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, whether they effectively perform their possession or control calculations). Furthermore, FINRA will overview whether corporations manage adequate documentation to exhibit that securities are held freed from liens and encumbrances, specifically for securities held at overseas custodians. FINRA will critique no matter if corporations’ overseas depositories, clearing agencies and custodial banking companies are superior control spots, like whether or not firms have submitted programs Along important source with the SEC for these overseas custodial arrangements.
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Separately, exactly where the SBLOC lender is undoubtedly an affiliate on the member agency or other third party, the company have to build controls to earmark the collateral securing the SBLOC and make sure that the SBLOC collateral isn't dually pledged for any other extension of credit rating (