A – Z Escrow ProcessA – Z Escrow Process

Presented by:Presented by:

• Tracey Paine, State Treasurer’s OfficeTracey Paine, State Treasurer’s Office• Cheryl Ormond, State Treasurer’s OfficeCheryl Ormond, State Treasurer’s Office• Avelina Saavedra, CSU San BernardinoAvelina Saavedra, CSU San Bernardino• Barbara Nicholson, Office of the ChancellorBarbara Nicholson, Office of the Chancellor• Haaziq Muhammad, Office of the ChancellorHaaziq Muhammad, Office of the Chancellor

Escrow FunctionEscrow Function

To ensure performance under a contract, the Trustees To ensure performance under a contract, the Trustees shall retain no less than 5 % of the contract amount shall retain no less than 5 % of the contract amount until final completion and acceptance of the project by until final completion and acceptance of the project by the Trustees. the Trustees.

Trustees’ Retention OptionsTrustees’ Retention Options

1. Trustees retain a minimum of 5% of all processed partial payment 1. Trustees retain a minimum of 5% of all processed partial payment requests in a contract account. Upon completion of the project, the requests in a contract account. Upon completion of the project, the amount in retention shall be paid to the Contractor within 30 calendar amount in retention shall be paid to the Contractor within 30 calendar days after the recordation date on the Notice of Completion by the days after the recordation date on the Notice of Completion by the county recorder (if no stop notices or claims against the Contractor or county recorder (if no stop notices or claims against the Contractor or project). project).

2. Trustees may allow Contractor to establish an escrow account with the 2. Trustees may allow Contractor to establish an escrow account with the State Treasurer’s Office (STO), at the request and expense of the State Treasurer’s Office (STO), at the request and expense of the Contractor. Securities totaling 5% of the contract amount shall be Contractor. Securities totaling 5% of the contract amount shall be deposited in installments or in one lump sum.deposited in installments or in one lump sum.

3. Trustees use a combination of both an escrow with the STO and 3. Trustees use a combination of both an escrow with the STO and retention with the Trustees. Both accounts shall equal not less than 5% retention with the Trustees. Both accounts shall equal not less than 5% of the entire contract.of the entire contract.

See California Public Contract Code Sections 10851 – 10852.See California Public Contract Code Sections 10851 – 10852.

(Option 1) (Option 1) Trustees RetentionTrustees Retention

This is a $12,000,000 project scheduled to be completed This is a $12,000,000 project scheduled to be completed within 730 calendar days.within 730 calendar days.

• The Contractor shall be paid partial payments monthly.The Contractor shall be paid partial payments monthly.• Partial payment requests shall be processed with a minimum of 5% Partial payment requests shall be processed with a minimum of 5%

retention.retention.• If the partial payment is $500,000, the Contractor receives $475,000, If the partial payment is $500,000, the Contractor receives $475,000,

and the Trustees retain $25,000 in contract account.and the Trustees retain $25,000 in contract account.• Upon completion, the Trustees should have a minimum of $600,000 Upon completion, the Trustees should have a minimum of $600,000

retention for this project. If there were change orders that increased the retention for this project. If there were change orders that increased the amount of the contract, the retention amount for this project will also amount of the contract, the retention amount for this project will also increase. If the contract was increased by $550,000 in change orders, increase. If the contract was increased by $550,000 in change orders, the retention amount will increase to $675,000 (5% of the entire the retention amount will increase to $675,000 (5% of the entire contract).contract).

• If an escrow account was NOT established for this project, the If an escrow account was NOT established for this project, the Contractor is entitled to only ONE retention payment.Contractor is entitled to only ONE retention payment.

(Option 2)(Option 2)Escrow with STOEscrow with STO

• The Trustees submit a signature authorization letter and The Trustees submit a signature authorization letter and contact information to the STO.contact information to the STO.

• A three-party escrow agreement is drawn up between the A three-party escrow agreement is drawn up between the Trustees of the California State University as the Trustee, Trustees of the California State University as the Trustee, the Contractor, and the State Treasurer’s Office as the the Contractor, and the State Treasurer’s Office as the Escrow Agent. Escrow Agent. – All parties must hold a fully executed agreement (this includes the All parties must hold a fully executed agreement (this includes the

Escrow Agreement, Surety, Power of Attorney, and an All Purpose Escrow Agreement, Surety, Power of Attorney, and an All Purpose Acknowledgment), all with original signatures.Acknowledgment), all with original signatures.

