SAN DIEGO CITY EMPLOYEES' RETIREMENT SYSTEM REQUEST FOR PROPOSAL (RFP) FOR GENERAL INVESTMENT CONSULTANT

Transcription

1 SAN DIEGO CITY EMPLOYEES' RETIREMENT SYSTEM REQUEST FOR PROPOSAL (RFP) FOR GENERAL INVESTMENT CONSULTANT

2 SAN DIEGO CITY EMPLOYEES RETIREMENT SYSTEM GENERAL INVESTMENT CONSULTANT RFP SEPTEMBER 2014 Table of Contents I. Introduction... 2 II. Purpose and Requested Services... 2 Policy Duties:... 2 Asset Allocation and Portfolio Duties:... 3 Investment Manager Oversight and Duties:... 3 Performance Measurement Duties:... 3 Training, Education and Client Service Duties:... 4 III. Proposal Participation, Completion and Submission Procedures... 4 A. Mandatory Requirements Certification and Minimum Requirements... 4 B. Confidentiality... 6 C. Intention to Participate... 6 D. RFP Submission... 6 E. Number of Copies of the Response... 7 IV. Proposal Evaluation Criteria... 7 V. Insurance Requirements... 8 VI. Search Schedule... 8 VII. Technical Proposal... 9 A. Organization... 9 B. Assets Advised...12 C. Investment Consulting Philosophy and Process...13 D. Manager Measurement and Evaluation...14 E. Research...14 F. Manager Searches and Evaluation...15 G. Other Information...15 H. Fee Proposal...16 ATTACHMENT A...17 ATTACHMENT B...17 ATTACHMENT C...19 ATTACHMENT D...20 ATTACHMENT E...21 ATTACHMENT F...22 ATTACHMENT G...26 SDCERS General Investment Consultant RFP September

3 I. Introduction The San Diego City Employees Retirement System ( SDCERS ) is a Retirement System Trust Fund for the employees of the City of San Diego, the Unified Port District, and the San Diego County Regional Airport Authority. The Board of Administration (Board) establishes policies and objectives for SDCERS. SDCERS staff is responsible for the daily operations involving the administration of benefits, accounting functions, and, with the assistance of its General Investment Consultant, management of the investments for the fund. SDCERS was established in 1927 by the City of San Diego. In accordance with the California State Constitution Article XVI, Section 17, the San Diego City Charter Article IX Sections and Article X Section 1 and the San Diego Municipal Code Sections et seq., SDCERS administers retirement benefits, health insurance, disability, and death benefits to its members and their beneficiaries. II. Purpose and Requested Services SDCERS is seeking a qualified firm with substantial public fund experience to provide comprehensive pension fund investment consulting services. The selected investment consulting firm will report to the Board, through staff. The selected Consultant will work closely with the Investment Committee and/or the Board of Administration, as well as staff. The firm will serve in a fiduciary capacity and will acknowledge in writing the firm s fiduciary status, without qualification. In all cases, the firm and its consultants will offer advice to SDCERS solely in the interest of the plan participants and the beneficiaries of SDCERS. The selected consulting firm is expected to provide the following services: Policy Duties: Provide recommendations concerning long-term investment policy and investment objectives and strategy. Provide recommendations regarding investment guidelines and procedures. Provide recommendations concerning risk management strategies. Provide monitoring. Advise on rebalancing policies. SDCERS General Investment Consultant RFP September

4 Asset Allocation and Portfolio Duties: Conduct an annual asset allocation review. (Schedule of Investment Managers is attached See Attachment A) Conduct an asset/liability study at least every 3 years. Conduct a manager structure review at least every year. Provide asset class research, analysis and recommendations. Provide an annual Investment Policy Statement review. Provide access to analytical software and tools. Provide recommendations concerning securities lending strategies. Provide compliance monitoring of the securities lending program. Provide recommendations concerning custodial arrangements. Provide investment vendor fee negotiation services as needed. Provide recommendations concerning brokerage issues, including directed brokerage, commission recapture, and low transaction cost trading strategies. Provide an annual brokerage commission trading cost analysis. Investment Manager Oversight and Duties: Provide ongoing monitoring of institutional investment managers. Provide research and analysis of SDCERS investment managers. Provide investment manager selection services and recommendations. Provide investment manager compliance monitoring. Provide investment manager compliance with CFA Institute guidelines. Provide recommendations concerning investment manager allocation and structure, manager guidelines and benchmark identification. Performance Measurement Duties: Evaluate total portfolio investment performance to custom policy benchmark. Evaluate investment manager performance to policy benchmarks and appropriate peer groups. Provide quarterly performance measurement reporting. Provide quarterly performance review and commentary to the Investment Committee and/or Board, if necessary. Provide benchmark evaluation, implementation and analysis. Provide access to analytical software, if any. Provide review of portfolio risk. SDCERS General Investment Consultant RFP September

