Investments Regulation

Authorized Investments


The District Treasurer is authorized to invest all available district funds, including proceeds of obligations and reserve funds, in the following types of instruments:


  • Savings Accounts or Money Market accounts of designated banks;
  • Certificates of Deposit issued by a bank or trust company located in and authorized to do business in New York State
  • Demand deposit accounts in a bank or trust company located in and authorized to do business in New York State
  • Obligations of New York State
  • Obligations of the United States government (US Treasury Bills and Notes)




All investments made pursuant to this investment policy will comply with the following conditions:


  1. Collateral
    1. Savings accounts, money market accounts, time deposit accounts and certificates of deposit will be fully secured by insurance of the Federal Deposit Insurance Corporation or by obligations of New York State, the United States, New York State school districts and federal agencies whose principal and interest are guaranteed by the United States. The market value of collateral will at all times exceed the principal amount of the certificate of deposit. Collateral will be monitored no less frequently than on a monthly basis.
    2. Collateral will not be required with respect to the direct purchase of obligations of New York State, the United States and federal agencies, the principal and interest of which are guaranteed by the United States Government
  2. Delivery of Securities

Payment of funds may only be made upon receipt of collateral or other acceptable form of security, or upon the delivery of government obligations whether such obligations are purchased outright, or pursuant to a repurchase agreement. Written confirmation of delivery shall be obtained from the custodial bank.

  1. Written Contracts

Written contracts are required for certificates of deposit and custodial undertakings. With respect to the purchase of direct obligations of U.S., New York State, or other governmental entities in which monies may be invested, the interests of the school district will be adequately protected by conditioning payment on the physical delivery of purchased securities to the school district or custodian, or in the case of book-entry transactions, on the crediting of purchased securities to the Custodian’s Federal Reserve System account. All purchases will be confirmed promptly in writing to the school district.

  1. Designation of Custodial Bank
    1. The Board will designate a commercial bank or trust company authorized to do business in the State of New York to act as Custodial Bank of the school district’s investments. However, securities may not be purchased through a Repurchase Agreement with the Custodial Bank.
    2. When purchasing eligible securities, the seller will be required to transfer the securities to the district’s Custodial Bank.
  2. Selection of Financial Institutions
    1. The District Treasurer will periodically monitor, to the extent practical but not less than annually, the financial strength, credit-worthiness, experience, size and any other criteria of importance to the district, or all institutions and trading partners through which the district’s investments are made.
    2. Investments in time deposits and certificates of deposit are to be made only with commercial banks or trust companies, as permitted by law.
  3. Operations, Audit, and Reporting
    1. The District Treasurer will authorize the purchase and sale of all securities and execute contracts for investments and deposits on behalf of the school district. Oral directions concerning the purchase or sale of securities will be confirmed in writing. The school district will pay for purchased securities upon the simultaneous delivery or book-entry thereof.
    2. The school district will encourage the purchase and sale of securities through a competitive process involving telephone solicitation for at least three quotations.
    3. Monthly investment reports will be furnished to the Board of Trustees.



Adoption date:           August 21, 2013


The objectives of the district’s investment policy are to safeguard district funds and to minimize risk, to ensure that investments mature when cash is required to finance operations, and to ensure a competitive rate of return. In accordance with this policy, the District Treasurer is authorized to invest and/or deposit all funds, including proceeds of obligations and reserve funds, in time-deposit accounts, certificates of deposit, short-term government securities or other investment instruments permitted by law, subject to the investment regulations approved by the Board of Trustees.

To the extent feasible, investments and deposits shall be made in and through local or regional financial institutions. Concentration of investments in a single financial institution should be avoided. Diversification of investments and deposits is encouraged.

This policy will be reviewed annually by the Board and may be amended from time to time in accordance with the provisions of section 39 of the General Municipal Law.

Ref: Education Law §§1604-a; 1723-a; 3651; 3652
Local Finance Law §§24.00, 25.00, 165.00
General Municipal Law §§6(d), 6(j); 6(l-n, p, r); 10; 11; 39

Adoption date: August 21, 2013

Code of Ethics


General Provisions
Pursuant to the provisions of General Municipal Law Section 806, the Board of Education of the Wainscott Common School District recognizes that there are rules of ethical conduct for members of the Board and employees of the District that must be observed if a high degree of moral conduct is to be obtained in our unit of local government. It is the purpose of this resolution to promulgate these rules of ethical conduct for the Board members and employees of the District. These rules shall serve as a guide for official conduct of the Board members and employees of the District. The rules of ethical conduct of this resolution, as adopted, shall not conflict with, but shall be in addition to any prohibition of General Municipal Law Article Eighteen or any other general or special law relating to ethical conduct and interest in contracts of Board members and employees.

Standards of Conduct
Every Board member or employee of the Wainscott Common School District shall be subject to and abide by the following standards of conduct:


Pursuant to General Municipal Law Section 805-a, he/she shall not, directly or indirectly, solicit any gift or accept or receive any gift having a value of seventy-five dollars ($75) or more, whether in the form of money, services, loan, travel, entertainment, hospitality, thing or promise, or any other form, under circumstances in which it could reasonably be inferred that the gift was intended or expected to influence him/her in the performance of official duties or was intended as a reward for any official action on his/her part.

