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employees. The back office (also known as the swaps operations
group) ensured the integrity of the paperwork on FNBC’s swaps and
other multiple trading products. The back office, among other
things, verified that swap master agreements were executed, that
confirmations on swap transactions were received, and that
periodic payments on swaps were properly transacted.
2. Traders
a. Function
FNBC’s traders were the individuals who on behalf of FNBC
negotiated and entered into swap transactions with other dealers
or brokers. In order to effect these transactions, FNBC’s
traders usually dealt directly with the brokers or with their
(FNBC’s traders’) counterparts at the other dealers. In swaps
with other dealers, including brokered transactions and those
swaps which a dealer entered into for its own use (e.g., to hedge
its own books), the FNBC trader usually determined the final
price for the swap and was authorized to enter into the
transaction without specific credit approval if sufficient credit
limits had already been established for the counterparty/dealer.
If the counterparty was strictly an end-user, as opposed to a
dealer acting either as a dealer or as an end user, the FNBC
trader would not deal directly with the counterparty. Rather, a
marketer would handle negotiations with the counterparty after
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