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SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
______________
FORM 8-K
CURRENT REPORT
PURSUANT TO SECTION 13 OR 15(d) OF THE
SECURITIES EXCHANGE ACT OF 1934
Date of report (Date of earliest event reported) December 4, 1994
BANKERS TRUST NEW YORK CORPORATION
(Exact Name of Registrant as Specified in Charter)
New York 1-5920 13-6180473
(State or Other Jurisdiction (Commission (IRS Employer
of Incorporation) File Number) Identification No.)
280 Park Avenue, New York, New York 10017
(Address of Principal Executive Offices) (Zip Code)
Registrant's telephone number, including area code (212) 250-2500
N/A
(Former Name or Former Address, if Changed Since Last Report)
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Item 5. Other Events
On December 5, 1994, Bankers Trust New York Corporation (the
"Corporation") announced that it and its subsidiaries Bankers Trust Company
and BT Securities Corporation had executed a written agreement with the
Federal Reserve Bank of New York. A copy of that written agreement is
included as Exhibit 99.1 to this Current Report on Form 8-K. The
Corporation issued a press release regarding this written agreement, a copy
of which is included as Exhibit 99.2 to this Current Report on Form 8-K.
Item 7. Financial Statements, Pro Forma Financial Information and
Exhibits
(c) Exhibits.
99.1 Form of Written Agreement, dated as of December __, 1994,
by and among Bankers Trust New York Corporation, Bankers
Trust Company, BT Securities Corporation and the Federal
Reserve Bank of New York.
99.2 Press Release of Bankers Trust New York Corporation,
dated December 5, 1994.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934,
the registrant has duly caused this report to be signed on its behalf by
the undersigned hereunto duly authorized.
Date: December 5, 1994
BANKERS TRUST NEW YORK CORPORATION
By: /s/ James T. Byrne, Jr.
Name: James T. Byrne, Jr.
Title: Secretary
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INDEX TO EXHIBITS
99.1 Form of Written Agreement, dated as of December __, 1994, by
and among Bankers Trust New York Corporation, Bankers Trust
Company, BT Securities Corporation and the Federal Reserve Bank
of New York.
99.2 Press Release of Bankers Trust New York Corporation, dated
December 5, 1994.
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Exhibit 99.1
UNITED STATES OF AMERICA
BEFORE THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C.
- - - - - - - - - - - - - - - - - - - - x
WRITTEN AGREEMENT By :
and Among
: DOCKET NOs.
BANKERS TRUST NEW YORK CORPORATION 94-082-WA/RB-HC
New York, New York : 94-082-WA/RB-SM
94-082-WA/RB-HCS
and :
BANKERS TRUST COMPANY :
New York, New York
:
and
:
BT SECURITIES CORPORATION
New York, New York :
and :
FEDERAL RESERVE BANK OF NEW YORK :
New York, New York
- - - - - - - - - - - - - - - - - - - - x
WHEREAS, in recognition of their common goals to ensure the
prudent operation of the leveraged derivative transaction business, and to
ensure compliance with applicable federal and state laws, rules and
regulations by Bankers Trust New York Corporation, New York, New York
("BTNYC"), a registered bank holding company, Bankers Trust Company, New
York, New York ("Bankers Trust"), a State-member bank, and BT Securities
Corporation, New York, New York ("BT Securities"), a wholly owned
subsidiary of BTNYC authorized pursuant to Section 4(c)(8) of the Bank
Holding
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Company Act of 1956, as amended, to engage to a limited extent in
underwriting and dealing of securities, BTNYC, Bankers Trust, BT Securities
(collectively "BT"), and the Federal Reserve Bank of New York (the "Reserve
Bank") have mutually agreed to enter into this Written Agreement (the
"Agreement");
WHEREAS, for purposes of this Agreement the leveraged
derivative transaction business is intended to encompass derivative
transactions (i) where a market move of two standard deviations in the
first month would lead to a reduction in value to the counterparty of the
lower of 15 percent of the notional amount or $10 million, and (ii) for
notes or transactions with a final exchange of principal, where
counterparty principal (rather than coupon) is at risk at maturity, and
(iii) for coupon swaps, where the coupon can drop to zero (or below) or
exceed twice the market rate for that market and maturity, and (iv) for
spread trades that include an explicit leverage factor, where a spread is
defined as the difference in the yield between two asset classes (such
transactions shall be referred to herein individually as "LDTs" and
collectively the "LDT Business");
WHEREAS, the Reserve Bank is currently engaged in an annual
inspection and examination of BTNYC and its banking and nonbanking
subsidiaries; and, in connection with that review, it has had a series of
discussions with representatives of
