Regulatory Alerts2006-04-25
Added
Frequently Asked Question Customer Identification Program Responsibilities under the Agency Lending Disclosure Initiative
Broker-dealer borrowers are not required to treat the underlying customers of an agent lender as 'customers' for purposes of the Customer Identification Program rule. Instead, the broker-dealer borrower must treat only the agent lender as the person opening the account. This guidance clarifies that the definition of 'customer' refers to the named accountholder, meaning the borrower is not required to look through the agent lender's omnibus account to identify the ultimate securities lenders.
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