SEC Division of Trading and Markets no-action letter: Chubb Securities Corporation

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION WASHINGTON. D.C. 20549 & DIVISION OF MARKET REGULATION Nove-mber 24, 1993 Ian E. Celecia, Esq. Chubb Securities Corporation One Granite Place P.0. Box 2005 Concord, New Hampshire 03302 Re: Chubb Securities Cornoration Dear Mr, Celecia:
In your letter of September 1, 1993, on behalf of Chubb Securities Corporation ("CSCm), as supplemented by telephone conversations with the staff, you request assurance that the staff would not recommend enforcement action to the Commission under Section 15(a)(1) of the Securities Exchange Act of 1934 ("Exchange Act") if CSC enters into networking arrangements with certain federal and state chartered banks, savings and loan associations, savings banks, and credit unions (collectively, "Financial Institutions'') and, where required by law, their service corporation subsidiaries, to provide securities brokerage services on the premises of such Financial Institutions, as described in your letter, without the Financial Institutions, the required service corporations, or their unregistered employees registering as broker-dealers under Section 15(b) of the Exchange Act. We understand the facts to be as follows:
CsC, a wholly-owned subsidiary of Chubb Life Insurance Coqany of America, is a registered broker-dealer and member of the National Association of Securities Dealers, Inc. ("NASD"). CSC proposes to enter into networking arrangements with Financial Institutions to provide securities brokerage services to customers of such Financial Institutions and the general public, on the premises of the,Financial Institutions, Where required by the laws or regulations governing a Financial Institution, the Financial Institution will enter into the networking arrangement with CSC through a service corporation subsidiary of the Financial Institution, CSC wili provide brokerage services on the premises cf each Financial Institution in an area that is physically separate from the Financial Institution's regular business activities, in such a way as to clearly segregate and distinguish CSC from the Financial Institution, The area in which CSC provides brokerage services will clearly disDlay CSC's name and an indication that