Southbridge 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 Southbridge Retirement Board may invest funds of the Retirement System (the “System”) in the fund known as the Institutional Retirement Trust (IRT) International Equity 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.

February 14, 2007

17.03

Notwithstanding the provisions of the Public Employee Retirement Administration Commission regulations, the Southbridge 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.

February 13, 2007

 

Notwithstanding the provisions of the Public Employee Retirement Administration Commission regulations, the Southbridge Retirement Board may invest funds of the Retirement System (the “System”) in the fund known as INVESCO Core Real Estate USA, LLC (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 assets of the System shall be deemed to include, for purposes of applying the rules set forth in 840 CMR 16.00 et seq. and 17.00 et seq., the System’s interest in the Fund but not any of the underlying assets of the Fund; provided that, at all times, the Fund qualified as a “venture capital operating company” within the meaning of the Employee Retirement Income Security Act of 1974, as amended, and the regulations promulgated thereunder.

January 11, 2006

16.08

In accordance with Investment Guideline 99-2, the Southbridge Retirement Board is authorized to make a minor modification to its large cap equity mandate with Freedom Capital Management Company.  The Board will supplement its existing investments in Freedom Capital’s Large Cap Growth Fund, Large Cap Value Fund, and Equity Style Fund with an allocation to Freedom Capital’s “Style-Weighted Concentrated Fund”.  This fund invests in the same large cap universe as the existing funds and has the same benchmark as the Equity Style Fund, but has a more concentrated portfolio that represents Freedom’s best ideas for both growth and value stocks.

October 23, 2003

16.08

In accordance with PERAC Investment Guideline 99-2, the Southbridge Retirement Board is authorized to make a minor modification to its fixed income mandate with Freedom Capital Management Company.  The board will change from the Core Portfolio to the Core Plus Opportunistic Portfolio, offering the Board limited exposure to high yield and international bonds when the manager sees value in these sectors.

Also under that Guideline, the Board is modifying its large cap equity mandate with Freedom Capital.  Under the board’s current investment, the Equity Style Fund, the board has predominant exposure to either large cap growth or large cap value stocks.  Under the new “Core Equity Management” product, the investment universe, portfolio management team, and benchmark remain unchanged but the board will have greater diversification between growth and value and, therefore, less portfolio volatility over time.