Deep analysis · House Strategies Group · RFP 902732

The investigation: who owns the pool — and why its total return goes unspoken.

What follows is the analytical core of our work. It is also a story — six weeks of following the evidence from the County's own documents to a conclusion that reframes how the pool should be read.

1
We pulled one thread, and it unravelled the rest. We set out to evaluate performance and immediately hit the gap: the pool reports book yield, not total return. So we reconstructed the total return ourselves — 75 monthly reports, chain-linked. It revealed something the County's reporting never shows: the pool spent nearly three years underwater (2022–2024), bottoming at a −4.1% net asset value in September 2022.
2
Underwater only bites if someone is forced to sell. A paper loss self-heals at maturity — unless withdrawals force a sale into a down market and crystallize it. So the real question became: who could pull money out and force that sale? We built a run-risk simulator to test every timing and magnitude.
3
We went looking for the flight risk. The obvious suspects were the voluntary participants — the cities and agencies who choose to be in the pool and could leave. To size them, we pulled the audited financial statements of all 14 incorporated cities in Alameda County.
4
The surprise: not one city is in the pool. Every Alameda city self-manages its own portfolio and uses the State's LAIF (and CAMP/CalTrust) as its liquidity vehicle — none reports a dollar in the County Treasurer's pool. Combined, these cities hold roughly $7 billion in their own investments and zero in the County's. Cities aren't statutorily required to pool, so they don't. The flight risk we went looking for wasn't there.
5
So who is in it? That sent us back to the FY2024 audited financial statements, where the structure resolves cleanly. The external participants — 46%, about $4.93B — are the captive involuntary entities: school districts, community-college districts, and special districts required by law to deposit with the Treasurer. And the voluntary majority — 54%, about $5.79B, labeled "internal participants" — is defined in the County's own audited statements as "participants from County departments."
6
The voluntary money is the County itself. Confirmed in the audited FY2024 financial statements: "The Treasurer's Pool includes participants from County departments, which are considered internal participants…" with internal-participant equity of $5,787,263 thousand. It triangulates against the County's own Annual Comprehensive Financial Report, which carries the mirror entry — the County's funds' equity in the Treasurer's pool.

Why the total return goes unspoken — the structural answer.

Set the ownership beside the reporting and the gap explains itself. The pool's discretionary owner is the County; everyone else is captive and cannot leave. There is therefore no external, discretionary constituency that would ever demand a mark-to-market total return — the audience that number exists to protect largely doesn't exist in this pool. Book-yield reporting has never been pressured to evolve because the very pressure that forces it — investors who can walk, comparing pools on a total-return basis — isn't present here.

This is not an accusation of concealment. Governmental accounting runs on amortized cost; the hold-to-maturity philosophy is genuine; and over a full cycle, book and total return converge. But the reason the gap has persisted unchallenged is structural: a pool owned by its sponsor and filled out by captives faces none of the market discipline that elsewhere makes total-return disclosure routine.

Which is exactly the void an independent evaluation fills. We supply the outside, mark-to-market discipline the ownership structure otherwise lacks — and the total return we reconstructed is the single most valuable number we can hand the Board, precisely because no one inside the structure was ever obliged to produce it.

The deep work behind this conclusion

The recast engine →

All 401 securities, repriced bottom-up from public data; reproduces the County's own marks to the dollar.
The run-risk simulator →

Model any participant withdrawal at any month; see what the managers must do and who bears the loss under §27136.

Where this led: the EIP gate

The ownership finding reframed the question the County actually convened this review to settle. The Board approved an Ethical Investment Policy in October 2025 and froze it pending this peer review — so our analysis is the gate. We have already begun pricing the policy against the real book.

Open the EIP gate — the real question →

Every holding classified against the three tiers, the runoff design that makes divestment largely loss-free, our methodology and recommendation, and the downloadable recast + EIP-classification workbook.
← Return to the public analysisHouse Strategies Group · Public Funds Advisory · prepared for RFP 902732. Sources: County of Alameda Treasurer monthly reports + FY2024 audited financial statements + the 14 cities' ACFRs.