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required firms like B&C, already registered with and regulated by
the CFTC as an FCM, to register with the SEC and the NASD. B&C
initially applied for registration but later withdrew its
application on the basis of its understanding that it was not
required to register because it was an FCM. Petitioner, who was
not personally registered as an FCM, never registered with the
SEC as a Government securities dealer for a trade or business
separate from B&C's, and he never registered with the NASD as a
dealer for a trade or business separate from B&C's.
Generally, any person acting as a dealer in securities and
maintaining a place of business in Illinois must register with
the Illinois secretary of state. B&C did not register with the
Illinois secretary of state because of its understanding that it
was exempt from registration requirements as an FCM. Petitioner
never registered with the Illinois secretary of state as a dealer
for a trade or business separate from B&C's.
V. Petitioner/B&C Trading in Treasury Securities Cash Market
Petitioner traded Treasury securities through Account 2900
with the following known counterparties:
Aubrey G. Lanston & Co., Chicago
Barclays de Zoete Wedd, New York
Chemical Bank, New York
Chicago Research & Trading Co., New York
Citibank, N.A./Citicorp, New York
Continental Illinois National Bank and Trust Co., Chicago
Daiwa Securities America, Inc., New York
Discount Corp. of New York
Drexel Burnham Lambert Government Securities, Inc., New York
* Fidelity Investments Brokerage Services, Boston
First Boston Corporation, New York
First Interstate Bank of California, Chicago
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