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part, in the United States in transactions with persons
situated within or without the United States:
(a) Receiving deposits of funds from the public,
(b) Making personal, mortgage, industrial, or other
loans to the public,
(c) Purchasing, selling, discounting, or negotiating
for the public on a regular basis, notes, drafts, checks,
bills of exchange, acceptances, or other evidences of
indebtedness,
(d) Issuing letters of credit to the public and
negotiating drafts drawn thereunder
(e) Providing trust services for the public, or
(f) Financing foreign exchange transactions for the
public.
LTD engaged in four of the six activities listed in the
regulation. LTD engaged in "Receiving deposits of funds from the
public" by receiving deposits of funds from its clients into its
client clearing account. LTD engaged in "Making personal * * *
loans to the public" by making loans to its clients. LTD engaged
in "Purchasing * * * [and] selling * * * for the public on a
regular basis * * * evidences of indebtedness" by purchasing and
selling for its clients on a regular basis: (1) Certificates of
deposit and (2) interests in such certificates of deposit. LTD
engaged in "Issuing letters of credit to the public". Finally,
LTD engaged in "Financing foreign exchange transactions for the
public" by effecting currency exchange transactions for the
public with Mexican banks. LTD engaged in all of the above
activities,12 in whole or in part, in the United States in
12
Additionally, LTD engaged in creating and operating a U.S.
(continued...)
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