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attention of petitioner, sometimes with a reference to Account
2900, and sometimes with no reference to either petitioner or
Account 2900. Petitioner almost always received repo trade
confirmation from the primary or secondary dealers with whom he
dealt. Petitioner never sent trade or repo confirmation to the
primary dealers with whom he dealt and he never sent trade or
repo confirmation to any of the counterparties with whom he
dealt. When B&C executed a trade for a retail customer, B&C
usually phoned the customer acknowledging that the trade had been
executed and sent the customer a written confirmation.
Petitioner received monthly statements from the primary
dealers with whom he dealt regularly, and he received monthly
statements from other primary dealers irregularly. He never sent
monthly statements to any of his primary dealer counterparties,
and he never sent monthly statements to any of his secondary
dealer counterparties. B&C routinely sent monthly statements to
its customers.
The Government securities dealers with whom petitioner dealt
kept various records on their customers' accounts, including
petitioner's. These records included customer account
agreements. B&C regularly used a customer agreement for its
retail customers during the subject years. Petitioner did not
receive a customer account agreement from any of the
counterparties with whom he dealt.
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