5 Training, Education and Client Service Duties: Attend Investment Committee and/or Board meetings and any other meetings as necessary. (Schedule is attached See Attachment B) Coordinate effectively with specialty consulting firms (Real Estate, Private Equity). Provide investment education and training to staff and the Board as needed. Provide assistance on special projects as needed. Participate in ad hoc workshops on specific issues designated by the Board. Communicate regularly with staff about workflow and any other operational issues between meetings. Develop educational materials. Respond to inquiries in an appropriate and timely manner. Share all firm research, including white papers, and provide access to research staff. Make no changes in the assigned consultant team without the explicit approval of SDCERS. III. Proposal Participation, Completion and Submission Procedures A. Mandatory Requirements Certification and Minimum Requirements SDCERS will accept proposals from firms that meet the minimum requirements listed below. The proposing firm should complete the Mandatory Requirements Certification (attached as Attachment C) and submit it with the cover letter. 1. The investment consulting firm must be a registered advisor under the Investment Company Act of The investment consulting firm must have provided for at least five (5) years as of December 31, 2013, investment consulting services comparable to the duties contained in this RFP to at least three (3) defined benefit public retirement systems, each of which must have had at least $5 billion in current assets. 3. The investment consulting firm must be able to maintain a satisfactory data processing interface with SDCERS custodian, State Street Bank, on-line connection or other electronic means, at the firm s expense, for the purposes of compiling all required reviews and reports. SDCERS General Investment Consultant RFP September

6 4. The investment consulting firm must agree to disclose all potential, current conflicts of interest as well as potential conflicts as they might occur, and annually disclose all sources of revenue from sources and affiliations other than investment consulting. The investment consulting firm agrees to abide by SDCERS Conflict of Interest policy. This policy can be found on SDCERS website at Documents/Board_CPRR_final_ aspx. The policy can be found on page II-34 of the Charters, Policies, Resolutions and Rules of the Board of Administration. 5. The investment consulting firm must agree to abide by SDCERS Placement Agent Disclosure Policy. (The current policy is attached See Attachment F). 6. The individuals assigned to SDCERS as the primary consultant, as of December 31, 2013, must have a minimum of ten total years experience in the public/private defined benefit pension fund area. 7. The investment consulting firm must be directly responsible for the management of the account, and all personnel responsible for working on the account must be employees of the firm. 8. The investment consulting firm must not have, nor potentially have, a material conflict of interest to include, but not limited to: SDCERS Board, staff, actuary, auditor, investment managers, or other consultants. 9. The investment consulting firm must carry Errors and Omissions coverage and other insurance coverage as discussed in Section V. Insurance Requirements. 10. The investment consulting firm must have its principal place of business within the United States and be subject to service of process in the United States. 11. All minimum qualifications must be met by December 31, PLEASE COMPLETE THE MANDATORY REQUIREMENTS CERTIFICATION. (Schedule is attached See Attachment C) This should be attached to the cover letter. SDCERS General Investment Consultant RFP September