• Except for the signature block, the agreement forms Except for the signature block, the agreement forms cannot be altered.cannot be altered.

Acceptable SecuritiesAcceptable Securities

Per Government Code Section 16430Per Government Code Section 16430, eligible , eligible securities... shall be any of the following: securities... shall be any of the following: •(a) U.S. bonds or interest-bearing notes or obligations, or those for which the faith (a) U.S. bonds or interest-bearing notes or obligations, or those for which the faith and credit of the United States are pledged for the payment of principal and interest. and credit of the United States are pledged for the payment of principal and interest. •(b) Bonds or interest-bearing notes on obligations that are guaranteed as to (b) Bonds or interest-bearing notes on obligations that are guaranteed as to principal and interest by a federal agency of the United States. principal and interest by a federal agency of the United States. •(c) Bonds and notes of this state, or those for which the faith and credit of this state (c) Bonds and notes of this state, or those for which the faith and credit of this state are pledged for the payment of principal and interest. are pledged for the payment of principal and interest. •(d) Bonds or warrants, including, but not limited to, revenue warrants, of any (d) Bonds or warrants, including, but not limited to, revenue warrants, of any county, city, metropolitan water district, California water district, California water county, city, metropolitan water district, California water district, California water storage district, irrigation district in the state, municipal utility district, or school storage district, irrigation district in the state, municipal utility district, or school district of this state. district of this state. •(e) Bonds, consolidated bonds, collateral trust debentures, consolidated (e) Bonds, consolidated bonds, collateral trust debentures, consolidated debentures, or other obligations issued by federal land banks or federal intermediate debentures, or other obligations issued by federal land banks or federal intermediate credit bankscredit banks•(f) Commercial paper of "prime" quality as defined by a nationally recognized (f) Commercial paper of "prime" quality as defined by a nationally recognized organization that rates these securities. Eligible paper is further limited to issuing organization that rates these securities. Eligible paper is further limited to issuing corporations or trusts approved by the Pooled Money Investment Board that meets corporations or trusts approved by the Pooled Money Investment Board that meets specific conditions. specific conditions.

Establishing an Escrow with Establishing an Escrow with the STO (continued)the STO (continued)

• If book entry securities are going to be pledged, the If book entry securities are going to be pledged, the Contractor shall pay an annual custodian bank fee of Contractor shall pay an annual custodian bank fee of $145.00 to establish and maintain an account with the $145.00 to establish and maintain an account with the STO’s custodian bank, Citibank. STO’s custodian bank, Citibank.

• The Contractor shall submit a New Account Request form The Contractor shall submit a New Account Request form and a check for $145.00 payable to the State Treasurer’s and a check for $145.00 payable to the State Treasurer’s Office. Office.

• For accounts that remain open beyond the current For accounts that remain open beyond the current calendar year, an annual renewal fee is due by December calendar year, an annual renewal fee is due by December 3131stst of each year, and will not be prorated for a partial year. of each year, and will not be prorated for a partial year.

Book Entry SecuritiesBook Entry Securities

• Book entry securities are purchased and sold in an Book entry securities are purchased and sold in an automated system and can be obtained from a automated system and can be obtained from a licensed broker or bank.licensed broker or bank.

• Eligible book entry securities are listed in California Eligible book entry securities are listed in California Government Code Section 16430.Government Code Section 16430.

Book Entry Securities --Book Entry Securities --Depositing Depositing

• The STO requires instruction from The STO requires instruction from bothboth the Contractor the Contractor and the Trustees to deposit, exchange, or release any and the Trustees to deposit, exchange, or release any securities.securities.

• The Contractor purchases the securities to be The Contractor purchases the securities to be deposited, and submits a completed, signed Securities deposited, and submits a completed, signed Securities Transaction Request form to the Trustees’ Escrow Transaction Request form to the Trustees’ Escrow Representative. Representative.

• The Trustees’ Escrow Representative reviews and The Trustees’ Escrow Representative reviews and approves the request and transmits it with a Securities approves the request and transmits it with a Securities Transaction Authorization letter to the STO.Transaction Authorization letter to the STO.

