Director of Investments & Financial Analysis
This investment policy is intended to set forth the framework within which Indiana University’s investment activities are conducted. This investment policy applies to the funds held by or for the benefit of Indiana University.
The Investment Policy (“Policy”) provides the guiding principles for Indiana University (the “University”) to effectively supervise, monitor and evaluate the investment of its financial assets to optimize returns within appropriate risk parameters. The investment program is defined in the various sections of the policy by:
II. Description of the Assets
These funds are referred to collectively as the “Invested Assets”. The actual investment approach and the return objectives will vary for each of these types of funds. The funds will be invested in a manner commensurate with intended use of the funds by Indiana University, and performance benchmarks will be established accordingly. In all cases, the funds will be invested consistent with prudent investor standards.
III. Roles and Responsibilities
The fiduciary responsibilities of the Board of Trustees include, but are not limited to, the following:
– Approve the investment objectives of the IUOF.
– Approve the tiered liquidity structure and broad asset allocation strategy.
– Approve written investment policies consistent with investment objectives of the IUOF.
– Monitor the investment performance of the IUOF to ensure achievement of investment objectives and compliance with policy guidelines.
The purpose of the UIC is to provide tactical oversight of the investment management program and to assure that the policies established by the Board are implemented and adhered to. The Board of Trustees has delegated the following responsibilities to the UIC:
– Approve the manager structure of each investment tier.
– Approve the selection of qualified investment professionals to assist in the implementation of, management of, and advisement on the investment policies of the IUOF.
– Monitor the investment performance of the IUOF investment managers to determine achievement of investment objectives and compliance with policy guidelines.
– Meet with each investment manager of the IUOF as appropriate.
The UIC will be chaired by the University Treasurer and will include the Chief Investment Officer of the IU Foundation and a faculty member from the Kelley School of Business. The UIC will also include, but will not be limited to senior members of the following organizations: Office of the Treasurer, Academic Affairs, & General Counsel. The VPCFO is an ex-Officio member of the UIC. The VPCFO may also appoint membership to qualified external candidates, as appropriate. The Office of the Treasurer will provide staff support for the UIC.
The day-to-day management and oversight of the invested assets are the responsibility of the University Treasurer and the staff of the Office of the Treasurer. These responsibilities include:
– Ongoing communication with the Board, UIC, investment managers, custodian, Investment Consultant, and all other parties within and outside the University that have a portion of the responsibility for managing, safekeeping and accounting for the invested assets.
– Delivering a quarterly review of the performance of all funds for the UIC and the Finance & Audit Committee of the Board of Trustees.
– For the IUOF, IUCF and IUMF, gathering all data through a Request for Information (RFI) process and make recommendations to the UIC with respect to the selection of new investment managers, custodial banks, investment funds and consultants.
– Meeting with investment managers of the IUOF as appropriate. The purpose of each visit is to evaluate that manager’s depth of staff, organization, security, compliance with investment guidelines, performance, outlook and any and all matters which the Office of the Treasurer deems to be consistent with exercise of due diligence with respect to prudent management of the invested assets.
– Maintaining a level of expertise within the Office of the Treasurer subject to available resources that allows the staff to carry out the responsibilities listed herein.
– Any and all other responsibilities as may be deemed necessary by the UIC or the Board with respect to the prudent oversight of the Invested Funds.
– Monitor the investment performance of the IUOF.
– Periodically review compliance with applicable state and federal laws.
– Study issues affecting the investment of the IUOF so as to make educated and prudent decisions in establishing investment policies.
– Manage assets under its care, custody, and/or control in accordance with the guidelines and objectives contained in this policy.
– Exercise investment discretion in regard to buying, managing, and selling assets held in the portfolio, subject to any limitations contained in this policy.
– Communicate with Indiana University and the Investment Consultant in writing regarding all significant and/or material changes pertaining to the portfolio it manages or the firm itself.
– Use the same care, skill, prudence, and due diligence under the circumstances then prevailing that experienced investment professionals acting in a like capacity and fully familiar with such matters would use in like activities with like aims in accordance and compliance with all applicable laws, rules, and regulations, including the State of Indiana.
– Acknowledge and agree in writing as to fiduciary responsibility for full compliance with the entire policy set forth herein, and as modified in the future.