7 B. Confidentiality Information presented in this RFP, including all subsequently disclosed information about SDCERS during the proposal process, is intended only for use in responding to this RFP and not for public disclosure. C. Intention to Participate If you intend to reply to the RFP, please send Ms. Liza Crisafi an attaching a letter that your organization will be replying to the RFP. If you have any questions, please Ms. Crisafi. D. RFP Submission Please complete all questions in the order that they are presented in the Technical Proposal section of this RFP. Preface each response with the section number, question numbers and text of the question. Any additional comments or information may be provided as an Appendix. The individual who is authorized to bind the investment consulting firm (hence, Proposer ) contractually must sign a cover letter, which must accompany the firm s RFP response. This cover letter must indicate the signer is so authorized and must indicate the title or position that the signer holds in the Proposer s firm. An unsigned cover letter shall cause the proposal to be rejected. The cover letter must contain a statement that the firm acknowledges that all documents submitted pursuant to this request for proposal process will become a matter of public record. The letter must also contain the following: 1. The Proposer s name, address, , telephone, and fax number. 2. The Proposer s Federal Employer Identification Number and Corporate Identification Number, if applicable. 3. The name, title or position, , and telephone number of the individual signing the cover letter. 4. A statement indicating the signature is authorized to bind the Proposer contractually. 5. The name, title or position, , and telephone number of the primary contact and/or account administrator, if different from the individual signing the cover letter. 6. A statement to the effect that the proposal is a firm and irrevocable offer, good for six (6) months. Please attach a Fee Proposal as Exhibit L of your RFP response (A sample is provided as Attachment E). 7. A statement expressing the Proposer s willingness to perform the services as described in this RFP. 8. A statement expressing the Proposer s availability of staff and other required resources for performing all services and providing all deliverables within the specified time frames as described in the RFP. SDCERS General Investment Consultant RFP September

8 E. Number of Copies of the Response The response should be labeled 2015 SDCERS General Investment Consultant Search. Please submit one (1) full and complete electronic copy (in PDF readable format) via , ten (10) complete hard copy sets, and one (1) DVD/CD ROM in PDF format of the proposal to: Liza Crisafi, Chief Investment Officer San Diego City Employees Retirement System 401 West A Street, Suite 400 San Diego, CA sdcersinvestments@sdcers.org The deadline for submission of the firm s proposal is October 10, 2014 at 5:00 pm (PST). All materials must be received in SDCERS office at that time. IV. Proposal Evaluation Criteria SDCERS will determine the specific methodology and criteria by which submitted proposals will be evaluated. Selection of finalists and determinations of compliance with the minimum qualifications is solely and exclusively within the judgment of SDCERS and may be made solely on the basis of SDCERS evaluation of a candidate s suitability. The following is a summary of the general considerations that will be used to determine the firms that will be selected as finalists: Understanding of SDCERS and Ability to Deliver Services in a Timely Manner Independence and Objectivity of Investment Advice Firm Experience and Client Relevant Experience Analytical Tools, Research and Process Firm Personnel and Proposed Consultant Team Client and Industry Feedback Fee Schedule Fees and compensation will be an important factor in the evaluation of investment consulting proposals. However, SDCERS is not required to choose the lowest cost bidder. SDCERS will select the firm that, in the Board s sole discretion, best serves the overall needs of the plan participants and beneficiaries. SDCERS General Investment Consultant RFP September

9 V. Insurance Requirements The selected firm shall provide evidence of Professional Liability insurance with contractual liability coverage covering the Proposer s liability arising from errors and omissions made directly or indirectly during the duration of the contract. The selected firm shall provide coverage for the total limits actually arranged by the selected firm but not less than $10 million combined single limit. The selected firm shall maintain a Fidelity Bond covering employee dishonesty, in an amount arranged by the selected firm, but not less than $15 million, per occurrence. In addition, the selected firm shall maintain workers compensation coverage. VI. Search Schedule September 8, 2014 October 10, 2014 October 24, 2014 November 3-4, 2014 December 8-12, 2014 RFP distributed Deadline for submission of proposals Determination of semi-finalists Semi-finalist in-house interviews Due diligence visits February 25, 2015 Finalist presentation materials for Board meeting due March 12, 2015 March 13, 2015 Finalist presentations to Investment Committee Ratification of finalist selection at full Board Meeting SDCERS General Investment Consultant RFP September

10 VII. Technical Proposal Please be as clear, accurate, and complete as possible in your responses. Providing incomplete or misleading data may lead to disqualification of the proposal and elimination of the firm from the search process. A. Organization 1. Please provide a brief history of the firm including the year organized, the year the firm began providing investment consulting services to U.S. tax-exempt clients, and the nature of the firm s ownership (including any changes in the last five years) and specific details with regard to any affiliated companies or joint ventures. 2. Does your organization receive revenue from investment management firms? Revenues within this request would include, among others, strategic consulting fees, conference fees, education fees, or fees from research including databases. Please identify the percent of the firm s total revenues that is derived from investment management firms. 3. Provide the percentage of total firm revenues that came from the categories listed below for each year: Consulting to Plan Sponsors % % % Money Management Activities % % % Services to Money Managers % % % Other (Please describe) % % % 100% 100% 100% 4. Please list the total number of firm professionals, broken down by consultants, research professionals, and staff. 5. Please provide the location and function of each of your firm s offices, including the number of professionals at each office and what services are provided by each office. 6. Please indicate which office would service this account, the names of the team members who would be assigned to this account and their contact information. Attach as Exhibit A biographies for these team members. SDCERS General Investment Consultant RFP September