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BTNYC and its subsidiaries regarding the management and control of the LDT
Business;
WHEREAS, as a result of such discussions, BTNYC has undertaken
a comprehensive review of its LDT Business under the close direction of the
audit committee of BTNYC's board of directors, and with active
participation of outside counsel and accountants, to ensure that the LDT
Business will be appropriately managed and controlled going forward;
WHEREAS, a written report of the findings and conclusions of
the above-referenced comprehensive review has been presented to, and
approved by, BTNYC's board of directors on November 15, 1994, and forwarded
to the Reserve Bank, and such findings and conclusions will be reflected in
the development and implementation of improved polices and procedures
governing the LDT Business;
WHEREAS, upon the recommendation of the Reserve Bank and the
staff of the Board of Governors of the Federal Reserve System ("Board of
Governors"), the Board of Governors has authorized the Reserve Bank to
enter into this Agreement with BTNYC, Bankers Trust, and BT Securities;
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WHEREAS, on December , 1994, the respective boards of
directors of BTNYC and Bankers Trust, at duly constituted meetings, each
adopted a resolution authorizing and directing Charles S. Sanford, Jr.,
Chairman of the Board, to enter into this Agreement on behalf of BTNYC and
Bankers Trust, and consenting to compliance with each and every provision
of this Agreement by BTNYC, Bankers Trust and their institution-affiliated
parties, as defined in Sections 3(u) and 8(b)(3) of the Federal Deposit
Insurance Act, as amended (the "FDI Act") (12 U.S.C. secs. 1813(u) and
1818(b)(3)); and
WHEREAS, on December , 1994, the board of directors of BT
Securities, at a duly constituted meeting, adopted a resolution authorizing
and directing Howard M. Schneider, President, to enter into this Agreement
on behalf of BT Securities, and consenting to compliance with each and
every provision of this Agreement by BT Securities and its institution-
affiliated parties.
NOW, THEREFORE, before the taking of any testimony or
adjudication of or finding on any issue of fact or law herein, and without
this Agreement constituting an admission of any allegation made or implied
by the Board of Governors or the Reserve Bank, BTNYC, Bankers Trust, BT
Securities, and the Reserve Bank hereby agree as follows:
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Client Selection and Appropriateness
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1. (a) BT shall conduct its LDT Business in a manner which
seeks to reasonably ensure that each LDT customer has the capability to
understand the nature and material terms, conditions, and risks of any LDT
entered into with the customer.
(b) By December 31, 1994, BTNYC, Bankers Trust, and BT
Securities shall jointly develop and submit to the Reserve Bank written
policies and procedures designed to accomplish the objectives set forth in
paragraph 1(a) hereof and to ensure that BT's client selection and
appropriateness policies for the LDT Business are otherwise consistent with
safe and sound banking practices.
LDT Marketing Policies and Procedures
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2. (a) BT shall make disclosures in connection with sales and
restructurings of LDTs that provide customers with sufficient information
to allow the customer to understand the nature and material terms,
conditions, and risks of any LDT or restructuring thereof entered into with
the customer.
(b) By December 31, 1994, BTNYC, Bankers Trust, and BT
Securities shall jointly develop and submit to the Reserve Bank written
policies and procedures designed to accomplish the objectives set forth in
paragraph 2(a) hereof and to ensure that BT's marketing and sales practices
in the LDT Business are otherwise consistent with safe and sound
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banking practices. The policies and procedures submitted shall address,
consider, and include, at a minimum, the following:
(1) New product identification and introduction;
(2) disclosures to each customer of the nature, and material terms,
conditions, and risks of LDTs to be entered into with the
customer; and
(3) distribution of (A) written term sheets and (B) sensitivity
analyses designed to illustrate a broad range of outcomes and
distribution of risks at maturity. Price sensitivity over the
life of a transaction will be addressed by the periodic
quotation of indicative prices and by the inclusion of
appropriate disclosure language (to be agreed with the Reserve
Bank) in term sheets, sensitivity analyses, and indicative
price quote communications. A sensitivity analysis should be
delivered (i) upon entering into an LDT, and (ii) upon receipt
of a request from a customer for an update of such information.
