-100-
b. Practice as to Quotations
FNBC’s marketers negotiated the best price (within the
limits set by a trader) for any swap with a nondealer end-user
but needed the approval of an FNBC trader for any negotiated
price as to the swap. The marketer would communicate to an FNBC
trader the terms of a proposed swap for a nondealer end-user
customer and obtain a price quote. The marketer could build in
an additional spread but could not decrease the price quoted by
the trader without the trader’s approval.33 The trader had to
sign the trade ticket and, in so doing, took on all
responsibility for risk-managing the swap. The marketer had no
responsibility for risk management.
4. Relationship Managers
Each customer of FNBC had an assigned FNBC relationship
manager who was responsible for generating business from the
customer and overseeing FNBC’s dealings with the customer. The
relationship manager was not part of the group that included swap
traders and marketers. Marketers worked with the relationship
managers to explain to customers how they could benefit from
using FNBC’s swap products. Relationship managers had overall
responsibility for all of the customers’ transactions (e.g., bond
33 A client that received many services from an FNBC
marketer might allow the marketer to add to the spread to pay for
the services.
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