Sifma Prime Brokerage Agreement

In Regulatory Notice 07-58, the Financial Industry Regulatory Authority (FINRA) proposed guidelines for international prime brokerage. International brokerage premium is when a client (PB client) abroad uses a foreign broker as the first broker (FPB) and the FPB has an affiliate or correspondence relationship with a FINRA member (IPBC) to manage and invoice trades of FPB PB clients executed by another FINRA member (EB). The proposed guidelines follow exactly the Premier Broker`s January 25, 1994 no-action letter from the Securities and Exchange Commission. The proposed guidelines recommend, among other things, an omnibus money account agreement between FPB and IPBC for all trades of PB clients. EB confirms trades via OmgeoTrade Suite/CNS Interface for Prime Brokers at IPBC and sends SEC 10b-10 confirmation to PB clients. I think maintaining Lexology will give me a competitive advantage. » Information and documentation on swaps and other derivatives. . . . .

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