(Each term sheet and sensitivity analysis shall set out the
definitions and assumptions used therein. Written
communications to a customer after execution of an LDT shall
include a notice to the customer that an updated sensitivity
analysis is available upon request.)
LDT Pricing and Valuation
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3. (a) BT shall conduct its LDT Business in a manner which
seeks to ensure reasonable transparency of LDT pricing and valuation to its
customers.
(b) By December 31, 1994, BTNYC, Bankers Trust, and BT
Securities shall jointly develop and submit to the Reserve Bank written
policies and procedures designed to accomplish the objectives set forth in
paragraph 3(a) hereof and to ensure that BT's pricing and valuation
practices in the LDT Business are otherwise consistent with safe and sound
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banking practices. Such policies and procedures shall, at a minimum,
address, consider, and include the following:
(1) The provision of indicative quotes and firm quotes to
customers;
(2) the provision of daily indicative quotes to customers with
highly market sensitive LDTs, and monthly indicative quotes to
customers with all other types of LDTs;
(3) the methodology for making valuation adjustments;
(4) the analytical foundation for the valuation adjustment
methodology; and
(5) documentation and review of customer quotes as they relate to
LDT values reflected in BT's books, and all valuation
adjustment decisions.
LDT Management and Supervision
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4. By December 31, 1994, BTNYC, Bankers Trust, and BT
Securities shall jointly develop and submit to the Reserve Bank a written
plan to augment the management and supervision process with respect to BT's
LDT Business. At a minimum, the plan shall address, consider and include
the following:
(a) The review of client relationships and individual transactions;
(b) the oversight and control of the structuring and restructuring
of individual transactions;
(c) the oversight and performance evaluation of individual officers
and employees in the LDT Business by supervisors and managers
with responsibility for the LDT Business;
(d) the oversight and performance evaluation of managers of the LDT
Business by senior management of BTNYC, Bankers Trust, and BT
Securities;
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(e) the monitoring and correction of weaknesses and deficiencies in
the LDT Business noted in regulatory reports of examination and
inspection; and
(f) the monitoring of BT's compliance in its LDT Business with all
applicable federal and state laws, rules, and regulations, this
Agreement, and the policies and procedures of BTNYC, Bankers
Trust, and BT Securities.
Compliance Committee
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5. (a) Within 15 days of this Agreement, the board of
directors of BTNYC shall form a Compliance Committee, comprised of outside
directors, to monitor compliance with the provisions of the Agreement.
(b) Beginning on March 31, 1995, BTNYC's management shall
prepare a quarterly report for the review and approval of the Compliance
Committee which describes and documents BT's compliance with the plans,
policies, and procedures, and the program and engagement letter required by
this Agreement. The Compliance Committee shall provide such written
reports to the Reserve Bank contemporaneous with their submission to the
board of directors of BTNYC.
LDT Staff Training
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6. By December 31, 1994, BTNYC, Bankers Trust and BT
Securities shall jointly develop and submit to the Reserve Bank a training
program for their marketing and sales staffs in the LDT Business. The
program, at a minimum, shall address and consider the requirements of this
Agreement, other
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applicable BT internal policies and procedures, and business ethics.
LDT Credit Administration
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7. By December 31, 1994, BTNYC, Bankers Trust and BT
Securities shall jointly develop and submit to the Reserve Bank written
policies and procedures regarding the establish-ment and administration of
LDT Business credit facilities. The LDT Business credit administration
policies and procedures shall, at a minimum, address, consider and include
the following:
(a) The credit approval and post-approval credit review processes;
(b) monitoring and reporting of customer current market values and
potential exposures, and actions to be taken as a result of
such monitoring and reporting;
(c) evaluation of the appropriateness and consistency with sound
banking practice of customer transactions, including those of
structured note purchasers, with special attention to
restructurings; and
(d) standards for credit file documentation and maintenance.
Internal Audit and Internal Reporting
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8. (a) By December 31, 1994, BTNYC, Bankers Trust, and BT
Securities shall jointly develop and submit to the Reserve Bank written
policies and procedures designed to strengthen and maintain internal audit
coverage and audit procedures for the LDT Business.
