Since 1989, the Virginia Treasury Board has sponsored the Program to provide investment management, accounting and arbitrage rebate calculation services for proceeds of tax-exempt financings of Virginia governments.

The investment options provided to investors through the Program are the SNAP Fund Portfolio and Individual Portfolios managed by the Program's Investment Manager.  Arbitrage rebate compliance services are provided for all investments managed through the Program.

SNAP Fund Portfolio

Investment Objective
The SNAP Fund Portfolio is organized and operated in a manner and in accordance with investment objectives and policies intended to earn the highest income consistent with preserving principal and maintaining liquidity, to maintain a stable $1.00 net asset value (NAV).

Principal Investment Strategies
The SNAP Fund Portfolio (the Portfolio) invests exclusively in investments authorized under Virginia law for counties, cities, towns, and political subdivisions and public bodies of the Commonwealth of Virginia as those terms are used in Section 2.2-4500 et seq. of the Code of Virginia of 1950, as it may be amended from time to time.  These authorized investments include the following high-quality, short-term money market instruments:

• U.S. Government and Federal agency obligations, and repurchase agreements involving these obligations
• Commercial paper
• Bankers' acceptances
• Negotiable certificates of deposit
• Corporate obligations
• Obligations of U.S. municipalities
• Government money market mutual funds that invest exclusively in these types of obligations

The Portfolio is designed to maintain a dollar-weighted average maturity of no more than 60 days and a dollar-weighted average life (final maturity, adjusted for demand features but not interest rate adjustments) of not more than 120 days. In addition, it only buys investments that have either a final or effective maturity (or, for repurchase agreements, a remaining term) of 397 days or less. The Portfolio is rated AAAm¹ by S&P Global.
 

The Investment Manager may adjust exposure to interest rate risk, typically seeking to protect against possible rises in interest rates and to preserve yield when interest rates appear likely to fall.

Purchase and Sale of Portfolio Shares
Minimum Initial Investment No minimum.
Minimum Account Balance No minimum.
Minimum Holding Period 1 day.

For more information about investing in the SNAP Fund Portfolio, please visit the How to Invest page.

The SNAP Fund Portfolio is not registered as an investment company under the Investment Company Act of 1940 (15 U.S.C. Sec. 80a-1 et seq.) and, accordingly, is not subject to the provisions of the Investment Company Act of 1940 and the rules and regulations promulgated thereunder including rules relating to registered money market mutual funds. 

Individual Portfolios²
The Program provides Investors with the option of investing all or a portion of their proceeds in one or more fixed rate investments including fixed income securities and structured investment products, held in Individual Portfolios outside of the SNAP Fund Portfolio.  By using an Individual Portfolio a Participant may invest in longer-term investments in a manner that the Investment Manager will coordinate with the Issuer.  Individual Portfolios will be managed by the Investment Manager in accordance with specific instructions from the Participant.  Individual Portfolios established as structured investment products will be subject to separate agreements between the Participant and investment counterparty.

Individual Portfolios are designed to complement investment in the SNAP Fund Portfolio by providing specific investments for surplus funds or for a portion of the proceeds of a debt issue where liquidity is not needed or where specific expenditures are to be funded.  For proceeds of debt issues, an Individual Portfolio may be appropriate for Participants with relatively lengthy project drawdown schedules, or for Participants that wish to match expected construction draws more closely with investment maturities to fix earnings on some or all of their funds.  Individual Portfolios may also be appropriate for the investment of debt service reserve funds and certain funds subject to investment yield restrictions.  The Investment Manager will assist each Investor in evaluating the possible use of an Individual Portfolio.  For further information, call the Investment Manager at 1-800-570-SNAP (1-800-570-7627).  In order to establish an Individual Portfolio, the Participant must first establish an account with the SNAP Program.  The Custodian will hold assets in an Individual Portfolio in a separate account in the Participant's name.

Individual Portfolios are not under the management or supervision of the Treasury Board. 

Investment Policies for Individual Portfolios
Assets in an Individual Portfolio may be invested in those investments that are legal investments for the Investor under applicable Virginia law for counties, cities, towns, political subdivisions and public bodies of the Commonwealth of Virginia as those terms are used in Chapter 45, Title 2.2 of the Code of Virginia of 1950, as it may be amended from time to time and the Investor's investment policy or are permitted under the terms of related debt issue documents, if any. Individual Portfolios are not governed by the investment policy of the SNAP Program. A Participant should discuss the characteristics of specific investments in an Individual Portfolio with the Investment Manager.

Opening an Individual Portfolio
Before an Issuer's funds are invested in an Individual Portfolio, the Issuer must first join the SNAP Program or become an Investor. An Investor may then open an Individual Portfolio. Investors interested in structured investment products should consult their bond counsel and the Investment Manager on the process appropriate for structuring the investment product and competitively selecting the cournterparty. Investors should contact a Relationship Manager directly at 800.570.SNAP (800.570.7627) regarding investments in an Individual Portfolio.

Arbitrage Rebate Compliance Services
As part of the Program, the Treasury Board has contracted with Bingham Arbitrage Rebate Services, Inc., to provide formal Arbitrage Rebate Compliance Services. In addition, the Investment Manager, once bond proceeds are deposited into the Program, starts tracking the issue for arbitrage rebate compliance purposes. The Investors receive the following correspondence/reports/services from the Investment Manager:

• Spending exception compliance reports including notification of an upcoming benchmark
• Yield restriction compliance notification
• Annual estimates of accrued arbitrage rebate and yield restriction liabilities
• Notification of Installment Calculation Date sent 60 days in advance of the required calculation date
• Retention of arbitrage related documents and investment records

Investors can check the arbitrage rebate and yield restriction compliance status of any of their bond issues invested in the Program at any time by contacting Michael Steinbrook at 800.570.SNAP (800.570.7627) or one of the other Program Representatives.

SNAP Users' Group Meetings
Each year the Investment Manager offers training on Program services and other topics related to the investment of tax-exempt bond proceeds. The Users' Group meeting is available free of charge to current and prospective SNAP Investors, their financial advisors, bond counsel, bank trustees, and others that want to know more about the Program.

Topics at recent sessions have included:

• Basics of arbitrage rebate and yield restriction
• Investment strategies for bond proceeds
• Current market conditions
• Bond pools
• Frequently asked questions about debt issuance

CPE credit is also given for attendance at these sessions.

For access to this year's presentations please visit the Investor Resources Section.

Customer Service
Customer service representatives are available to answer general questions about your accounts Monday through Friday from 8:30 a.m. until 5:30 p.m.

1  S&P Global AAAm Rating: S&P evaluates a number of factors, including credit quality, market price, exposure, and management. Please visit SPGlobal.com/Ratings for more information and ratings methodology.

2  Individual Portfolios are available under a separate agreement with the investment manager.