Book Entry Securities --Book Entry Securities --Depositing (continued)Depositing (continued)

• The STO completes a Depository Deposit (“D”) form The STO completes a Depository Deposit (“D”) form to deposit the book entry security and transmits it to to deposit the book entry security and transmits it to the STO’s custodian bank, Citibank. the STO’s custodian bank, Citibank.

• The STO faxes a memo to both the delivering broker The STO faxes a memo to both the delivering broker or bank and the Contractor, notifying them of the or bank and the Contractor, notifying them of the delivery date and instructions.delivery date and instructions.

• Note: Citibank cannot process any transaction without Note: Citibank cannot process any transaction without written authorization from the STO.written authorization from the STO.

Book Entry Securities --Book Entry Securities --Depositing (continued)Depositing (continued)

• On the delivery date, the Contractor’s broker or bank On the delivery date, the Contractor’s broker or bank electronically transmits the book entry securities to electronically transmits the book entry securities to Citibank.Citibank.

• After receipt of delivery confirmation from Citibank, After receipt of delivery confirmation from Citibank, the STO sends a confirmed copy of the “D” form to the STO sends a confirmed copy of the “D” form to the Trustees’ Escrow Representative and the the Trustees’ Escrow Representative and the Contractor. Contractor.

Book Entry Securities --Book Entry Securities --ReleasingReleasing

• When a security matures or has been called for When a security matures or has been called for redemption, the principal balance is credited to the redemption, the principal balance is credited to the account as cash.account as cash.

• The Trustees must first determine whether to require the The Trustees must first determine whether to require the Contractor to put up a replacement security or to release Contractor to put up a replacement security or to release the cash to the Contractor. the cash to the Contractor.

• If the Trustees require a replacement security, the If the Trustees require a replacement security, the

Contractor must deposit the security before the cash can Contractor must deposit the security before the cash can be released.be released.

Book Entry Securities --Book Entry Securities --Releasing (continued)Releasing (continued)

• To release a book entry security, the Contractor shall To release a book entry security, the Contractor shall submit a completed, signed Securities Transaction Request submit a completed, signed Securities Transaction Request form to the Trustees’ Escrow Representative for approval. form to the Trustees’ Escrow Representative for approval.

• The Trustees’ Escrow Representative submits the request The Trustees’ Escrow Representative submits the request to the Construction Administrator for review and approval. If to the Construction Administrator for review and approval. If approved, the Trustees’ Escrow Representative shall approved, the Trustees’ Escrow Representative shall transmit along with a Securities transmit along with a Securities Transaction Transaction Authorization Authorization letter to the STO. letter to the STO.

• This request should be received by the STO This request should be received by the STO on or beforeon or before the day the security matures or has been called for the day the security matures or has been called for redemption.redemption.

Book Entry Securities --Book Entry Securities --Releasing (continued)Releasing (continued)

• The STO completes a Depository Maturity (“DM”) or a The STO completes a Depository Maturity (“DM”) or a Depository Release (“DR”) form to release the book Depository Release (“DR”) form to release the book

entry security and sends it to Citibank.entry security and sends it to Citibank.

– A “DM” is a document used to release a security A “DM” is a document used to release a security on or afteron or after the date it matures or is called for early redemption. the date it matures or is called for early redemption.

– A “DR” document is used to release a security A “DR” document is used to release a security beforebefore the the date it matures or is called for early redemption. date it matures or is called for early redemption.

Book Entry Securities --Book Entry Securities --Releasing (continued)Releasing (continued)

• Released book entry securities are electronically Released book entry securities are electronically transmitted from Citibank to the Contractor’s broker or transmitted from Citibank to the Contractor’s broker or bank. bank.

• Once the STO receives release confirmation from Once the STO receives release confirmation from Citibank, the STO sends a confirmed copy of the “DM” Citibank, the STO sends a confirmed copy of the “DM”

or “DR” form to both the Trustees and the Contractor.or “DR” form to both the Trustees and the Contractor.