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(b) By December 31, 1994, BTNYC, Bankers Trust and BT
Securities shall jointly develop and submit to the Reserve Bank written
policies and procedures relating to BT's internal reporting system which
are designed, at a minimum, to improve the availability of information to
BT's senior management regarding the exposure of BTNYC, or any of its
subsidiaries, to LDT Business customers.
Affiliate Transactions and Firewalls
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9. (a) BTNYC, Bankers Trust, and BT Securities shall not
engage, directly or indirectly, or participate in any violation of Section
23B of the Federal Reserve Act (the "FRA") (12 U.S.C. sec. 371c-1) or of
any of the conditions imposed by the Board of Governors in connection with
its approval for BTNYC and BT Securities to engage in any securities-
related activities (commonly referred to as "Firewalls") including the
provisions of the Order Conditionally Approving Applications to Engage, to
a Limited Extent, in Underwriting and Dealing in Certain Securities, dated
January 18, 1989, as amended by subsequent orders issued by the Board of
Governors, or interpretations thereof, in the conduct of BT's LDT Business.
(b) By December 31, 1994, BTNYC, Bankers Trust and BT
Securities shall jointly conduct, with the assistance of outside counsel, a
comprehensive review of (i) the method for allocating revenue and expense
in the LDT Business among
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Bankers Trust and its "affiliates" as defined in Section 23A of the FRA (12
U.S.C. sec. 371c), and (ii) BT's compliance in connection with its LDT
Business with Firewalls related to corporate separateness and management
interlocks. By January 31, 1995, BTNYC shall submit to the Reserve Bank a
written report of the methodology, findings and conclusions of the
comprehensive review, and a description of any changes made or contemplated
as a result of such findings and conclusions. At a minimum, this
comprehensive review shall address, consider, and include the following:
(1) An analysis and review of LDTs for market risk, credit risk and
other contingencies related to the LDT Business;
(2) the nature and extent of services provided to Bankers Trust by
BT Securities in marketing LDTs, including a survey of current
market practice regarding compensation for such services;
(3) the appropriate allocation between Bankers Trust and BT
Securities of losses arising from market risk, credit risk, and
other contingencies;
(4) the fairness to Bankers Trust of the compensation it has paid
to BT Securities for services rendered in connection with LDTs
between Bankers Trust and its customers from January 1, 1992
through the date of this Agreement;
(5) the amount to be reimbursed by BT Securities to Bankers Trust,
including appropriate interest, for all compensation received
by BT Securities for services rendered in connection with LDTs
in excess of Bankers Trust's current profit allocation policy
since the adoption of its current policy;
(6) the additional amount, if any, to be reimbursed by BT
Securities to Bankers Trust, including appropriate interest, to
cure any violation of Section 23B of the FRA, uncovered in the
review,
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in connection with the provision of services in the LDT
Business between January 1, 1992 and the date of this
Agreement; and
(7) allocation of responsibilities in the LDT Business between
Bankers Trust and BT Securities including organizational charts
and reporting lines.
(c) By January 31, 1995, BT Securities shall make payment
to Bankers Trust to the extent required by paragraphs 9(b)(5) and (6)
hereof and provide the Reserve Bank with a written statement detailing the
amount of compensation paid, including interest, and the methodology used
to calculate the aggregate amount of the payment.
(d) By January 31, 1995, BTNYC shall develop and submit
to the Reserve Bank compliance policies and procedures designed to ensure
that Bankers Trust complies with Section 23B of the FRA and applicable
Firewalls in connection with its LDT Business and the findings and
conclusions of the comprehensive review required by paragraph 9(b) hereof.
(e) By January 31, 1995, Bankers Trust shall obtain an
opinion of outside counsel as to whether the methodology for allocating
revenue and expense in the LDT Business among Bankers Trust and its
affiliates complies with Section 23B of the FRA, and shall provide a copy
of the counsel's opinion to the Reserve Bank.
Special Counsel
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10. (a) As soon as practical, but no later than December 31,
1994, BTNYC shall retain qualified independent
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legal counsel, acceptable to the Reserve Bank, to conduct a review of: (1)
any conduct by BT officers and employees related to the LDT Business which
does not comport with industry standards, BT's Code of Conduct, or
applicable law; and (2) whether any disciplinary action is appropriate with
respect to officers and employees engaged in the LDT Business, including
failure by management to supervise adequately BT employees.
