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Language Notification

Please be advised that future verbal and written communications from the bank may be in English only. These communications may include, but are not limited to, account agreements, statements and disclosures, changes in terms or fees; or any servicing of your account.

Por favor, tenga en cuenta que es posible que las comunicaciones futuras del banco, ya sean verbales o escritas, sean únicamente en inglés. Estas comunicaciones podrían incluir, entre otras, contratos de cuentas, estados de cuenta y divulgaciones, así como cambios en términos o cargos o cualquier tipo de servicio para su cuenta.

Informamos que as futuras comunicações do banco, verbais e escritas, podem estar disponíveis apenas em inglês. Essas comunicações podem incluir, entre outras, acordos de conta, extratos de conta e divulgações, alterações aos termos ou tarifas, ou qualquer tipo de serviço pertinente à sua conta.

仅此通知,本行即日起发出的口头及书面通信可能将只提供英文版本。这些通信可能包括但不限于账户协议,账单和通知,条款或费用变更;或任何为您账户提供的服务。

Please be advised that future verbal and written communications from the bank may be in English only. These communications may include, but are not limited to, account agreements, statements and disclosures, changes in terms or fees; or any servicing of your account.

Por favor, tenga en cuenta que es posible que las comunicaciones futuras del banco, ya sean verbales o escritas, sean únicamente en inglés. Estas comunicaciones podrían incluir, entre otras, contratos de cuentas, estados de cuenta y divulgaciones, así como cambios en términos o cargos o cualquier tipo de servicio para su cuenta.

Informamos que as futuras comunicações do banco, verbais e escritas, podem estar disponíveis apenas em inglês. Essas comunicações podem incluir, entre outras, acordos de conta, extratos de conta e divulgações, alterações aos termos ou tarifas, ou qualquer tipo de serviço pertinente à sua conta.

仅此通知,本行即日起发出的口头及书面通信可能将只提供英文版本。这些通信可能包括但不限于账户协议,账单和通知,条款或费用变更;或任何为您账户提供的服务。

How-secure-are-your-assets-held-in-custody

Perspectives

How secure are your assets held in custody?

Michael Grippo

By Michael Grippo

Head of Custody Sales - Americas

July 8, 2020Posted InCustody

When considering the safety of our assets, our first thoughts are usually about the risks involved with particular investments. How much volatility might our equities suffer? Might the issuer of a certain bond default? However, the safety of such assets can also be affected by the type of custody relationship under which they are held – either with a bank or a broker-dealer. Despite this, investors often pay little attention to the significant differences between these two types of custodians.

Not all accounts offered by broker-dealer custodians are equal when it comes to asset safety. Client assets held in margin accounts are not fully segregated, as a result, the broker-dealer may pledge those assets as collateral or use them for other client’s needs, such as covering short positions. While this is not true of broker-dealer cash accounts – where the client has paid in full for all assets held – the distinction does not matter in a worst-case scenario where the broker dealer fails.

If the broker-dealer fails, all the assets held in the broker-dealer’s custody are commingled together.  This happens irrespective of whether the assets belong to client cash accounts or a client’s margin account. Clients with accounts in the U.S. have to wait for the Securities Investor Protection Corporation (SIPC) to manage an orderly recovery, which can be a lengthy process. Based on the results of this assessment, a broker-dealer’s clients may only get back a pro rata share or distribution of their affected positions. Eventually, clients may be able to recover all of their assets, but there is no guarantee of this. Only once the assessment and recovery are complete would clients be able to transfer their assets to another custodian.

By contrast, bank custodians fully segregate client assets from their own assets: clients remain the main beneficial owners of their own assets. As a result, the bank cannot lend out (or ‘hypothecate’) client assets held in bank custody. In the event of a bank failing, the Federal Deposit Insurance Corporation (FDIC) would facilitate the return of clients’ assets in custody.

The likeliest times for custodians to experience distress are during periods of intense financial and economic turbulence. While the financial system has continued to function smoothly during the COVID-19 pandemic so far, the air of uncertainty has prompted investors to revisit the important differences between holding assets with a bank or broker-dealer custodian.

Although very important, asset safety is only one difference between broker-dealer and bank custodians. Broker-dealers are typically used by clients for their ability to generate ideas and place trades. By contrast, bank custody is a specialized service focused on the administration and reporting of client portfolios; bank custodians are agnostic as it relates to the generation of ideas or execution of trades. The table below highlights further considerations when comparing the two types of custody services, which can impact how you grow and preserve your wealth over time.

 

Broker-dealer custodian

Bank custodian

Trade execution

Clients may be required to trade through the broker-dealer’s own desk

Clients have the flexibility to trade through any third-party execution desk that makes a delivery versus payment (DVP) account available, allowing their trades to settle through their bank custodian

 

 Costs

Typically no separate custody fee, as revenue is earned on trade commissions and mark-ups charged on trades done through the trading desk

Separate custody fee for safekeeping client assets; client negotiates trade commissions and mark-ups charged on trading through the respective trading desks they use

 

Borrowing

(In the US)

Margin lending (reg. T)1

Reg. U collateralized lending i.e. purpose vs non-purpose2

 

Service

Typically, the focus is on advice and transactional needs

Typically, there is a dedicated team of custody specialists working directly with clients or their intermediaries on administrative and reporting needs

 

Regulators

(In the US)

The Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA)

 

The Federal Reserve Board and the Office of the Comptroller of the Currency (OCC)

Insurance

(In the US)

Securities Investor Protection Corporation (SIPC) for investments and cash

Federal Deposit Insurance Corporation (FDIC) for on balance sheet cash deposits

 

 

 Often, investors don’t understand the differences or nuances of their custody arrangements. As a client’s portfolio grows more complex, spanning multiple accounts and providers, understanding where assets are held is pivotal, and the need to centralize assets for safety benefits, enhanced reporting, and ease of administration become more pronounced.

To learn more about the differences between broker-dealer and bank custodians, please read our recently published white paper: Is your custodian helping you protect and grow your wealth?

1 Regulation T was established by the Board of Governors of the Federal Reserve System and is a collection of provisions that govern investors’ cash accounts and the amount of credit that brokerage firms and dealers may extend to customers for the purchase of securities.

2 Regulation U is a Federal Reserve Board regulation that governs loans by entities involving securities as collateral and the purchase of securities on margin. Regulation U limits the amount of leverage that can be extended for loans secured by securities for the purpose of buying more securities.

 

In the Americas, custody services are provided by Citibank N.A. in the U.S.

Not all products and services are available in all locations.