surplus will be deposited with the UK Government, via the Debt Management Office or invested in government treasury bills for example, or with other local authorities. This will cause a reduction in the level of investment income earned, but will protect the principal sum invested.
The criteria for providing a pool of high quality investment counterparties (both specified and non-specified investments) is:
Specified Investments: The DCLG Guidance defines specified investments as those:
• denominated in pound sterling,
• due to be repaid within 12 months of arrangement,
• not defined as capital expenditure by legislation, and
• invested with one of:
• the UK Government,
• a UK local authority, parish council or community council, or
• a body or investment scheme of “high credit quality”.
The Council defines “high credit quality” organisations and securities as those having a credit rating of A- or higher that are domiciled in the UK or a foreign country with a sovereign rating of AA+ or higher. For money market funds and other pooled funds “high credit quality” is defined as those having a credit rating of A- or higher.
Non-specified Investments: Any investment not meeting the definition of a specified investment is classed as non-specified. The Authority does not intend to make any investments denominated in foreign currencies, nor any that are defined as capital expenditure by legislation, such as company shares. Non-specified investments will therefore be limited to long-term investments, i.e. those that are due to mature 12 months or longer from the date of arrangement, and investments with bodies and schemes not meeting the definition on high credit quality. Limits on non-specified investments are shown in the table below.
Non-Specified Investment Limits
|
Cash limit |
Total long-term investments |
£5m |
Total investments without credit ratings or rated below A- |
£5m |
Total investments (except pooled funds) with institutions domiciled in foreign countries rated below AA+ |
£8m |
Total non-specified investments |
£18m |
The council will maintain a counterparty list to identify institutions suitable for investment. The counterparty list will be maintained using the following principles:
Risk Assessment and Credit Ratings: Credit ratings are obtained and monitored by the Authority’s treasury advisers, who will notify changes in ratings as they occur. Where an entity has its credit rating downgraded so that it fails to meet the approved investment criteria then:
• no new investments will be made,
• any existing investments that can be recalled or sold at no cost will be, and
• full consideration will be given to the recall or sale of all other existing investments with the affected counterparty.
Investment Limits: In order that available reserves will not be put at risk in the case of a single default, the maximum that will be lent to any one organisation (other than the UK Government) will be £8 million. A group of banks under the same ownership will be treated as a single organisation for limit purposes. Limits will also be placed on fund managers, investments in brokers’ nominee accounts, foreign countries and industry sectors as below. Investments in pooled funds and multilateral development banks do not count against the limit for any single foreign country, since the risk is diversified over many countries.
|
Cash limit |
Any single organisation, except the UK Central Government |
£5m each |
UK Central Government |
unlimited |
Any group of organisations under the same ownership |
£5m per group |
Any group of pooled funds under the same management |
£8m per manager |
Negotiable instruments held in a broker’s nominee account |
£5m per broker |
Foreign countries |
£5m per country |
Registered Providers |
£5m in total |
Unsecured investments with Building Societies |
£3m each |
Loans to unrated corporates |
£50,000 each |
Money Market Funds |
£8m each fund or fund group |
Liquidity Management: The council uses a cash flow forecasting spreadsheet to determine the maximum period for which funds may prudently be committed. The forecast is compiled on a prudent basis to minimise the risk of the council being forced to borrow on unfavourable terms to meet its financial commitments. Limits on long-term investments are set by reference to the council’s medium term financial plan and cash flow forecast.
Non-Treasury Investments
Although not classed as treasury management activities and therefore not covered by the CIPFA Code or the DCLG Guidance, the Authority may also purchase property for investment purposes and may also make loans and investments for service purposes, for example in shared ownership housing, as loans to local businesses and landlords, or as equity investments and loans to the Authority’s subsidiaries.
Such loans and investments will be subject to the Authority’s normal approval processes for revenue and capital expenditure and need not comply with this treasury management strategy.
Accounting treatment of investments.
The accounting treatment may differ from the underlying cash transactions arising from investment decisions made by this Council. To ensure that the Council is protected from any adverse revenue impact, which may arise from these differences, we will review the accounting implications of new transactions before they are undertaken.
In-house funds. The majority of investments will be made with reference to the cash flow requirements so invested for short-term interest rates (i.e. rates for investments up to 12 months). However, there is a provision of funds that can be used for longer term investments (greater than 12 months) if it deemed to be prudent by the section 151 officer.
Investment treasury indicator and limit - total principal funds invested for greater than 364 days. These limits are set with regard to the Council’s liquidity requirements and to reduce the need for early sale of an investment, and are based on the availability of funds after each year-end.
The Council is asked to approve the treasury indicator and limit: -
Maximum principal sums invested > 364 days |
|||
|
2018/19 £000 |
2019/20 £000 |
2020/21 £000 |
Principal sums invested > 364 days |
5,000 |
5,000 |
5,000 |
Interest Rate Exposures: This indicator is set to control the Authority’s exposure to interest rate risk. The upper limits on fixed and variable rate interest rate exposures, expressed as the amount of net principal borrowed will be:
|
2018/19 £000 |
2019/20 £000 |
2020/21 £000 |
Upper limit on fixed interest rate exposure |
-38,453 |
-20,018 |
-5,514 |
Upper limit on variable interest rate exposure |
-32,000 |
-32,000 |
-32,000 |
The upper limit on fixed interest rates incorporates maximum borrowing of £10.36m within the strategy which reduced the negative investment limit within 2018/19. The upper limit on variable interest rate exposure is calculated as being 80% of the projected highest level of investments during 2018/19.
Maturity Structure of Borrowing: This indicator is set to control the Authority’s exposure to refinancing risk. The upper and lower limits on the maturity structure of fixed rate borrowing will be:
|
Upper |
Lower |
Under 12 months |
100% |
100% |
12 months and within 24 months |
100% |
0% |
24 months and within 5 years |
100% |
0% |
5 years and within 10 years |
100% |
0% |
10 years and above |
100% |
100% |
Time periods start on the first day of each financial year. The maturity date of borrowing is the earliest date on which the lender can demand repayment
4.3 End of year investment report
At the end of the financial year, the Council will report on its investment activity as part of its Annual Treasury Report as previously stated within 1.2.
4.4 Other Items
It is a requirement of the Prudential Code of Practice for Treasury Management that authorities have a policy on the use of financial derivatives. Local authorities have previously made use of financial derivatives embedded into loans and investments both to reduce interest rate risk (e.g. interest rate collars and forward deals) and to reduce costs or increase income at the expense of greater risk (e.g. LOBO loans and callable deposits). The general power of competence in Section 1 of the Localism Act 2011 removes much of the uncertainty over local authorities’ use of standalone financial derivatives (i.e. those that are not embedded into a loan or investment).
The council will only use standalone financial derivatives (such as swaps, forwards, futures and options) where they can be clearly demonstrated to reduce the overall level of the financial risks that the Authority is exposed to. Additional risks presented, such as credit exposure to derivative counterparties, will be taken into account when determining the overall level of risk. Embedded derivatives, including those present in pooled funds and forward starting transactions, will not be subject to this policy, although the risks they present will be managed in line with the overall treasury risk management strategy.
Financial derivative transactions may be arranged with any organisation that meets the approved investment criteria. The current value of any amount due from a derivative counterparty will count against the counterparty credit limit and the relevant foreign country limit.
This strategy is compiled in accordance with the current Treasury Management Code of Practice , however due to the consultation in relation to the proposed changes to the Prudential Framework of Capital Finance, an amended report may be presented to the Audit, Governance & Standards Committee for scrutiny during 2018. It is predicted that the results of the consultation will be circulated in January 2018.