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advice advisor agency agent Agreement application approved authority bank holding company bank's Banking Act bonds brokered deposits Capital T Account certificates of deposit charges Citibank collective investment collective investment fund commercial banks commercial paper Commission common trust funds Comptroller Comptroller's Congress corporate customers deposit broker distribution employees engaged ERISA exemption FDIC Federal Reserve System fiduciary final regulation financial planners financial planning Glass-Steagall Act insured nonmember bank investment adviser investment company Investment Company Institute investment fund investors IRA trust issue issuer joint venture limited McFadden Act ment Merrill Lynch money market Mortgage mutual fund national bank obligations offered operation paragraph participation payment permitted plaintiff Portfolio principal prohibited proposed purchase pursuant registered restrictions rule Schwab securities activities securities laws selling shares statute subsidiary or affiliate tion transactions trust assets trust department underwriting violation