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deposits. Mr. Fahey testified that he compiled a list of banks
that Mr. Zollino approved.
Pursuant to its Agreement with LTD, INC assembled and
maintained a document entitled Institution Standings, which
reflected the financial information of financial institutions
that met the Inver Group’s criteria. Mr. Fahey contacted banks
throughout the United States that were on the approved list 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 certificates of deposit and
term deposits. Mr. Fahey testified that he "got approval of the
banks that were on * * * [the list telecopied to promoters], but
not approval on a daily basis for the rates that I quoted on
there." Promoters sold the certificates of deposit or term
deposits (or interests therein) to clients, who wired funds
directly to LTD’s account in San Antonio.
On its own, albeit pursuant to the criteria established by
Inver Group and only from banks that had been approved by Mr.
Zollino, INC purchased certificates of deposit or term deposits
in either the client’s name (for amounts greater than $98,000) or
in LTD’s name (for amounts less than $98,000, in increments of
$10,000). INC purchased the certificates of deposit and term
deposits on behalf of LTD and LTD’s clients with great frequency
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