General Interrogatory Question #29

[VeronikaK-BCSIC]

We hold OIA securities and mutual funds securities - 5 in total, outside of our main custodian. Do those institutions (i.e. Vanguard) need to be listed within GI question #29? In discussing this concept internally with the team, those institutions are not considered a custody bank and we have historically not listed them. We answer the question "yes" and just include our main custody bank within the question. We appreciate your feedback.

[Lisa]

Hello,
I believe you will want to review the type of agreement you have with the other institutions. Per the Annual Statement instructions, the purpose of the general interrogatory is to disclose ?whether items are held in accordance with the Financial Conditions Examiners Handbook?. I don?t believe because your organization does not consider the other organizations a ?custodial bank? automatically excludes it from disclosure in GI #29.

Please refer to the Financial Conditions Examiners Handbook. The particular section of the handbook can be found at http://www.naic.org/documents/commit...Agreements.doc.

Regards,
Lisa Mullen