11 7. Complete the following table as it pertains to the team who would be assigned to this account: Average number of years of general consulting experience: Average number of years tenure with your firm: Number of years consulting professionals have worked together as a team: 8. Please provide details on the financial condition of your firm. Most recent reports filed (for the last two years) with the SEC will be acceptable, but any recent material changes should be included. 9. Are you registered with the SEC or a state securities regulator as an investment adviser? If so, provide as Exhibit B all disclosures required under those laws (including Part I and II of Form ADV). 10. Has your firm ever been censured by the SEC or any regulatory body? If so, please describe. 11. Has your firm been subject to or is currently being reviewed/audited by the SEC or other regulatory agencies. If yes, please describe the nature of the investigation. 12. Over the last five (5) years has the firm, the Primary Consultant, or another principal or officer of the firm been involved in any business litigation, regulatory, or other legal proceedings or government investigation involving allegations of fraud, negligence, criminal activity or breach of fiduciary duty? If so, please describe. 13. Will your firm acknowledge fiduciary status and accept fiduciary responsibility for recommendations to SDCERS? 14. State whether or not the employees comply with the Code of Ethics and Standards of Professional Conduct of the CFA Institute. If not, does your firm maintain a Code of Ethics? Attach as Exhibit C a copy of the firm s Code of Ethics. SDCERS General Investment Consultant RFP September

12 15. List the dollar amounts of fiduciary liability insurance, errors and omissions insurance and bonding insurance carried by your firm, as follows: Insurance carrier providing coverage Type of coverage Dollar amount 16. Please discuss the overall business objectives of your firm with respect to future growth. Comment on any present or planned areas of emphasis over the near future. Be sure to include in your response: a. Total assets or client relationships that will be accepted. b. Maximum limits on asset amounts or number of clients per consultant. c. Plans to develop and expand resources, merge or acquire other firms, spin off subsidiaries. 17. Complete the following table regarding consulting staff who left or joined your firm within the last three (3) years. Include anticipated personnel changes for the next year. Name and title Left: Date terminated or hired Reason Joined: SDCERS General Investment Consultant RFP September

13 18. Briefly describe your firm s compensation system for principal staff, and indicate what specific incentives are utilized to ensure key professionals do not leave the firm either as a group or individually. How does the firm tie client performance and satisfaction to a consultant s performance? 19. Describe your firm s disaster recovery plan. B. Assets Advised 1. Complete the following table by providing the number of clients, assets under advisement for the firm s full-service retainer investment consulting relationships and the number of clients that have renewed their contract with your firm over each of the last three years. Please provide the data as of December 31 st for all years. Number of Clients Assets under Advisement Number of Clients to Renew Contract Provide as Exhibit D a list of the firm s investment consulting clients as of 12/31/2013. Please provide a table listing all current clients for whom you provide investment consulting services along with the following information: a. Name/Type of client (public plan, corporate plan, endowment, fund of hedge funds, etc.) b. Total size of each relationship c. Assets on which you provide consulting services d. Length of service of the relationship e. Brief, one sentence description of the type of services you provide for each client f. Nature of the relationship (retainer or project-based) 3. Please list all clients your firm has gained in the last three (3) years and the clients who have terminated your services during that time. For those who have terminated your service, please indicate the reason for terminating service. 4. Please provide as Exhibit E the name, address, telephone number and contact person for three (3) current clients to serve as a reference for your firm, preferably public pension plans. SDCERS General Investment Consultant RFP September