– Report to Indiana University and the Investment Consultant monthly regarding the status of the portfolio and its performance for various time periods.
– Register and retain that registration under the Investment Advisors Act of 1940 and Securities Exchange Commission Acts, unless exempted from registration by the SEC.
An investment consultant (“Investment Consultant”) may be retained by the Treasurer to assist the Board of Trustees, the Vice President and Chief Financial Officer (“VPCFO”), the Treasurer and the staff with the strategic planning, implementation and oversight of the Invested Assets.
The custodian performs functions necessary for the effective management and monitoring of Invested Assets, detailed within the contract between the custodian and Indiana University. These responsibilities include, but are not limited to, safekeeping of assets, trade settlement, collection and receipt of income, maintaining accounting records and performance reporting.
IV. Objectives of the IUOF
The objective of the Investment Policy is to adequately provide for the liquidity needs of the University while maximizing the opportunity to increase total return on investments. Objectives include, but are not limited to, the following:
V. Asset Allocation and Investment Tier Structure for the IUOF
Given the fluctuating balances inherent in an operating fund structure, recommended minimum and maximum balances for Tiers I and II, in dollar amounts, are listed below, designed to ensure liquidity needs are met while balancing the opportunity cost of over-allocating to these tiers:
|Objective||Tier||Investment Style||Minimum Balance||Maximum Balance|
|I||Cash, Active Cash||$300 million||$700 million|
|II||Defensive Fixed Income||$100 million||$300 million|
The total return tiers (Tiers III, IV and V) are the residual assets after the Liquidity Tiers balances have been satisfied. These tiers are less likely to be used for short-term cash flow needs, thus balance fluctuations are more likely to be caused by market movement.
|Total Return Tiers||III & IV||Core Plus & Unconstrained Fixed Income|
∗In September 2017, the University deemed the available assets for the equity investment allocation to be approximately $1 billion. The University will review the maximum allowable allocation on a periodic basis.
VI. Selection of Investment Managers for the IUOF, IUCF and IUMF
The University will follow a process that embodies the principles of procedural due diligence in the selection of investment managers. The University may retain a "prudent expert" (a bank, insurance company, or investment advisor as defined by the Registered Investment Advisors Act of 1940) to facilitate this process.
VII. Monitoring of the IUOF Investment Managers
Indiana University is aware that the ongoing review and analysis of money managers is just as important as the due diligence implemented during the manager selection process. Monitoring these managers will include:
If the UIC determines that any of the above factors, or any other development regarding the manager’s performance or organization, warrants a more thorough examination, the University may place the manager on a formal “watchlist.” The watchlist period will generally be four to six quarters, but the time period can be shorter or longer depending on the factors causing the watchlist. As a result of the watchlisting examination of the investment manager, a recommendation to either replace or retain the manager will be made.
The watchlist is not the only route for removing an existing manager. The aforementioned events, or any other events of concern identified by the University, may prompt the immediate removal of a manager without its first having been watchlisted.
VIII. Securities Lending
To enhance investment income, securities may be made available to securities lending programs. Such programs will require that securities be collateralized at a minimum of 102%, and that the collateral will be valued daily. The managers of such lending programs will maintain current credit analyses of the brokers to whom they lend, and a list of the participating brokers will be submitted for approval to Indiana University. Participation in a lending program will not restrict the portfolio manager from trading securities as he or she deems appropriate.
This policy was established on October 1, 2006.
The investment policy was reviewed and updated in November 2014. No changes were made to core business practices and responsibilities. The table of investment managers was updated in order to reflect recent changes with respect to portfolio rebalancing and the hiring of new investment managers. Certain limitations on asset allocations in tier one and tier two investments were updated in order to better reflect the specific guidelines of the investment management strategies. Finally, there were minor updates to position titles and nomenclature.
The investment policy was updated by the University Investment Committee in September 2017 and approved by the BOT in October 2017.
The investment policy was updated by the University Investment Committee in November 2018 and approved by the BOT in December 2018. The policy was significantly shortened to keep only the strategic aspects in the body of the policy. Most of the tactical/operational aspects were removed from the policy into a separate appendix, which will not be part of the body of the policy.