Subject: S7-08-19
From: David Zweig

December 17, 2019

Subject: File No. S7-08-19 
From: David Zweig, CFA 
Affiliation: Investment Officer
The purchase of private placement securities (144a or 4(2)) requires the buyer to be a Qualified Institutional Buyer (QIB).  The County of Santa Cruz can not currently qualify as a QIB due to the fact that there is not an appropriate category on the QIB form for a municipal investment pool. This omission prohibits the County Investment Pool from purchasing certain private placement securities. The County of Santa Cruz Investment Pool has assets under management ranging from $800 million to $1 billion. It is managed professionally by internal staff.  The County Investment Pool would benefit from being able to purchase private placement securities (144a or 4(2)).
Conclusion: Request that QIB requirements be modified to allow public agencies such as a County to qualify as a Qualified Institutional Buyer.