NCMA Unrestricted Reserve Fund NCMA Unrestricted Reserve Fund INVESTMENT POLICY STATEMENT This investment policy statement was adopted by the NCMA Asset Management Committee Date: April 21, 2007 1 NCMA Unrestricted Reserve Fund TABLE OF CONTENTS I Summary Data II Purpose III Statement of Objective IV Access Policy V Duties and Responsibilities VI Investment Policy and Guidelines VII Guidelines for Portfolio Holdings VIII Control Procedures: 2 NCMA Unrestricted Reserve Fund I – SUMMARY DATA Fund Name: Investment Time Horizon: Risk Tolerance: Portfolio Type: Trustee: Custodian: Investment Advisor: Fund Administrator: NCMA Unrestricted Reserve Fund 0-3 years Moderate Moderate Growth and Income NCMA Asset Management Committee Wachovia Trust Wachovia Charitable Services W.Todd Ripley, CTFA II - PURPOSE This document establishes the Investment Policy Statement for NCMA Unrestricted Fund Account and is designed to assist in effectively supervising, monitoring, and evaluating the investment of the current income portfolio assets. A thorough investment program is defined throughout this document to achieve the following: Document NCMA Unrestricted Account’s investment objectives, performance expectations, and investment guidelines for Fund assets. Establish an appropriate investment strategy for managing all Fund assets, including an investment time horizon, risk tolerance ranges, and asset allocation. The goal of this strategy is to provide sufficient diversification and overall return. Establish investment guidelines to control overall risk and liquidity, within the agreed upon investment strategy. Establish periodic performance reporting requirements that will effectively monitor investment results and ensure that the investment policy is being followed. Comply with fiduciary, prudence, due diligence, and legal requirements for Fund assets. The NCMA Asset Management Committee has arrived at this Investment Policy through careful study of the returns and risks associated with alternative investment strategies in relation to the current and projected access policies and fund raising requirements of the Fund. This policy has been chosen as the most appropriate policy for achieving the objectives of the Fund, which are described in the Objectives section of this document. III - STATEMENT OF OBJECTIVE The objective of the NCMA Unrestricted Reserves shall be defined as: To preserve and enhance the purchasing and earning value of the funds held in the NCMA Unrestricted Account Fund. To seek an average annual real rate of return of 1% or total return, or CPI plus 1%. This objective shall be measured over 0-3 year time frame, with the intent of this objective, to preserve over time the principal value of the assets as measured in real, inflation adjusted terms. 3 NCMA Unrestricted Reserve Fund To seek competitive investment performance versus appropriate or relative benchmarks. This objective shall be measured primarily by comparing investment results over 0-3 year time period. IV – ACCESS POLICY: The Access Policy for the NCMA Unrestricted Reserves as set forth by the NCMA Asset Management Committee shall be as follows: This account was designed as an unrestricted account to support certain NCMA Board approved projects, developmental activities, and assist from time-to-time with operational cash flow requirements. Access to this account shall be supported by a letter of justification prepared and signed by the NCMA National President and Executive Director. The letter of justification shall present the business case for accessing the unrestricted funds and shall be coordinated with the NVP & Treasurer and the Chair of the Asset Management Committee prior to accessing the funds. The NCMA CFO shall retain a copy of all documentation to support the audit trail for use of NCMA unrestricted reserve funds for a long enough period of time to support any audits or financial reviews. It shall be the responsibility of the NCMA Asset Management Committee to periodically review the access policy to make adjustments necessary to preserve the purchasing power of the NCMA Unrestricted Reserves. Further, it shall be the responsibility of NCMA Executive Director to promptly communicate any desired changes in the access policy or specifically any changes to expected outflows to the NCMA NVP & Treasurer, the Chair of the Asset Management Committee, and to the Investment Advisor prior to accessing the funds. V - DUTIES AND RESPONSIBILITIES The NCMA Asset Management Committee is responsible for managing the investment process in a prudent manner with regard to preserving principal while providing reasonable returns. In carrying out these duties, the NCMA Asset Management Committee has retained an Investment Advisor, Wachovia Trust, to assist in managing the assets of the Fund. The Investment Advisor’s role is to provide guidance to the committee on matters pertaining to the investment of Fund assets including investment policy, investment selection, monitoring Fund performance, and compliance with the Investment Policy. All decisions pertaining to the investment policy and guidelines for the policy’s implementation shall be made by the NCMA Asset Management Committee. NCMA Asset Management Committee: Retain a qualified Investment Advisor to assist in the development and implementation of the investment policy, (e.g., goals, objectives, and guidelines). Establish the investment policy of the Fund. This includes, but is not limited to, allocation between equity and fixed income assets, selection of acceptable asset classes, and investment performance expectations. Investment Advisor: Regularly review investment performance of the Fund to assure the policy is being followed and progress is being made toward achieving objectives. Assist the NCMA Asset Management Committee ‘in establishing the investment policy and guidelines contained in this Investment Policy Statement. 