Independent Evaluation · RFP 902732 · FY2020–FY2026
A six-year, source-verified review of the Treasurer's Investment Pool — performance against benchmark, portfolio composition, governance, reporting transparency, and the County's proposed Ethical Investment Policy — benchmarked against pools nationwide.
The pool at a glance
Sources: Alameda County Treasurer monthly investment reports (Mar 2026) and FY2024 audited financial statements (MGO CPAs). Policy WAM cap of 3 years (1,095 days) per the 2024 Investment Policy.
Performance & benchmark
The pool's book yield climbed from under 1% to 4.18%. But book yield is an accounting figure: it trailed the County's own benchmark by 54–84 bps in FY2023–FY2024, and it can't show the mark-to-market reality underneath. The number that would — a true total return — is published by neither Alameda nor any peer pool we surveyed.
Fiscal year-end (June 30). Yields in %. Benchmark = the County's stated ICE BofA Treasury composite; values plotted here FY2020–FY2024.
To its credit, Alameda reports relatively well — book yield, yield-to-maturity, effective duration, weighted-average maturity, unrealized gain/loss, NAV, and credit quality. But across all seven peer pools we surveyed, not one publishes a true total return — income plus price change — against a named index. What's labeled "rate of return" is a book-basis figure. CDIAC itself draws the line between a book-yield portfolio (what Alameda runs) and a total-return portfolio; the economic number the Board needs to see is the one that's missing.
This is the single largest gap between public-pool reporting and investment-manager-grade reporting — and exactly what an independent evaluation should close.
Portfolio composition
Federal agencies peaked at 58.3% of the pool in FY2024 and have eased to 49.5% by March 2026 as corporates rose to 16.9% and new sleeves (CMBS/MBS, a fixed-income JPA) appeared. Weighted-average maturity extended from a defensive 473 days (FY2023) to 842 days — still well inside the 3-year policy cap.
Source: Alameda County Treasurer monthly investment reports, FY2020–Mar 2026.
% of pool by fiscal year-end
% of pool by issuer — audited
Concentration & credit
As of June 30, 2024, Federal Home Loan Bank alone was 45.98% of the pool — policy-compliant (agencies may run to 100%), but a textbook diversification discussion. By March 2026 that single-issuer concentration had eased to ~25% as the book diversified. Credit quality is uniformly high (AA+/Aaa agencies, A-or-better corporates), consistent with a safety-first mandate.
Source: FY2024 audited financial statements, Note 3 (concentration of credit risk).
National benchmarking
We assembled a source-verified comparison set: every major California county pool plus eleven of the largest state and local government investment pools nationwide. Two things stand out — Alameda runs one of the longest durations of any large county pool, and it is one of the few without a consistent, market-based benchmark in its public reporting.
Each bubble is a county pool: horizontal = weighted-average maturity (days); vertical = reported book yield (%); bubble area ∝ assets under management. Latest available reports.
| Government investment pool | State | AUM ($B) | Yield % | Rating | Manager | ESG policy |
|---|
Alameda (highlighted) is a longer-duration county operating pool — not a money-market LGIP — so its higher book yield reflects the extra duration and credit risk it carries, not outperformance. Yields are the latest published 7-/30-day or book yields and are not strictly like-for-like across pool types; shown for scale. Sources: each pool's official fact sheet / disclosure and S&P Global Ratings.
Governance & advisory structure
For California county pools above ~$10B, in-house management with a statutory Treasury Oversight Committee and an annual independent audit is the dominant model — Los Angeles, San Diego, Riverside, San Bernardino, Sacramento, and Alameda all manage in-house. External advisors appear in only two cases in our set: Santa Clara (Meeder) and Orange County — and Orange only after a 2024 governance crisis transferred investment authority out of the Treasurer's office.
The entire California oversight framework — Gov. Code §§27130–27137 — exists because of Orange County's 1994 bankruptcy. That history is the reference point for any governance recommendation here.
Sources: county investment reports & ACFRs; Voice of OC (Feb 2025); CA Gov. Code §§27130–27137. Advisory fees typically 10–35 bps.
The benchmark question
To its credit, the County does show a benchmark: the ICE BofA 0-3yr and 0-5yr US Treasury indices, plotted against the portfolio monthly since 2015. Three things undercut it as a true performance yardstick — it's shown as 18- and 30-month moving averages (which can't be held as a portfolio), the Treasury-only indices don't match an agency- and corporate-heavy pool, and the County compares its book yield to them rather than total return against total return.
"The County does not manage the portfolio to a specific benchmark; rather, benchmarks are used to show the County is earning a market rate of return over a period of time."— County of Alameda monthly investment report, March 2026, p.4 (verbatim)
GFOA, the CFA Institute (SAMURAI), and GIPS all call for a benchmark that is investable, composition-matched, total-return-based, and one the manager is accountable to. Best-in-class California peers (Santa Clara, Sacramento, Spokane) report total return against a duration-matched index.
Sources: County of Alameda monthly report (Mar 2026, p.4); GFOA "Using Benchmarks to Assess Portfolio Risk and Return"; CFA Institute & GIPS 2020; CDIAC reporting guides.
The Ethical Investment Policy
In October 2025 the Board approved (but froze, pending this peer review) an Ethical Investment Policy screening issuers that derive more than 10% of revenue from oil/gas/coal, firearms, tobacco, casinos, correctional facilities, distillers, or defense. If implemented, it would be among the most expansive ethical screens ever adopted for a U.S. public operating pool.
Share of the pool exposed to the EIP's sector screens
~90% of the pool — U.S. Treasuries, federal agencies, supranationals, and bank CDs — is structurally outside the screened sectors. The policy bites only on the corporate slice (~$1B). Treasurer Levy stated he does not expect a lower yield.
