Form CUSTODY For Broker Dealers (SEC2897) {CUSTODY}

OMB APPROVALOMB Number:3235-0691Expires:December 13, 2019...................12UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM CUSTODY For Broker-Dealers (Please read instructions before preparing Form.) Name of Broker/Dealer As of (Month/Day/Year) 8- SEC File No. CRD No. Address of Principal Place of Business (No. and Street) (City) (State) (Zip Code) INSTRUCTIONS GENERAL INSTRUCTIONS A.Answer questions applicable to the broker-dealer222s business activities and all 223Yes224 or 223No224 questions.Questions that cannot be answered because the broker-dealer does not engage in a particular activity do notneed to be answered. For example, a broker-dealer that does not hold customer and non-customer funds orsecurities does not need to answer Items 3.C-3.E. B.Definitions: for purposes of this Form: 1.223Affiliate224 means any person who directly or indirectly controls the broker-dealer or any person who isdirectly or indirectly controlled by or under common control with the broker-dealer. Ownership of 25% ormore of the common stock of an entity is deemed prima facie evidence of control. 2.223Bank224 has the same meaning as in 15 U.S.C. 78c(a)(6). 3.223Broker224 has the same meaning as in 15 U.S.C. 78c(a)(4). 4.223Dealer224 has the same meaning as in 15 U.S.C. 78c(a)(5). 5.223Carrying broker-dealer224 means a broker-dealer that carries customer or broker or dealer accounts andreceives or holds funds or securities for those customers. 6.223Clearing broker-dealer224 means a broker-dealer that clears transactions for itself or accounts of otherbroker-dealers either on a fully disclosed or omnibus basis. 7.223Customer224 has the same meaning as in 17 CFR 240.15c3-3(a)(1). American LegalNet, Inc. www.FormsWorkFlow.com 8.223Free credit balance224 means any liabilities of a broker-dealer to customers and non-customers that aresubject to immediate cash payment to customers and non-customers on demand, whether resulting fromsales of securities, dividends, interest, deposits, or otherwise, excluding, however, funds in commodityaccounts that are segregated in accordance with the Commodity Exchange Act or in a similar manner. 9.223Money Market Fund224 means any security issued by an investment company registered under section 8 ofthe Investment Company Act of 1940 that is considered a money market fund under Investment CompanyAct Rule 2a-7. 10.223Omnibus account224 means an account carried and cleared by another broker-dealer and containing accountsof undisclosed customers on a commingled basis that are carried individually on the books of the broker-dealer introducing the accounts. 11.223Private Fund224 means an issuer that would be an investment company as defined in section 3 of theInvestment Company Act of 1940 but for section 3(c)(1) or 3(c)(7) of that Act. 12.223Structured debt224 means any security or money market instrument issued by an asset pool or as part of anyasset-backed or mortgage-backed securities transaction. Structured debt is a broad category of financialinstrument and includes, but is not limited to, asset-backed securities such as residential mortgage-backedsecurities (223RMBS224) and other types of structured debt instruments such as collateralized debt obligations(223CDOs224), including synthetic and hybrid CDOs, or collateralized loan obligations (223CLOs224). INSTRUCTIONS FOR SPECIFIC LINE ITEMS Item 1.A Item 1.B Item 2.A Item 2.B Item 3.A Item 3.B Answer the question by checking the appropriate box. A broker-dealer must check 223Yes224 if it introduces any customer accounts to another broker-dealer on a fully disclosed basis. A broker-dealer that carries customer accounts and/or introduces customer accounts on an omnibus basis must check 223Yes224 if it also introduces one or more customer accounts to another broker-dealer on a fully disclosed basis. Item 1.B applies to broker-dealers that introduce customer accounts on a fully disclosed basis to one or more other broker-dealers. If Item 1.B applies, identify each broker-dealer to which customer accounts are introduced on a fully disclosed basis. Answer the question by checking the appropriate box. A broker-dealer must check 223Yes224 if it introduces any customer accounts to another broker-dealer on an omnibus basis. A broker-dealer that carries customer accounts (other than those introduced on an omnibus basis) and/or introduces customer accounts on a fully disclosed basis must check 223Yes224 if it also introduces one or more customer accounts to another broker-dealer on an omnibus basis. Item 2.B applies to broker-dealers that introduce customer accounts on an omnibus basis to one or more other broker-dealers. If Item 2.B applies, identify each broker-dealer to which customer accounts are introduced on an omnibus basis. Answer the question by checking the appropriate box. A broker-dealer that introduces customer accounts to another broker-dealer on an omnibus basis is a carrying broker-dealer with respect to those accounts under the Commission222s broker-dealer financial responsibility rules. If those accounts are the only accounts carried by the broker-dealer, check 223No224 in Item 3.A, as those accounts are addressed in Items 2.A and 2.B. Answer the question by checking the appropriate box. Answer 223Yes224 if accounts are carried by the broker-dealer for persons that are not 223customers224 as that term is defined in Rule 15c3-3 under the Securities Exchange Act of 1934. Examples of persons that are not customers of a broker-dealer include general partners, directors, or principal officers 226 such as the president, executive vice presidents, treasurer, secretary or any person performing similar functions 226 of the broker- American LegalNet, Inc. www.FormsWorkFlow.com dealer and accountholders that are themselves broker-dealers (unless such broker-dealer accountholders are required to be treated as customers under Rule 15c3-3). Item 3.C Identify the types of locations where the broker-dealer holds securities. Only identify types of locations where the broker-dealer holds securities directly in the name of the broker-dealer (i.e., do not identify a type of location if the broker-dealer only holds securities at the location through an intermediary). A location holds securities directly in the name of the broker-dealer if the location is aware of the identity of the broker-dealer and acts directly upon the broker-dealer222s instructions. A location holds securities through an intermediary if the location is not aware of the identity of the broker-dealer or will not act on instructions directly from the broker-dealer (i.e., the location holding securities for the broker-dealer would only act on instructions relating to the broker-dealer222s securities from the broker-dealer222s intermediary). The information required by Items 3.C.i-iii is intended to identify all locations used by the broker-dealer to hold securities listed onthe broker-dealer222s stock record, and to elicit information concerning the frequency with which thebroker-dealer performs reconciliations between the information on its stock record andinformation about the securities provided by the location. In Item 3.C.i, check all applicableboxes, and in Items 3.C.i-iii provide all applicable information as specified for each Item. Item 3.D Answer the questions in Items 3.D.i-iii by checking appropriate boxes and entering appropriate financial information, where applicable, and by providing explanations as requested. In Item 3.D.i, check 223Other224 if a type of security carried by the broker-dealer for customers is not listed onthe chart, and for each category of security, indicate by checking the approximate box for theapproximate U.S. dollar market value of the securities. Item 3.E Answer the questions in Items 3.E.i-iii by checking appropriate boxes and entering appropriate financial information, where applicable, and by providing explanations as requested. In Item 3.E.i, check 223Other224 if a type of security carried by the broker-dealer for persons that are notcustomers is not listed on the chart, and for each category of security, indicate by checking theappropriate box the a