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Board approves keeping manager-concentration limits in the investment policy statement after governance debate

October 03, 2025 | San Jose , Santa Clara County, California


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Board approves keeping manager-concentration limits in the investment policy statement after governance debate
Trustees voted to retain manager-concentration and implementation limits in the board’s investment policy statement rather than move them into staff procedures. The discussion at the meeting centered on governance: whether limits that constrain staff implementation decisions are better kept in a board-controlled IPS or in a staff-level procedures document. Aon, the board’s governance consultant, advised placing limits in the IPS so they remain explicitly under board control.

Several trustees and members of the investment committee said they supported keeping the limits in the IPS to preserve board oversight on manager concentration and other high-level guardrails. Investment staff and some consultants noted it is common in similar governance structures to put implementation limits in a procedures document and to have staff manage manager-level allocations within an annual pacing framework. Trustee David (surname withheld in the transcript) said the investment committee unanimously recommended that changes to manager limits require board approval. Trustee Eileen (surname withheld) said the board should keep the limits in the IPS and that moving them could create confusion about which authority governs limits.

The board approved a motion to move the investment limits back into the IPS and asked staff and the consultants to revise paragraph language (including section references) for clarity. The motion passed on a roll-call vote. Staff said the existing implementation procedures will still be used operationally and that any revision to manager limits would be routed to the investment committee and ultimately to the full board for approval.

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