(b) Within 10 days of the retention of special counsel, BTNYC
shall submit to the Reserve Bank a proposed engagement letter relating to
the scope of the independent counsel review required by this paragraph.
The engagement letter shall, at a minimum, include a requirement that (1)
to the extent possible, the special counsel review will be completed within
120 days of inception; (2) the special counsel will prepare a comprehensive
report regarding his or her findings; and (3) the special counsel's report
will be provided contemporaneously to BTNYC's board of directors and to the
Reserve Bank upon its completion.
Restrictions on Certain Officers and Employees
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11. BTNYC, Bankers Trust, and BT Securities shall provide the
Reserve Bank with 30 days' prior written notice before any officer and
employee who has been reassigned as of the date of this Agreement, or
thereafter, on account of his
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or her LDT Business-related activity is returned to his or her prior
position or assigned to any position involving, in any manner, the sale of
any products to BT customers.
Restrictions on New LDT Business
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12. BTNYC, Bankers Trust, and BT Securities shall continue to
comply with the interim written LDT Business policy approved by the audit
committee of BTNYC's board of directors on October 7, 1994, and submitted
to the Reserve Bank, until the plans, policies, procedures, and the program
are approved and adopted in accordance with the provisions of this
Agreement, and the Reserve Bank agrees in writing to the termination of the
interim written policy.
Review and Approval of Plans
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13. The plans, policies, procedures, training program
and engagement letter required by paragraphs 1(b), 2(b), 3(b), 4, 6, 7,
8(a), 8(b), 9(d), and 10(b) hereof shall be reviewed and approved by
BTNYC's board of directors, or a designated committee thereof, prior to
submission to the Reserve Bank. Such plans, policies, procedures, training
program, and engagement letter shall be submitted to the Reserve Bank
within the required time periods set forth in this Agreement. In the
absence of any objections from the Reserve Bank within 30 days of receipt,
BTNYC, Bankers Trust, and BT Securities shall each, as soon as practical,
adopt,
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where applicable, the plans, policies, procedures, training program, and
engagement letter, including any Reserve Bank modifications thereto, and
then shall comply fully with them. The adopted plans, policies,
procedures, training program, and engagement letter shall not be amended or
rescinded without 30 days' prior written notice to the Reserve Bank, which
may offer objections to any amendment or rescission.
Communications
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14. All communications regarding this Agreement shall be sent
to:
(a) Mr. Chester B. Feldberg
Executive Vice President
Federal Reserve Bank of New York
33 Liberty Street
New York, NY 10045
(b) Mr. Charles S. Sanford, Jr.
Chairman of the Board
Bankers Trust New York Corporation
and
Bankers Trust Company
One Bankers Trust Plaza
130 Liberty Street
New York, NY 10006
(c) Mr. Howard M. Schneider
President
BT Securities Corporation
One Bankers Trust Plaza
130 Liberty Street
New York, NY 10006
Miscellaneous Provisions
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15. The provisions of this Agreement shall be binding on
BTNYC, Bankers Trust, BT Securities and each of
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their institution-affiliated parties, in their capacities as such, and
their successors and assigns.
16. Each provision of this Agreement shall remain effective
and enforceable until stayed, modified, terminated or suspended in writing
by the Reserve Bank.
17. The provisions of this Agreement shall not bar, estop, or
otherwise prevent the Board of Governors or any federal or state agency or
department from taking any other action affecting BTNYC, Bankers Trust, and
BT Securities or any of their current or former institution-affiliated
parties.
18. Notwithstanding any provision of this Agreement to the
contrary, the Reserve Bank may, at its sole discretion, grant written
extensions of time to BTNYC, Bankers Trust, and BT Securities to comply
with any provision of this Agreement.
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19. This Agreement is a "written agreement" for the purposes
of Section 8 of the FDI Act (12 U.S.C. sec. 1818).
IN WITNESS THEREOF, the parties have caused this Agreement to
be executed as of this day of December, 1994.
