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Norfolk County Retirement Board Investment Regulations

Regulations accepted by the board and approved by PERAC

PERAC Approval Date: April 25, 2011

Investment/Supplemental Regulation

The Norfolk County Retirement System is authorized to invest in the ArcLight Energy Partners Fund V, L.P.  To the extent that the partnership engages in foreign currency hedging, 21.01 (3) (a & b) will not apply.  To the extent that the partnership engages in other hedging activities central to its investment strategy, 21.01(4) (a – c) will not apply.  To the extent that the partnership engages in hedging activities central to its investment strategy, 21.01(5) will not apply.  Since the partnership may own restricted securities, 21.01(6) will not apply.  To the extent that the partnership engages in activities consistent with private equity management, 21.01(8) will not apply.  To the extent that the partnership may extend loans to the principals of underlying portfolio companies, 21.01(9) will not apply.  21.01(10) applies only to the general partners, not the underlying portfolio companies.

PERAC Approval Date: June 9, 2010

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with Investment Guideline 99-2, the Norfolk County Retirement Board is authorized to make a modest modification to its 130/30 equity management mandate with D.E. Shaw Investment Management Company.  In order to eliminate the role of Goldman Sachs as prime broker/custodian, the Board will transfer assets from its existing separately-managed account to a commingled vehicle with the same process and a similar strategy.  The new fund is the D.E. Shaw U.S. Broad Market Core Alpha Extension Special Fund II.

PERAC Approval Date: April 29, 2009

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with Investment Guideline 99-2, the Norfolk County Retirement System is authorized to make a modification to its existing fixed income management account with Income Research & Management.  As part of a revised asset allocation plan, the System is allocating more money to fixed income and is accomplishing this by adding to the assets under management by IR&M, with whom the System has had a successful relationship for seven years.  The new money will be managed with the same investment universe and benchmark as the existing Core Bond Fund but it will be in a separately managed account in which IR&M has greater flexibility to overweight or underweight particular sectors of the investment grade fixed income market.

PERAC Approval Date: June 2, 2008

Investment/Supplemental Regulation

Regulation Number 21.01(1): The Norfolk County Retirement Board’s investment in D.E. Shaw Investment Management Company’s Domestic Equity 130/30 strategy permits purchases on margin.

Regulation Number 21.01(8): In connection with any margin financing permitted by Supplementary Regulation 21.01(1) or short selling permitted by Supplementary Regulation 21.01(2), the Norfolk County Retirement Board may grant to a lender or broker-dealer providing such margin financing or securities loans a security interest in the assets maintained with such lender or broker-dealer in order to secure the obligations relating to such margin financing or securities lending.

PERAC Approval Date: March 4, 2008

Investment/Supplemental Regulation

Regulation Number 21.01(2): The Norfolk County Retirement Board’s investment in D.E. Shaw Investment Management Company’s Domestic Equity 130/30 strategy permits the portfolio manager to execute short sales in an amount of approximately 30% of the account’s net market value and to purchase additional stocks with the proceeds of these short sales.  Total market exposure will be approximately 1.0.

PERAC Approval Date: November 1, 2007

Investment/Supplemental Regulation

Notwithstanding the provisions of the Public Employee Retirement Administration Commission’s regulations and M.G.L. c. 32, et seq., the Norfolk County Retirement Board may invest funds of the Norfolk County Retirement System (the “System”) in the fund known as Hamilton Lane Co-Investment Fund II, L.P. (the “Fund”), and effective as of the date of the initial investment by the System of any of its assets in the Fund –

  1. while the System holds interest in the Fund, the General Partner may not be subject to the rules as established in 840 CMR 16.00 et seq. and 17.00 et seq. for so long as the Fund does not qualify as a “plan asset” as contemplated by the Employee Retirement Income Security Act of 1974 (“ERISA and as recently amended by the Pension Protection Act of 2006.  The Fund will not be considered a plan asset so long as less than 25% of the equity interest in the Fund is held by “benefit plan investors” as contemplated by ERISA and related amendments.

PERAC Approval Date: September 28, 2007

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with Investment Guideline 99-2, the Norfolk County Retirement Board is authorized to modify its real estate securities mandate with INVESCO by transforming it from a domestic REIT account to a global REIT account.  The investment universe is expanding and the account’s benchmark is changing, but the portfolio management team remains the same, as does the basic strategy and investment process.  The Board and its consultant are comfortable with INVESCO’s capability to run the expanded mandate.

