Salem Investment Regulations

PERAC Approval Date

Regulation Number

Supplemental Investment Regulation

February 14, 2007

17.03

Notwithstanding the provisions of the Public Employee Retirement Administration Commission regulations, the Salem Retirement Board may invest funds of the Retirement System (the “System”) in the fund known as the Institutional Retirement Trust (IRT) Equity Real Estate Securities Trust (the “Fund”), and effective as of the date of the initial investment by the System of any of its assets in the Fund, while the assets of the System are so invested, the activities and investments of the Fund, directly or indirectly, shall be deemed to satisfy the prohibited transaction rules set forth in 840 CMR 16.00 et seq. and 840 CMR 17.03 to the extent such activities satisfy the prohibited transaction rules set forth in Section 406 of the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), taking into account ERISA Section 408(b)(8) as well as other statutory exemptions under ERISA, and Prohibited Transaction Class Exemption 84-14, as amended, Prohibited Transaction Class Exemption 91-38, and other available class exemptions.

September 4, 2003

16.08

In accordance with PERAC Investment Guideline 99-2, the Salem Retirement Board is authorized to make a modest modification to its domestic equity management mandates with Freedom Capital Management.  The Board already has large cap value, large cap growth, and “equity style” mandates with Freedom Capital Management and has voted to make an initial investment in Freedom Capital Management’s Style Weighted Concentrated Fund.  This investment will allow the Board to meet its asset allocation target for large cap equities.  In this new fund, which has the S&P 500 as its benchmark, Freedom Capital Management will select its best ideas on both growth and value stocks out of the large cap universe in which it currently operates.

April 7, 2000

16.08

In accordance with PERAC Investment Guideline 99-2, the Salem Retirement Board may invest in the Freedom Capital Equity Style Fund.  Proceeds will come from 40% of the Board’s current equity account with Freedom Capital Management.  The Style Fund has the same investment strategy and invests in the same universe of stocks as the managed account.  The difference is that it invests in either of two indexes (the S&P Barra Growth Index or the S&P Barra Value Index) rather than in individual securities.  In so doing, management fees and other costs to the Board are reduced.