4 NCMA Unrestricted Reserve Fund Determine an investment strategy and coordinate the asset allocation process through the investment provider of the mutual funds and individual securities. This strategy shall be within investment policy guidelines as set forth in this statement, and as otherwise provided by the NCMA Asset Management Committee. Monitor asset allocation among all asset classes and verify on a quarterly basis, to the NCMA Executive Director, that allocations are within targets defined by this investment policy statement and approved by the NCMA Asset Management Committee. Monitor the investment performance of the Fund and provide quarterly performance advisory reports to the Executive Director in addition to an annual summary prepared for presentation to the NCMA Asset Management Committee, as mutually agreed upon. Report, in a timely manner to the NCMA Executive Director, any substantive developments that may affect the management of Fund assets. Brief the Finance and Budget Committee and the Board of Directors once every year at the first meeting of the new Program Year (traditionally the July meeting). Any additional briefings should be coordinated among the AMC, CFO, ED and President on an as-needed basis. VI - INVESTMENT POLICY AND GUIDELINE The Portfolio Fund assets will be held in an investment portfolio with an active strategic asset allocation strategy. This portfolio will be invested to match the projected outflows of this account, and will therefore, remain in cash or cash equivalents, mutual funds, or publicly traded individual securities, and as a result, assets held in this portfolio will be highly liquid. The investment adviser for the portfolio is responsible for managing the assets of the account in accordance with the stated objectives and policies of the fund as set forth in each prospectus. Investment Level Targets The aggregate target amount of NCMA reserve fund assets (both Restricted and Unrestricted) should be 40% of any given year’s Operating Budget. The target amount for Unrestricted Reserve Funds shall be 10% of the aggregate reserve funds. For example, if aggregate reserve funds are $2 million, then unrestricted should be $200,000. Fund Replenishment Replenishment plans should be developed any time $10,000 or more is withdrawn from the NCMA Unrestricted Fund Time Horizon Fund objectives are based on 0-3 year, investment horizon, so that interim fluctuations should be viewed with the appropriate perspective. The NCMA Unrestricted Fund Account has adopted this investment horizon such that the chances and duration of investment losses are carefully weighed against the potential for appreciation of assets. 5 NCMA Unrestricted Reserve Fund Diversification Investments shall be diversified with the intent to minimize the risk of significant losses to the Fund. Consequently, the total portfolio will be constructed and maintained to provide prudent diversification with regard to the concentration of holdings in individual issues, corporations, or industries. Diversification occurs at several levels. The NCMA Asset Management Committee realizes a significant portion of the account comprising the portfolio is allocated to CD’s, Money Market accounts, US Government, and Quality Corporate bonds. Moderate exposure to developed international and high yield bonds may be permitted, but may not exceed 10% of total portfolio. Financial research has demonstrated that price volatility can be further reduced by lengthening the investment time horizon. Notwithstanding the diversification policy outlined above, the Asset Management Committee reserves the right to override the diversification policy if the strategic or operating cash requirements of NCMA warrant such action. The portfolio is managed in accordance with the diversification and industry concentration restrictions set forth in the Investment Company Act of 1940, as amended (the “1940 Act”). Pursuant to the provisions of the 1940 Act, diversified mutual funds may not, with respect to 75% of their assets, (i) purchase securities of any issuer (except securities issued or guaranteed by the United States Government, its agencies or instrumentalities) if, as a result, more than 5% of its total assets would be invested in the securities of such issuer; or (ii) acquire more than 10% of the outstanding voting securities of any one issuer. Certain mutual funds in which the Fund may be invested are considered non-diversified for 1940 Act purposes. These non-diversified funds are not required to follow this procedure. In addition, no mutual fund in the portfolio or the portfolio itself, may purchase any securities which would cause more than 25% of its total assets to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that this limitation does not apply to investments in securities issued or guaranteed by the United States Government, its agencies or instrumentalities. Asset Allocation Academic research indicates that the decision to allocate total account assets among various asset classes will far outweigh security selection and other decisions that impact portfolio performance. The NCMA Asset Management Committee believes that to achieve the greatest likelihood of meeting fund objectives and the best balance between risk and return for optimal diversification, the Fund should allocate assets in accordance with the projected outflows, and will therefore, vary. However, the chart below indicates the target allocation Asset Classes Fixed Income – US CD’s/Money Markets Cash/Equivalents Asset Allocation Limitations: Target Weightings 50% 25% . 