PERAC Approval Date: September 27, 2007

Investment/Supplemental Regulation

Regulation Number 16.08: Notwithstanding the provisions of any statute or regulation to the contrary, specifically including the provisions of 840 CMR 21.01, the Norfolk County Retirement System is hereby granted an exemption from restrictions on investment for the purpose of investing $15 million of the Norfolk County Retirement System’s assets in the Eaton Vance Loan Opportunities Fund, Ltd., a private placement investment.

PERAC Approval Date: June 9, 2005

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with PERAC Investment Guideline 99-3, the Norfolk County Retirement Board is authorized to invest in Prism Venture Partners V, L.P. although meaningful returns are not yet available.  The Board has been a satisfied investor in Prism Venture Partners IV, the predecessor fund, and the management team and basic strategy remains the same.

PERAC Approval Date: March 11, 2005

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with Investment Guideline 99-3, the Norfolk County Retirement System is authorized to invest in Ascend Ventures II.  The System has invested in Ascend Ventures I, with satisfactory results to date, and has submitted the necessary regulatory documents.

PERAC Approval Date: February 1, 2005

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with Investment Guideline 99-2, the Norfolk County Retirement System is authorized to modify its small cap value equity mandate with The Boston Company.  The system has had an existing investment in the TBC Small Cap Opportunities strategy and intends to transfer the assets to the TBC Small Cap Value strategy.  The two strategies invest in the same market universe, have the same benchmark (Russell 2000 Value), and utilize the same research team, but the performance of the Small Cap Value strategy has been less momentum-driven and less volatile than that of the Small Cap Opportunities strategy.  The transfer also affords the Board the benefits of better diversification in portfolio managers, as the manager of the existing account also manages a mid-cap value account for the System.

PERAC Approval Date: December 30, 2003

Investment/Supplemental Regulation

Regulation Number 21.01: For the sole purpose of the Norfolk County Retirement System’s investment in the Mesirow Absolute Return Fund the provisions of 840 CMR 21.01(1), 21.01(2), 21.01(3), 21.01(4), 21.01(5) and 21.01 (6) shall not apply.

PERAC Approval Date: April 8, 2002

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with Investment Guideline 99-2, the Norfolk County Retirement Board is authorized to modify its fixed income mandate with Income Research & Management.  First, in order to achieve operational efficiencies and lower fees, the account is changing from a separately managed account to a commingled fund, the IR&M Core Bond Fund.  The management team and process remain the same.  Second, the investment universe is being modified to focus on intermediate rather than long maturities, consistent with the Board’s asset allocation objectives.  The Board has had a successful relationship with IR&M since 1998 and has great confidence in their fixed income capabilities.

PERAC Approval Date: April 18, 2001

Investment/Supplemental Regulation

Regulation Number 16.08: The Norfolk County Retirement Board (“the Board”) may maintain its current investment on behalf of the Norfolk County Retirement System with a real estate investment fund, as contemplated by 840 CMR 19.01(4)-(6), known as Sentinel Realty Partners Fund IV.  Said investment arising after other prospective real estate managers identified through the competitive bidding process would not agree to the Board’s contract consistent with PERAC requirements, and since the Board already maintained an ongoing relationship with Sentinel.

PERAC Approval Date: April 18, 2001

Investment/Supplemental Regulation

Regulation Number 19.01: The Norfolk County Retirement Board (“the Board”) may maintain its current investment on behalf of the Norfolk County Retirement System with a real estate investment trust fund, as contemplated by 840 CMR 19.01(4)-(6), known as the Corcoran Jennison Apartment Fund, Inc. (“the Fund”).  Said investment subject to further Board action.

PERAC Approval Date: January 25, 2000

Investment/Supplemental Regulation

Regulation Number 16.08: In accordance with PERAC Investment Guideline 99-3, the Norfolk County Retirement Board may invest in the Halpern Denny Fund III, L.P.  The board is an investor in Halpern Denny Fund II, L.P. and has submitted the required supporting documents.  This investment is contingent on the Fund’s continuing compliance with ERISA and its accompanying regulations, including, but not limited to, those setting forth exemptions for plan assets such as a venture capital operating company (“VCOC”).

Contact   for Norfolk County Retirement Board Investment Regulations

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