BANKERS TRUST NEW YORK FEDERAL RESERVE BANK OF
CORPORATION NEW YORK, Pursuant to
Delegated Authority
BANKERS TRUST COMPANY
New York, New York
By: By:
Charles S. Sanford, Jr. Chester B. Feldberg
Chairman of the Boards Executive Vice President
BT SECURITIES CORPORATION
New York, New York
By:
Howard M. Schneider
President
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The undersigned directors of BTNYC acknowledge that each has read the
foregoing and approves of the consent thereto by BTNYC.
Charles S. Sanford, Jr. George B. Beitzel
Phillip A. Griffiths William R. Howell
Jon M. Huntsman Vernon E. Jordan, Jr.
Hamish Maxwell Donald F. McCullough
N.J. Nicholas Jr. Russell E. Palmer
Didier Pineau-Valencienne Eugene B. Shanks, Jr.
Patricia Carry Stewart George J. Vojta
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Exhibit 99.2
Corporate Communications Division, 280 Park Avenue, New York Mailing
Address: P.O. Box 318, New York, N.Y. 10008-0318
Bankers Trust New York Corporation
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News Release
For Release:
BANKERS TRUST AND FEDERAL RESERVE BANK OF NEW YORK ENTER
INTO AGREEMENT FOR LEVERAGED DERIVATIVE TRANSACTION BUSINESS
New York, December 5, 1994 -- Bankers Trust New York Corporation and
two of its subsidiaries, together with the Federal Reserve Bank of New
York, have mutually agreed to enter into a written agreement regarding
Bankers Trust's leveraged derivative transaction (LDT) business. The
agreement notes that it was entered into by each party "in recognition of
their common goals to ensure the prudent operation of the leveraged
derivative transaction business."
"The agreement does not affect our overall derivatives business but
is limited specifically to our leveraged derivative transaction activities,
which have never been a core business for Bankers Trust," said Bankers
Trust Chairman Charles S. Sanford, Jr. He noted that leveraged derivative
transactions accounted for less than 5% of Bankers Trust's total revenue
for the period beginning January 1, 1993 through the first three quarters
of 1994.
The agreement notes that Bankers Trust has already "undertaken a
comprehensive review of its LDT business to ensure that the LDT business
will be appropriately managed and controlled going forward." As a result
of that review, many of the procedures outlined in the agreement have been
set in place and others are in the process of being implemented. "Our
review made clear that certain changes were needed, and we have made them,"
Mr. Sanford said. "Where warranted, we have taken disciplinary actions
against individuals who violated the firm's Code of Conduct, and we have
enhanced controls to prevent future violations.
"The standards and procedures described in this agreement will bring
to the leveraged derivative transaction business a level of transparency
and supervision that will benefit our clients," said Mr. Sanford.
-more-
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In accordance with the agreement, Bankers Trust New York Corporation
and its subsidiaries Bankers Trust Company and BT Securities Corporation
(collectively BT) will:
1. Seek to reasonably ensure that each LDT customer has the capability
to understand the nature and material terms, conditions and risks of
any LDT entered into with Bankers Trust.
2. Make disclosures that will provide LDT customers with sufficient
information to understand the nature and material terms, conditions
and risks of the transaction.
3. Ensure reasonable transparency of pricing and valuation for LDTs.
4. Enhance the management and supervision process for the LDT business.
5. Establish a committee of the Board of Directors to monitor compliance
with the agreement.
6. Augment the training program for the marketing and sales of LDTs.
7. Develop additional policies and procedures for the administration of
LDT credit facilities.
8. Strengthen the internal audit of LDTs.
The agreement also provides that, with the assistance of outside
counsel, BT will review how revenue and expense in the LDT business are
allocated among Bankers Trust Company and its affiliates, as well as
compliance in the LDT business with "firewalls" related to corporate
separateness and management interlocks, and that outside legal counsel will
review any conduct by BT employees related to the LDT business which does
not comport with BT's Code of Conduct or applicable law; and whether any
disciplinary action is appropriate with respect to employees engaged in the
LDT business. Outside counsel has assisted in Bankers Trust's internal
review.
"This agreement will in no way restrict our ability to grow our risk
management business or restrain our leadership in product innovation," Mr.
Sanford said. "Instead, these improvements in our procedures and controls
will facilitate our work with clients and pave the way for the continued
expansion of this business."
Bankers Trust continues to cooperate with Federal regulators in their
review of the leveraged derivative transactions business.
For additional information, contact Douglas Kidd, Bankers Trust, (212) 454-
3532.