14 C. Investment Consulting Philosophy and Process 1. Briefly describe your firm s philosophy with respect to investment consulting mandates, and the nature of the service that you provide. What key strengths and competitive advantages does the firm possess that generate superior performance and service for your clients? 2. Describe your firm s experience in developing and reviewing investment policies and strategies for clients. 3. How frequently does the firm recommend reviewing asset allocation, asset/liability reviews, and manager structure reviews and describe your firm s methodology. Please provide samples of an Asset Allocation Review and Asset/Liability Study as Exhibit F. 4. Provide a sample of your firm s most recent five (5) years of capital market assumptions (projected returns, volatilities and corrections) in table format as Exhibit G. 5. What is the range of target allocations which you are currently recommending to your public fund clients? 6. Describe your firm s views of active versus passive management. 7. Has your firm recommended significant changes to client portfolios in response to the global financial crisis? If yes, please describe the recommendation. 8. What level of liquidity do you recommend for a public pension plan? 9. How does your firm assess risk in client s portfolios and what new methodologies are being considered? What are the appropriate metrics to review? 10. In your view, how should a client measure its investment consulting firm s performance? How does your firm measure its own performance? 11. Describe your firm s views of global versus international mandates. 12. SDCERS currently has an allocation of up to eight (8) percent in the Opportunity Fund. This allocation is a place for mandates that may not fit neatly within the asset allocation or can be used to take advantage of temporary market dislocations. What is your firm s view on such an allocation? What recommendations would your firm suggest for SDCERS allocation? SDCERS General Investment Consultant RFP September

15 D. Manager Measurement and Evaluation 1. How does your firm monitor and analyze investment performance? Please describe any databases used by your firm. How do you determine appropriate benchmarks? Please provide a sample performance report as Exhibit H. 2. Can the performance reports be customized? Are there charges for additional information requests? 3. What is the anticipated turnaround time to produce a performance report? 4. Describe how your firm obtains data from the client s Custodian. How does your firm verify the accuracy of the data received from the Custodian? 5. What is your firm s step by step process for return reconciliation? How will discrepancies be handled? 6. What process does your firm use to communicate performance issues with investment managers? Please describe your firm s criteria for recommending an investment manager be terminated. 7. Do you monitor your success in selecting managers? Explain how you measure the level of success of existing managers. E. Research 1. List notable publications that have included your firm s research. 2. Does your firm prepare white papers on relevant investment topics? Please provide a sample as Exhibit I. 3. Provide a listing of research generated during 2012 and 2013 with Exhibit I. 4. Describe in detail the type and frequency of research that would be provided to SDCERS. Through what media is it provided? Does the firm provide research reports other than those specifically requested by the client? If so, please describe. What research and analytical resources (including databases) does the firm possess that the firm would be willing to provide SDCERS? SDCERS General Investment Consultant RFP September

16 F. Manager Searches and Evaluation 1. Describe in detail your manager database and search process. Include the criteria used to make manager recommendations. 2. Describe the process how new investment managers are added into your database. 3. Please provide a sample of investment manager research or due diligence reports as Exhibit J. 4. How often are on-site due diligence visits conducted with your client s managers? 5. Have your most recent manager searches resulted in the same manager being selected for multiple clients? Provide results (table format) for the three most recent searches for US equities, non-us equities, and fixed income. At a minimum, identify the finalist candidates and indicate which firm was selected. 6. Provide as Exhibit K a sample of a finals report for a recently completed public markets search. 7. State your willingness to make specific investment hiring or firing recommendations to your clients. G. Other Information 1. Describe your firm s capabilities in providing educational opportunities for trustees and staff. Does your firm hold an annual investment conference for its clients? 2. Describe your firm s experience and ability to support issues relating to securities lending, custodial services and commission recapture. 3. Describe your custodial bank search process. Please include details such as criteria used for evaluating and ranking custodians. 4. Does your firm maintain an in-house database of custodial banks? If not, from what vendor do you purchase the database? How many banks are contained in the database? How often are custodial banks in the database reviewed? SDCERS General Investment Consultant RFP September

17 5. State your firm s opinion of overlay/derivative strategies and how would you recommend a client use them to reduce risk in the portfolio. H. Fee Proposal 1. Provide a fee proposal as Exhibit L for the services outlined in the Expected Service Level Requirements See Attachment D. A fee proposal template is attached - See Attachment E. Please provide fee proposals for: a. Full scope of services outlined above. b. Manager selection services only. 2. Are you willing to guarantee your fees for a specific period of time? 3. Are your fees negotiable? 4. What other potential costs might be incurred during the term of the contract? SDCERS General Investment Consultant RFP September

