- 27 -
deposits, assets and liabilities ratios, and standing with the
FDIC or FSLIC, to guide INC in selecting banks from which to
purchase certificates of deposit and term deposits.
Pursuant to its Agreement with LTD, INC assembled and
maintained a document entitled Institution Standings, which
reflected financial information regarding financial institutions.
Mr. Fahey contacted a list of banks throughout the United States
and obtained interest rates from each bank for 30-day, 60-day,
90-day, and 6-month placements of certificates of deposit and
term deposits. A list of the rates quoted by each bank was
telecopied, usually daily, to Mexico to inform promoters of the
current interest rates offered on the certificates of deposit and
term deposits. A promoter had no discretion to offer a client
higher interest rates than the rates reflected on the list but
did have the discretion to offer lower rates.
H. Financial Accounting and Client Statements for LTD
Pursuant to its Agreement with LTD, INC provided the
bookkeeping for LTD. INC maintained all of LTD's records of
clients' transactions, which LTD called "lower level documents".
Such records consisted of cash receipts, debit-credit memos, wire
transfers, and check requests reflecting every transaction for
every client. During the years in issue, LTD’s lower level
documents were maintained in the central filing system of INC in
San Antonio.
Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 NextLast modified: May 25, 2011