Watertown Investment Regulations

PERAC Approval Date

Regulation Number

Supplemental Investment Regulation

May 12, 2011 17.04(3)(b), 21.01(1)-(6)

The Watertown Retirement Board is authorized to invest in the Brandywine Global Opportunistic Fixed Income Fund.  Since the Fund is an institutional mutual fund, the portfolio manager’s investment recommendations and actions are made on behalf of the Fund in its entirety and not on behalf of any specific shareholder.  Thus, 840 CMR 17.04(3)(b) does not apply to this investment.  To the extent that the Fund may use forward currency contracts in legitimate hedging strategies involving more than 25% of non-dollar portfolio holdings, to the extent that the Fund may use futures contracts as part of duration hedging strategies, and to the extent that the Fund may own a currency forward unrelated to an underlying portfolio holding as a result of limitations in certain markets, the provisions of 21.01(1)-(6) do not apply to this investment.

November 5, 2010 17.04(3), 21.01(1)-(6)

The Watertown Retirement Board is authorized to invest in the MFS Institutional International Equity Fund.  Since the Fund is an institutional mutual fund, the portfolio manager’s investment recommendations and actions are made on behalf of the fund in its entirety and not on the behalf of any specific shareholder.  Therefore, with reference to recommendations made or actions taken on behalf of a retirement board, the provisions of 17.04(3) do not apply.  Since the Fund’s prospectus permits the use of futures contracts and options in the implementation of its basic investment strategy and also permits purchases on margin and purchases of restricted stock, the Fund is exempt from the provisions of 21.01(1) (2) (3) (4) (5) and (6).

September 16, 2010 21.01(2)-(5)

The Watertown Retirement Board is authorized to invest in the BlackRock Global Allocation Fund.  This fund may employ shorting strategies up to 20% of its total portfolio market value and may also use futures, options, and other derivatives in the execution of its basic portfolio strategy.

April 1, 2002

16.08

In accordance with Investment Guideline 99-2, the Watertown Retirement Board is authorized to modify its domestic fixed income mandate with Income Research & Management from a separate account structure to a commingled fund, the IRM Commingled Bond Fund.  This change is intended to achieve operational efficiencies and involves no change in investment strategy.

July 26, 2000

16.08

In accordance with PERAC Investment Guideline 99-2, the Watertown Retirement Board may modify its investment contract with Hutchens Management Company to allow investment in mid cap equities.  The board has had a satisfactory relationship with Hutchens as its domestic large cap manager.  In recognition of Hutchens’ strong performance results for mid cap equities, the Board believes that expanding its mandate to include mid caps is an appropriate way to achieve their asset allocation goals.