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pursuant to a request by a customer of petitioner to do a trade.
Many times petitioner would submit a bid to CF and ask that it be
continuously re-input into the CF system until petitioner was
successful in buying the desired security. Petitioner on
occasion gave discretion to primary dealers as to price for both
auction and nonauction transactions. On other occasions,
petitioner would give the primary dealers "orders".11 Petitioner
never received a customer order in Government securities.
Petitioner typically financed his purchases of Treasury
securities through repurchase agreements. Ms. James contacted
primary dealers and CF to locate the best rates. Petitioner had
credit lines with 20 different primary and secondary dealers, and
he could finance his purchases through any of these firms.
Petitioner sometimes financed Treasury securities through a
dealer other than the dealer from whom he purchased the
securities. Petitioner typically dealt with a variety of
counterparties in the course of acquiring, financing, and selling
particular positions.
Government securities dealers usually orally confirm a trade
and mail written confirmation on it. When petitioner executed
trades of Treasury securities with primary dealers, the primary
dealers always mailed the confirmation to B&C, sometimes to the
11 An "order" is a customer's request to a dealer to
purchase or sell a specified quantity of securities on the
customer's behalf either at a specified price or at the best
available price in the market.
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