Confidential Information
He/she shall not disclose confidential information acquired by him/her in the course of his/her official duties or use such information to further his/her personal interest.

Disclosure of Interest in Contracts
Any District officer or employee, as well as his/her spouse, who has, will have, or later acquires an interest in any actual or proposed contract, purchase agreement, lease agreement or other agreement, including oral agreements, with the District shall publicly disclose the nature and extent of such interest in writing to his/her immediate supervisor and to the Board of Education as soon as he/she has knowledge of such actual or prospective interest. Such written disclosure shall be made part of and set forth in the Board minutes.

Representation before one’s own agency
He/she shall not receive, or enter into any agreement, express or implied, for compensation for services to be rendered in relation to any matter before any municipal agency of which he/she is an officer, member or employee or of any municipal agency over which he/she has jurisdiction or to which he/she has the power to appoint any member, officer or employee.

Representation before any agency for a contingent fee
He/she shall not receive, or enter into any agreement, express or implied, for compensation for services to be rendered in relation to any matter before any agency of his/her municipality, whereby his/her compensation is to be dependent or contingent upon any action by such agency with respect to such matter, provided that this paragraph shall not prohibit the fixing at any time of fees based upon the reasonable value of services rendered.

Disclosure of interest in resolution
To the extent that he/she knows thereof, a member of the Board of Education or employee of the Wainscott Common School District, whether paid or unpaid, who participates in the discussion or gives official opinion to the Board of Education on any resolution before the Board of Education shall publicly disclose on the official record the nature and extent of any direct or indirect financial or other private interest he/she has in such resolution.

Investments in conflict with official duties
He/she shall not invest or hold any investment directly or indirectly in any financial, business, commercial, or other private transaction, that creates a conflict with his/her official duties.

Private employment
He/she shall not engage in, solicit, negotiate for or promise to accept private employment or render services for private interests when such employment or service creates a conflict with or impairs the proper discharge of his/her official duties.

Future employment
He/she shall not, after the termination of service or employment with the School District, appear before any board or agency of the Wainscott Common School District in relation to any case, proceeding, or application in which he/she personally participated during the period of his/her service or employment or which was under his/her active consideration.

Legal Remedies

District Officers
In accordance with the Penal Law 60.27(5), if a District officer is convicted of a violation against the District under Penal Law Article 155 relating to larceny, the courts may require an amount of restitution up to the full amount of the offense or reparation up to the full amount of the actual out-of- pocket loss suffered by the District.

Board Members and Employees
Nothing herein shall be deemed to bar or prevent the timely filing by a present or former Board member or employee of any claim, account, demand or suit against the Wainscott Common School District, or any agency thereof on behalf of himself/herself or any member of his/her family arising out of any personal injury or property damage or for any lawful benefit authorized or permitted by law.

Distribution/Posting of Code of Ethics
The Superintendent of the Wainscott Common School District shall cause a copy of this code of ethics to be distributed to every Board member and employee of the School District within thirty (30) days after the effective date of this resolution. Each Board member and employee elected or appointed thereafter shall be furnished a copy before entering upon the duties of his/her office or employment. The Superintendent shall also cause a copy of General Municipal Law, Article 18, to be kept posted in each building in the District in a place conspicuous to its Board members and employees. Failure to distribute any such copy of this code of ethics or failure of any Board member or employee to receive such copy, as well as failure to post any such copy of General Municipal Law, Article 18, shall have no effect on the duty of compliance with such code or Article 18, nor with the enforcement of provisions thereof.

In addition to any penalty contained in any other provision of law, any person who shall knowingly and intentionally violate any of the provisions of this code may be fined, suspended or removed from office or employment, as the case may be, in the manner provided by law.

Effective Date
This resolution shall take effect immediately
Education Law Section 410
General Municipal Law Article 18 and Section 803 Labor Law 201-d
Penal Law Article 155 and Section 60.27(5)

Petty Cash Account

A $200 petty cash fund shall be established for the school for the purchase of materials, supplies or services under conditions requiring immediate payment. The amount of individual reimbursement from the fund will not exceed fifty (50) dollars unless authorized by the Superintendent of Schools. The Board of Trustees shall appoint a custodian for the petty cash fund who shall administer and be responsible for such fund.

To ensure that the fund is properly managed, the following guidelines shall be followed:

  • Receipts and cash-on-hand must always total the authorized fund amount. All disbursements from the fund are to be supported by receipted bills or other evidence documenting the expenditure.
  • Payments may be made from petty cash for materials, supplies, or services requiring immediate payment. Sales tax on purchases will not be paid by the school district from petty cash funds.

The district shall reimburse uses of petty cash funds up to the extent of expenditures, with appropriate documentary support. The Purchasing Agent shall sign off on all uses of petty cash funds requested by others. The Business Manager shall reimburse the petty cash fund when necessary.

Ref: Education Law §1604(26)
8 NYCRR §170.4

Adoption date: August 21, 2013

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