18 ATTACHMENT A SDCERS General Investment Consultant RFP September

19 ATTACHMENT B SDCERS 2015 Investment Committee and Board Meeting Dates Investment Committee Thursday Meeting Begins at 12:30 PM Board of Administration Friday Meeting Begins at 8:30 AM January 8 January 9 March 12 March 13 May 7 May 8 July 9 July 10 September 10 September 11 November 12 November 13 SDCERS General Investment Consultant RFP September

20 ATTACHMENT C MANDATORY REQUIREMENTS CERTIFICATION The undersigned Proposer hereby represents and warrants to SDCERS as follows: 1. Proposer is an investment advisor registered under the Investment Advisors Act of Proposer has been in business for a minimum of five years. Date business commenced: 3. Proposer provides investment consulting services to at least three public retirement system defined benefit clients with assets greater than $5 billion. Name(s) of client(s): 4. The primary consultant assigned to SDCERS account has a minimum of ten years experience providing domestic and international investment consulting services to public pension plans. Name of the primary consultant: Number of years of experience: 5. The Proposer s principal place of business is in the United States. Proposer is subject to service of process in the United States. Location of Proposer s principal place of business: 6. If awarded the contract, the Proposer will serve as a "fiduciary" with respect to SDCERS. PROPOSER'S NAME: Signed: Date: PLEASE RETURN WITH COVER LETTER SDCERS General Investment Consultant RFP September

21 ATTACHMENT D EXPECTED MINIMUM SERVICE LEVEL REQUIREMENTS 1. Attendance at monthly SDCERS Meetings; Investment Committee and/or Full Board. A schedule of Board and Investment Committee meetings is included as Attachment A. 2. Timely delivery of quarterly investment performance reports. 3. Preparation and presentation of an annual Asset Allocation study and annual Manager Structure Review. 4. Preparation and presentation of an Asset/Liability Study at least every three (3) years. 5. Willingness to take on additional duties (i.e. manager searches, special projects, etc). 6. Presentation and delivery of an annual commentary letter for inclusion in SDCERS Comprehensive Annual Financial Report. 7. Preparation and presentation of an annual commission cost analysis of SDCERS managers. SDCERS General Investment Consultant RFP September

22 ATTACHMENT E FEE PROPOSAL As the term of the contract is expected to be three (3) years with a two (2) one-year extensions issued at the discretion of SDCERS, the Fee Proposal should be guaranteed for a period of not less than five (5) years from the effective date of the contract. Proposed fees must include travel, taxes and all expenses. Proposer should submit an all inclusive annual fee for all services as follows: All inclusive flat fee year 1 All inclusive flat fee year 2 All inclusive flat fee year 3 Sub Total (Years 1-3) All inclusive flat fee year 4 (if extension is issued) All inclusive flat fee year 5 (if extension is issued) Total Fees (Years 1-5) $ $ $ $ $ $ $ Special Project Fees (Manager Searches, etc) per Project $ The final contract fee should represent the only compensation received by the consultant for services provided to SDCERS. There should not be any other benefit, monetary or otherwise, that results from this relationship between the consultant and SDCERS. PLEASE RETURN AS EXHIBIT L SDCERS General Investment Consultant RFP September

23 ATTACHMENT F SDCERS Placement Agent Payment Disclosure Policy SDCERS General Investment Consultant RFP September

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27 ATTACHMENT G SDCERS Investment Consulting Services Request for Proposal SUBMISSION CHECKLIST Item Included in RFP Response Cover Letter and Minimum Requirements Certification Answers to all Questions in Technical Proposal Exhibit A Biographies of Proposed Team Members Exhibit B - Form ADV (Part I & II) Exhibit C Copy of Proposing Firm s Code of Ethics Exhibit D List of Current Clients Exhibit E Public Fund References Exhibit F - Copy of Asset Allocation Review and Asset/Liability Study Exhibit G - Five Years of Capital Market Assumptions Exhibit H Sample Performance Report Exhibit I - Sample White Paper/Research Report & List of Research Generated in 2012 & 2013 Exhibit J Sample of Investment Manager Research/Due Diligence Report Exhibit K Sample of Finals Report for Recent Public Markets Search Exhibit L Fee Proposal SDCERS General Investment Consultant RFP September