Hampshire County Regional Investment Regulations

PERAC Approval Date

Regulation Number

Supplemental Investment Regulation

January 5, 2012   The HCRB may forego the normal procurement process for an investment related service (840 CMR 16.08) and transfer assets from the Mellon Capital Management EB Daily Valued Global Alpha I Fund into the Mellon Capital Management EB Daily Valued Expanded Alpha I Fund.

March 23, 2011 16.08

In accordance with Investment Guideline 99-3, the Hampshire County Retirement Board is authorized to invest in Ascent Venture Partners V.  The Board has been a satisfied investor in Ascent’s two predecessor partnerships. The management team and strategy remain the same. The Board has submitted updated regulatory documents as well as financial data pertaining to its existing investments.

September 16, 2010 16.04

The Hampshire County Retirement Board is granted an exemption from 840 CMR 16.04 which requires the board to designate a custodian bank to hold all its investment assets.  This exemption reflects the following facts:  1) the Board now invests totally in commingled investment funds and 2) the Board has an experienced staff that has already been performing cash management functions in-house and is in the process of implementing an in-house accounting and tracking system.

This supplemental regulation supersedes the one previously approved on March 26, 2004 and which is hereby revoked.

This supplemental regulation is subject to revision or cancellation if and when the Board reverts to one or more separate account investment mandates.

While retirement boards are expected to use fiduciary judgment in the management of cash reserves, PERAC does not generally request information on the selection of specific vendors of cash management services.

August 15, 2008  

Notwithstanding the provision of the Code of Massachusetts Regulation 840 CMR 21.01(2), (3)(a) & (b), (4)(a) & (b), and (5), the Hampshire County Retirement System through its duty constituted Retirement Board may invest funds of the Retirement System in the fund known as Shenkman Capital Management, Inc., General Partner of Credos Floating Rate Fund, L.P.

Shenkman Capital Management, Inc., General Partner of Credos Floating Rate Fund, L.P., shall not be subject to the existing provisions of 840 CMR 21.01(2), (3)(a) & (b), (4)(a) & (b), and (5), but shall be subject to the prohibited investment provisions under ERISA guidelines.

The prohibited investment provisions that apply to the Shenkman Capital Management, Inc., General Partner of Credos Floating Rate Fund, L.P., portfolio shall be defined relying upon ERISA statutory exemptions and the administrative class exemptions and regulations, specifically QPAM Exemption 84-14, as amended (“PTCE 84-14”), Prohibited Transaction Class Exemption 91-38 (“PTCE 91-38”) issued by the Department of Labor and other ERISA applicable regulations.

August 15, 2008  

Notwithstanding the provision of the Code of Massachusetts Regulation 840 CMR 21.01(2), (3)(a) & (b), (4)(a) & (b), and (5), the Hampshire County Retirement System through its duty constituted Retirement Board may invest funds of the Retirement System in the fund known as Primus High Yield Bond Fund, L.P. Shenkman Capital Management, Inc., General Partner.

Primus High Yield Bond Fund, L.P. Shenkman Capital Management, Inc., General Partner, shall not be subject to the existing provisions of 840 CMR 21.01(2), (3)(a) & (b), (4)(a) & (b), and (5), but shall be subject to the prohibited investment provisions under ERISA guidelines.

The prohibited investment provisions that apply to the Primus High Yield Bond Fund, L.P. Shenkman Capital Management, Inc., General Partner, portfolio shall be defined relying upon ERISA statutory exemptions and the administrative class exemptions and regulations, specifically QPAM Exemption 84-14, as amended (“PTCE 84-14”), Prohibited Transaction Class Exemption 91-38 (“PTCE 91-38”) issued by the Department of Labor and other ERISA applicable regulations.

August 16, 2007

21.01(2)(3)(4)(5)

Notwithstanding the provisions of any statute or regulations of the Public Employee Retirement Administration Commission to the contrary, including the provisions of 840 CMR 21.01(2)(3)(4) and (5), the Hampshire County Retirement Board is hereby granted an exemption from restrictions on investment and may invest a portion of the funds of the Hampshire County Retirement System (the “System”) in the fund known as the GMO Global Balanced Asset Allocation Fund of Grantham, Mayo, Van Otterloo & Company LLC.

July 20, 2007

21.01(2)(3)(4)(5)

Notwithstanding the provisions of any statute or regulations of the Public Employee Retirement Administration Commission to the contrary, including the provisions of 840 CMR 21.01(2)(3)(4) and (5), the Hampshire County Retirement Board is hereby granted an exemption from restrictions on investment and may invest a portion of the funds of the Hampshire County Retirement System (the “System”) in the fund known as the EB Daily Valued Global Alpha I Fund of Mellon Capital Management Corporation.

July 20, 2007

21.01(2)(3)(4)(5)

Notwithstanding the provisions of any statute or regulations of the Public Employee Retirement Administration Commission to the contrary, including the provisions of 840 CMR 21.01(2)(3)(4) and (5), the Hampshire County Retirement Board is hereby granted an exemption from restrictions on investment and may invest a portion of the funds of the Hampshire County Retirement System (the “System”) in the fund known as the PIMCO All Asset Fund.

January 12, 2004

16.08

In accordance with PERAC Investment Guideline 99-3, the Hampshire County Retirement Board is authorized to invest in Ascent Venture Partners IV, L.P.  The board has been a satisfied investor in Ascent Venture Partners III and has submitted updated regulatory documents pertaining to its current and future investments with Ascent.