Did Jan Klein "invest" illegally?

Brief rest over.

Authorized Types of Investments for Pennsylvania School Districts:

Section 440.1(c) of the School Code authorizes the types of investments school districts may have:

• United States Treasury bills.
• Short-term obligations of the United States Government or its agencies or instrumentalities.
  Short-term obligations usually refer to investments of less than 13 months.
• Deposits in savings accounts or time deposits or share accounts of institutions insured by The Federal Deposit Insurance Corporation (FDIC), or The Federal Savings and Loan Insurance Corporation, or The National Credit Union Share Insurance Fund to the extent that such accounts are so insured, and for any amounts above maximum, provided that approved collateral as provided by law therefore shall be pledged by the depository.
• Obligations of the United States of America or any of its agencies or instrumentalities backed by the full faith and credit of the United States of America, the Commonwealth of Pennsylvania or any of its agencies or instrumentalities. Full faith and credit means the obligation is backed by the government’s ability to levy taxes to repay debt. These investments include any bonds issued by the Commonwealth of Pennsylvania or any municipality or school district carrying the backing of the taxation powers of the governmental unit issuing the debt. Some investments of the federal government do not have full faith and credit backing. Fannie-Mae (FNMA) and Freddy-Mach (FNMC) bonds do not. Ginnie-Mae (GNMA) bonds do have full faith and credit backing.
   • Shares of an investment company registered under the Investment Company Act of 1940 whose shares are registered under the Securities Act of 1933 provided that the following are met:
  o Only investments of that company are in the authorized investments for school district funds listed in the categories above, and repurchase agreements fully collateralized by such investments.

  o The investment company is managed so as to maintain its shares as a constant net asset value in accordance with 17 CFR 270 2a-7 (relating to money market funds).

  o The investment company is rated in the highest category by a nationally recognized rating agency.

  This classification includes pooled investments such as the Pennsylvania School District Liquid Asset Fund, Pennsylvania Local Government Investment Trust and the Pennsylvania State Treasurer’s Invest Program.

  Any purchase or sale of investments shall be made by the treasurer of the school district on a resolution adopted by the board of school directors.

  
  

  
  http://www.education.pa.gov/Documents/Teachers-Administrators/School%20Finances/Comptrollers%20Office/Manual%20of%20Accounting.pdf