Operating-fund precedent is vanishingly rare
Across all 50 state LGIPs and every county pool we surveyed, formal ESG/ethical screening of an operating pool exists in just three places — and where measured, the return impact was reported as negligible.
| Entity | Adopted | Reported impact |
|---|
Sources: LA County, Multnomah County, City of Portland policies; Oaklandside/KQED (Oct 2025); Friede-Busch-Bassen (2015); MSCI; World Bank/GPIF (2018).
Innovation & forward practice
An independent evaluation shouldn't stop at "is the pool well-run?" It should ask "what does best-in-class look like now, and what's within reach?" We surveyed the most innovative practices in public fixed-income today — each already in use at a named public fund — and mapped every one to Alameda's exact mandate: safety first, ≤3-year maturity, investment-grade only, no leverage or derivatives, fully within Government Code §53601.
| Innovation | Public funds already doing it | Fits §53601, no added risk? |
|---|---|---|
| Two-portfolio structure — a liquidity sleeve plus a longer "core" managed for total return | Fairfax County (VA); City of San Diego; Oregon Short-Term Fund | Yes — structure only |
| Total-return management vs. a market index — the core measured on income + price against a duration-matched benchmark | San Diego (vs. ICE BofA 1-3yr Treasury); Palo Alto; Chandler-managed CA agencies; Florida Intermediate Duration | Yes — measurement only |
| GIPS-compliant, total-return performance reporting | CalPERS (asset-owner GIPS-verified, incl. its §53601 STIF); Pennsylvania Treasury (first U.S. state treasury); Chandler (verified since 1997) | Yes — reporting standard |
| Weekly shadow-NAV & liquidity-coverage stress testing (S&P AAAm template) | Virginia LGIP; 40+ S&P-rated pools (TexPool, COLOTRUST, Florida PRIME) | Yes — analytics overlay |
| OAS / key-rate-duration analytics on the callable-agency book | GFOA best practice; platforms at Chandler, Clearwater for Pooled Funds, BlackRock Aladdin | Yes — analytics only |
| Public open-data transparency dashboard | Illinois Treasurer ("The Vault"); Washington State LGIP — and this portal | Yes — disclosure only |
| Sustainability tilt without divestment — Sustainalytics scoring as a tiebreaker; labeled green/social supranationals | LA County; Santa Clara; San Diego; San Francisco; CA PMIA (World Bank green bonds); Nuveen impact IG | Yes — within IG / §53601(q) |
| Community-impact & linked deposits at local banks, MDIs, and CDFIs (collateralized / FDIC-insured) | SF Treasurer local-bank CD program; CA State Treasurer Time-Deposit / CDFI program | Yes — §53601(f), collateralized |
Sources: each fund's official disclosures, fact sheets, and policies; GFOA "Managing Market Risk in Investment Portfolios"; S&P Global AAAm surveillance; CDIAC; CFA Institute / GIPS 2020. Full citations in the engagement report.
Six moves that advance performance, transparency, and the County's stated values without changing its safety-first, ≤3-year, investment-grade risk posture. Each is an option for the Board to weigh — not a criticism of a pool that already reports above the norm.
Carve the pool into a liquidity sleeve sized to participant cash needs and a "core" sleeve managed and measured on total return vs. the ICE BofA 0-3yr Treasury index. Fairfax and San Diego run exactly this. An investment-policy amendment — no new instruments, no higher duration ceiling.
Report a mark-to-market total return against a duration-matched index each quarter, and move toward GIPS-aligned presentation — following Pennsylvania Treasury and CalPERS. Closes the single biggest reporting gap we found, at zero portfolio cost.
Adopt the Virginia LGIP / S&P template — a weekly market-value NAV plus a published "days-of-liquidity under stress" coverage figure. A pure analytics overlay that strengthens the safety-and-liquidity mandate.
Pair the EIP's negative screens with a positive tilt — labeled green/sustainable supranationals inside the existing IBRD/IFC allocation (the CA PMIA model) and collateralized deposits at local / MDI / CDFI banks (the SF / CA-STO model). Advances the County's values at no credit or duration cost.
Productize this very portal — machine-readable holdings, total-return-vs-index, and a real-time EIP screening & tracking-error monitor. Illinois's "Vault" sets the transparency precedent; a live EIP-impact tracker would be genuinely first-in-nation.
Apply option-adjusted-spread and key-rate-duration analysis to the callable-agency holdings (GFOA best practice; standard in Clearwater / Aladdin). Sharper risk capture and better relative-value execution — same instruments, same limits.
None requires a new asset class, more duration, leverage, or any departure from investment-grade safety. They are innovations in structure, measurement, transparency, execution, and impact — the dimensions where a well-run book like Alameda's can still move from good to best-in-class. Surfacing exactly that is the value of an independent evaluation.
How House Strategies Group would deliver
This portal is a preview of the work itself — every claim sourced, every metric traceable. Our engagement turns it into a complete, defensible evaluation.
Six+ years of holdings, yields, and reporting — independently rebuilt from primary sources, not the County's summaries.
Total-return performance against a duration-matched, investable index, plus a national peer cohort by size, structure, and objective.
Oversight structure, advisory model, and the transparency of what reaches the Board — measured against GFOA and CDIAC best practice.
Quantify the EIP's real reach and return impact against the actual book, with screening, monitoring, and implementation methodology.
A written report and a Board of Supervisors presentation — practical, implementable, and built to withstand public scrutiny.
Prepared by House Strategies Group in support of County of Alameda RFP 902732 — Treasury Pool Evaluation Services. Fiduciary, independent, and grounded entirely in the public record.
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