25% Sector Target Range 6 Strategic Target NCMA Unrestricted Reserve Fund Domestic Large-Cap Equity US Treasuries/Agencies Corporate Bonds (Inv. Grade) Certificates of Deposit International Fixed / High Yield Cash Equivalent / Money Market 0% -- 20% 0% 5% – 50% 5% – 50% 0% 0% 0% – 100% 0% – 10% 0% 0% 5 – 100% 100% Rebalancing Procedures From time-to-time, market conditions may cause the Portfolio’s investment in various mutual funds to vary from the established allocation. To remain consistent with the asset allocation guidelines established by this Statement, each mutual fund in which the Portfolio invests will be reviewed on a quarterly basis and rebalanced back to the normal weighting if the actual weighting varies by 5% or more from the recommended weighting. In addition, the allocation of assets in the Portfolio may deviate from the normal allocation within the permitted range when market conditions warrant. Such deviations are designed primarily to reduce overall investment risk in the long term. The Asset Management Committee recognizes that rebalancing is inherent to the element of diversification, where the goal is to create a portfolio that balances the appropriate levels of risk and return. That balance, once achieved, only can be maintained by periodically rebalancing to the preferred asset allocation guidelines. Policy will mandate annual rebalancing (minimum), though the Committee reserves the right to review quarterly as deemed prudent. In addition, the Investment Advisor will by policy seek to rebalance to strategic asset allocation guidelines when notified of any distributions or contributions. Risk Tolerances The NCMA Asset Management Committee recognizes that the objectives of the Portfolio cannot be achieved without incurring a certain amount of principal volatility. The Portfolio will be managed in a style-neutral manner that seeks to minimize principal fluctuations over the established time horizon and that is consistent with the Portfolio’s stated objectives and projected outflows. Performance Expectations Over the long-term, the investment objectives for this portfolio shall be to achieve an average total annual rate of return which consists of the Consumer Price Index (CPI) plus 1% for the aggregate investments under this Investment Policy Statement. Returns may vary significantly from VII - GUIDELINES FOR PORTFOLIO HOLDINGS As described in the Investment Advisory Agreement, the Investment Advisor implements this Investment Policy through investments in mutual funds and individual securities. Such investments are acceptable investments provided they conform to the diversification restrictions set forth below. 7 NCMA Unrestricted Reserve Fund Domestic Fixed Income The Domestic Fixed Income asset class may be comprised of mutual funds and Individual securities that are invested principally in fixed income securities that are rated investment grade or better, i.e., rated in one of the four highest rating categories by an NRSRO at the time of purchase, or if not rated, are determined to be of comparable quality by the Investment Advisor or a mutual fund sub-Advisor. Cash Equivalent Reserves Cash equivalent reserves shall consist of money market mutual funds that comply with Rule 2a-7 under the 1940 Act. Equity Income The Equity Income asset class may be comprised of mutual funds that are invested principally in equity securities of Large Cap. US Companies. These securities may be listed on registered exchanges, or actively traded in the over the counter market, or considered to be restricted Securities (provided that the percentage of the funds assets invested in such securities conform to the funds prospectus and stated objectives). VIII - CONTROL PROCEDURES Review of Liabilities NCMA Asset Management Committee will review all policies, objectives and guidelines annually. This review will focus on an analysis of major differences between the Fund’s assumptions and actual experience. Review of Investment Objectives Investment performance will be reviewed annually by the Investment Advisor to determine the continued feasibility of achieving the investment objectives and the appropriateness of the investment policy for achieving these objectives. In addition, the validity of the stated objective will be reviewed annually. It is not expected that the investment policy will change frequently. In particular, short-term changes in the financial markets should not require an adjustment in the investment policy. Review of Investment Advisor The Investment Advisor will report on a quarterly basis to review the total Fund investment performance. In addition, the Investment Advisor will be responsible for keeping NCMA advised of any material change to access policy, investment strategy, or other pertinent information, potentially affecting performance of all investments. Proxy Statements Proxy statements will be voted in accordance with the terms of the Investment Advisory Agreement. Investment Advisor & Fund Manager(s) The Investment Advisor serves at the pleasure of the NCMA Asset Management Committee and Executive Director. NCMA may at any time direct the Investment Advisor on the means and methods of all investment instruments and instrumentalities in accordance with applicable laws and rules and regulations as well as policies set forth herein. 8 NCMA Unrestricted Reserve Fund ADOPTION OF INVESTMENT POLICY STATEMENT The NCMA Asset Management Committee has reviewed, approved, and adopted this Investment Policy Statement, dated April 21 2007. NCMA Executive Director Date Wachovia Trust Charitable Services Group Date 9