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Re: RealDutch post# 83247

Tuesday, 03/03/2015 4:54:08 PM

Tuesday, March 03, 2015 4:54:08 PM

Post# of 163716
RealDutch, this is true for offshore accounts that clear their shares through Brown Brothers Harriman (BBH).

SEB and Nordnet banks are some of the major Swedish brokers who utilize BBH. Frankly, most European houses do.

BBH was one of the few left who actually cleared OTC securities.

All of the big banks are almost now dealing exclusively with senior exchange listed securities. The risk is too heavy (and profit too little) to mess with OTC shares, anymore.

In the States, OTC shares trade between market makers, whereas once shares are purchased or sold from overseas, the respective brokerages have to clear through a US custodian (i.e. BBH or similar) where the shares are actually held on behalf of the brokerage / bank.

Basically, the issue resulted from a judgement / settlement between BBH and FINRA in which BBH provided "Corrective Action Statement" that it would take to cure the issues raised by FINRA.

If you go to the last 2 pages of the following pdf link titled "Corrective Action", you'll see where BBH has decided to 1) discontinue its brokerage services, and 2) no longer sell securities listed on OTC below $1; this item no longer applying to SIAF:

http://www.finra.org/web/groups/industry/@ip/@enf/@ad/documents/industry/p443448.pdf

From my understanding, since BBH was working toward mitigating its future risk, the likes of SEB and others went further to let their clients know that they were parting ways in holding OTC shares regardless of whether the shares were trading below or above a $1. Again, it's the exposure from dealing in an unregulated market that they're all trying to distance themselves from.

Frankly, I think it's a bit knee-jerky, but IMO the BBH issue gave these larger banks an out that they likely were looking for to begin with, and now that they found a scapegoat through BBH, they've decided to latch onto the "it's not me, it's them" bandwagon and are gradually having OTC shares moved away from their clients' accounts.

In other words, if SEB really wanted to they could have found another custodian to handle their OTC shares, but frankly saw this as a way to get out of the OTC business altogether.

What most of these individuals that hold SIAF shares at these institutions will need to do is to set up accounts with the likes of Interactive Brokers or with any of the market makers currently trading SIAF. They'll be glad to have your business if its available.

Honestly, I think that since this issue has been going on since June 2014 that some of the selling we've seen has been from those who had received notices earlier and frankly sold because they didn't want to mess with it, unfortunately.

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