The EIP gate · House Strategies Group · RFP 902732
A central question: can the Ethical Investment Policy move forward, financially?
This is one of the central questions the County convened the evaluation to weigh, alongside an independent read of the Pool's performance, benchmarking, governance, and reporting, each valuable in its own right. On October 3, 2025 the Board approved an Ethical Investment Policy and then froze it, directing that it not take effect until an independent peer review reports back on its impact. This engagement is that review. On the EIP, the decision turns not on whether the policy is morally right, but on whether it can be implemented without hurting returns or performance.
The policy, in three tiers.
The EIP layers a screen onto the existing policy, strictly subordinate to safety, liquidity, and return: positive, encourage ESG-strong issuers (World Bank, IFC, IADB, CDFIs); discouraged, soft, comply-or-explain, for issuers earning >10% of revenue from oil/gas/coal, firearms, tobacco, casinos, private prisons, alcohol, or defense; and prohibited, hard divest, for enabling severe human-rights violations. It reaches only the ~10% corporate sleeve; roughly 90% of the pool, Treasuries, federal agencies, supranationals, and bank CDs, is structurally outside every screen.
We have already begun the analysis, the bones are in the workbook
The same security-level reconstruction that rebuilt the pool's total return lets us price the policy. We classified every holding against the three tiers, straight from the County's own reports. The first pass is in the "EIP Classification" tab of the workbook below, a tier summary plus all 401 securities scored, with rationale.
The first-pass headline: the policy is likely low-cost.
For a pool this conservative and high-grade, the EIP reaches almost nothing. And because every bond is short and investment-grade, divestment can follow a no-loss runoff rule, sell anything trading at or above book now (a clean exit, often a small gain), and hold the temporarily underwater names to maturity, when they repay par. Nothing in the screened sleeve is far from maturity, so every screened holding can very likely be exited with little or no realized loss.
Our methodology for the full analysis
What it will take to execute.
Three inputs turn this first pass into the final, decision-grade analysis: (1) the County's machine-readable security-level holdings and amortized-cost basis, to run the six-year backtest precisely, we proved the method on public data; this sharpens it; (2) MSCI / Sustainalytics-grade revenue-exposure data to firm the ">10% of revenue" determinations and the human-rights screen; and (3) a short fiduciary review with County counsel on §53600.3. The analytical engine is already built, the recast, the total-return series, and the classification you can download here, so execution is refinement and validation, not construction, and fits comfortably inside the engagement term.
Where we land.
On the evidence, the EIP can move forward financially, implementable without material harm to returns, with guardrails: divest by no-loss runoff (no forced losses), an elective values-sleeve for consent, MSCI/Sustainalytics-grade data to firm the revenue-threshold calls, and ongoing Treasury-Oversight-Committee monitoring. We stay scrupulously neutral on the values themselves; we hand the Board the financial and fiduciary read, not a position. The number, not the politics, is what lets a split Board decide.
Nine tabs · all 401 securities + the 75-month total-return series, and a full EIP Classification tab that scores every holding against the policy's three tiers (positive / discouraged / prohibited) with a tier summary. The complete workbook, free to download.