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of a bank failure or other loss of the investment. Because there
was no Government-sponsored insurance on the non-U.S.
investments, there was no purpose in dividing the purchases into
amounts of $100,000 or under. Consequently, all of the non-U.S.
investments were in amounts of $1 million or more, which paid
higher rates of return.
LTD offered its clients investments in non-U.S. certificates
of deposit through products named "Eurodeposits", "InverCedes",
and "InverCede2". LTD offered its clients investments in non-
U.S. term deposits through products named "Liquid Assets" and
"Term Deposits". LTD offered its clients a non-U.S. investment
named "Asset Management Account". The names denoted different
methods of timing of interest paid to the client, availability of
funds, deposit amounts, etc. Each such certificate of deposit or
term deposits, however, constituted a purchase from an omnibus
account in bank deposits outside the United States and Mexico.
INC collected quotations of rates on certificates of deposit
and term deposits from various banks and telecopied to the
promoters term sheets listing all of the quoted rates. The term
sheets listed the top rate paid by each bank, and promoters
selling such investments negotiated a rate of return with
clients. Promoters could negotiate a lower, but not higher, rate
than the one listed on the term sheets. To the extent that a
bank might quote a higher rate of return because of the size of
the pooled deposit or the volume of transactions, LTD was
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