{
  "code": "CDA",
  "title": "Other Revenues: Investments",
  "description": "This policy governs how Conroe ISD invests district funds, including the requirement that investments comply with the Public Funds Investment Act. It outlines registration requirements for brokers, dealers, and distributors of investment pools, including registration with the Texas State Securities Board, SIPC/FINRA, and the Municipal Securities Rulemaking Board (MSRB).",
  "last_action_date": "2025-11-18",
  "last_action_result": "adopted",
  "timeline_local": [
    {
      "date": "2025-11-18",
      "school_year": "2025-2026",
      "action": "adopted",
      "result": "adopted",
      "summary": "This update to Conroe ISD's CDA (Local) investment policy adds two new requirements: (1) a statement that District funds shall be invested in accordance with the Public Funds Investment Act, and (2) a requirement that distributors of investment pools be registered with the Texas State Securities Board, SIPC/FINRA, and also be a registrant in good standing with the Municipal Securities Rulemaking Board (MSRB).",
      "changes_added": [
        "Funds of the District shall be invested in accordance with the Public Funds Investment Act.",
        "and of distributors of investment pools",
        "Distributors of investment pools shall also be a registrant in good standing with the Municipal Securities Rulemaking Board (MSRB)."
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2025-11-18_regular",
      "confidence": "high",
      "source_redline": "CDA_LOCAL.pdf",
      "notes": "Red underlined text was clearly identifiable on pages 3 and 5. No red strikethrough (removed) text was found in the document. The addition on page 5 inserts \"and of distributors of investment pools\" into an existing sentence about broker/dealer registration requirements, and adds a new sentence requiring MSRB registration for distributors of investment pools.",
      "compliance_assessment": {
        "classification": "Locally Discretionary",
        "elements": [
          {
            "element": "District funds shall be invested in accordance with the Public Funds Investment Act",
            "classification": "Locally Discretionary",
            "statutory_basis": "Texas Government Code § 2256.005 (cited but no verbatim quote provided in statute analysis)",
            "supporting_quote": "None",
            "verification_method": "unverified",
            "litigation_status": "None identified",
            "local_additions": "District adopted a policy statement affirming PFIA compliance; the statute analysis contains no verbatim requirement text to ground a 'Required by Law' classification under the grounding rule"
          },
          {
            "element": "Distributors of investment pools must be registered with Texas State Securities Board and SIPC/FINRA",
            "classification": "Locally Discretionary",
            "statutory_basis": "Texas Government Code § 2256.016 (cited but no verbatim quote provided in statute analysis)",
            "supporting_quote": "None",
            "verification_method": "unverified",
            "litigation_status": "None identified",
            "local_additions": "District imposed registration requirements for investment pool distributors with the Texas State Securities Board and SIPC/FINRA; no supporting statutory quote exists in the provided statute analysis to establish compulsion or express permission"
          },
          {
            "element": "Distributors of investment pools must be registrants in good standing with the Municipal Securities Rulemaking Board (MSRB)",
            "classification": "Locally Discretionary",
            "statutory_basis": "Texas Government Code § 2256.016 (cited but no verbatim quote provided in statute analysis)",
            "supporting_quote": "None",
            "verification_method": "unverified",
            "litigation_status": "None identified",
            "local_additions": "District added an MSRB good-standing requirement for investment pool distributors beyond any language found in the statute analysis; this represents a locally chosen standard not grounded in a verified statutory quote"
          }
        ],
        "statute_retrieval": "low_confidence"
      },
      "compliance_summary": [
        "PFIA Compliance Statement: The updated policy adds a statement that District funds will be invested following the Public Funds Investment Act (Texas Government Code § 2256.005). The District chose to include this language as a formal policy commitment, rather than being required to do so by the statute itself.",
        "Investment Pool Distributor Registration: The policy now requires that distributors of investment pools be registered with the Texas State Securities Board and SIPC/FINRA, referencing Texas Government Code § 2256.016. This registration requirement reflects a standard the District selected on its own, as no verified statutory language was found that specifically compels or permits this exact requirement.",
        "MSRB Good Standing Requirement: The policy also requires that investment pool distributors be in good standing with the Municipal Securities Rulemaking Board (MSRB), referencing Texas Government Code § 2256.016. This is an additional standard the District added beyond what the cited statute was confirmed to require or expressly allow.",
        "Overall Classification: All three changes in this policy update are classified as Locally Discretionary, meaning the District made these additions based on its own judgment rather than a direct state law mandate. No litigation related to any of these provisions was identified."
      ]
    },
    {
      "date": "2025-10-21",
      "school_year": "2025-2026",
      "action": "first_reading",
      "result": "first_reading",
      "summary": "This update to Conroe ISD's CDA (Local) Investment Policy adds a sentence requiring District funds to be invested in accordance with the Public Funds Investment Act, and expands broker/dealer registration requirements to include distributors of investment pools, who must also be registered with the Municipal Securities Rulemaking Board (MSRB).",
      "changes_added": [
        "Funds of the District shall be invested in accordance with the Public Funds Investment Act.",
        "and of distributors of investment pools",
        "Distributors of investment pools shall also be a registrant in good standing with the Municipal Securities Rulemaking Board (MSRB)."
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2025-10-21_regular",
      "confidence": "high",
      "source_redline": "CDA_LOCAL.pdf",
      "notes": "Red underlined text was clearly identifiable on pages 3 and 5. No red strikethrough (removal) text was detected anywhere in the redline document. The cover page title reads \"Discuss Revisions to Board Policy CDA (Local)\" indicating a first reading."
    }
  ],
  "timeline_legal": [],
  "policy_connect_url": "https://policyconnect.org/policy/conroe-isd/CDA"
}