Physical SecuritiesPhysical Securities

• Physical securities are purchased from a bank or Physical securities are purchased from a bank or lending institutionlending institution

• Eligible physical securities:Eligible physical securities:

– bank or savings and loan certificates of deposits bank or savings and loan certificates of deposits (CD’s) and (CD’s) and

– standby letters of credit standby letters of credit • not recommended by Trustees and STOnot recommended by Trustees and STO

CD’sCD’s

• CD’s must be registered as follows:CD’s must be registered as follows:– State Treasurer’s Office, State of California, Escrow # _____, State Treasurer’s Office, State of California, Escrow # _____,

for California State University, ______.for California State University, ______.

• CD’s should be auto-renewable.CD’s should be auto-renewable.

• Principal amount Principal amount changes cannot be made to current changes cannot be made to current CD’s without notification to, and written authorization CD’s without notification to, and written authorization from both the STO and the Trustees. from both the STO and the Trustees.

• No written authorization is needed for auto-renewable No written authorization is needed for auto-renewable CD’s, unless there is a principal amount changeCD’s, unless there is a principal amount change..

CD’s (continued)CD’s (continued)

• CD’s must possessCD’s must possess – Date, Authorized signature, Bank contact name & phone Date, Authorized signature, Bank contact name & phone

number.number.

• If the CD does not meet these requirements, a bank If the CD does not meet these requirements, a bank letter (on official bank letterhead) providing this and letter (on official bank letterhead) providing this and the terms of the CD must accompany the CD.the terms of the CD must accompany the CD.

• If any of these requirements are not met, the STO will If any of these requirements are not met, the STO will not accept the CD and will return it to the Contractor.not accept the CD and will return it to the Contractor.

• The bank shall send monthly statements to the STO. The bank shall send monthly statements to the STO.

Physical Securities -- Physical Securities -- DepositingDepositing

• Once the Contractor has purchased the securities to Once the Contractor has purchased the securities to be deposited, a completed, signed Securities be deposited, a completed, signed Securities Transaction Request form is submitted to the Transaction Request form is submitted to the Trustees’ Escrow Representative.Trustees’ Escrow Representative.

• The Trustees’ Escrow Representative reviews and The Trustees’ Escrow Representative reviews and approves the request and transmits it with a Securities approves the request and transmits it with a Securities Transaction Authorization letter to the STO. Transaction Authorization letter to the STO.

Physical Securities – Physical Securities – Depositing (continued)Depositing (continued)

• The Contractor, or his bank or lending institution, The Contractor, or his bank or lending institution, transmits the physical securities to the STO by transmits the physical securities to the STO by overnight delivery service, messenger service, or overnight delivery service, messenger service, or certified mail.certified mail.

• The STO completes a Vault Deposit (“V”) form to The STO completes a Vault Deposit (“V”) form to deposit the physical security into the STO vault. deposit the physical security into the STO vault.

• Once confirmation is received from the vault, the STO Once confirmation is received from the vault, the STO sends a copy of the confirmed “V” form to both the sends a copy of the confirmed “V” form to both the Trustees’ Escrow Representative and the Contractor. Trustees’ Escrow Representative and the Contractor.

Physical Securities -- Physical Securities -- ReleasingReleasing

• To release a physical security, the Contractor shall To release a physical security, the Contractor shall submit a completed, signed Securities Transaction submit a completed, signed Securities Transaction Request form to the Trustees’ Escrow Representative. Request form to the Trustees’ Escrow Representative.

• The Trustees’ Escrow Representative submits the The Trustees’ Escrow Representative submits the Securities Transaction Request form to the Securities Transaction Request form to the Construction Administrator for approval and signature; Construction Administrator for approval and signature; once the form is signed and approved, the Trustees’ once the form is signed and approved, the Trustees’ Escrow Representative transmits it to the STO along Escrow Representative transmits it to the STO along with a Securities with a Securities TransactionTransaction Authorization letter. Authorization letter.

Physical Securities – Physical Securities – Releasing (continued)Releasing (continued)

• The STO completes a Vault Release (“VR”) document The STO completes a Vault Release (“VR”) document to release the physical security from the STO vault. to release the physical security from the STO vault.

• The security and a copy of the confirmed “VR” form The security and a copy of the confirmed “VR” form are sent via certified mail to the Contractor.are sent via certified mail to the Contractor.

• An additional copy of the confirmed “VR” is sent to the An additional copy of the confirmed “VR” is sent to the Trustees’ Escrow Representative.Trustees’ Escrow Representative.

Monthly ReportsMonthly Reports

• Market Valuation ReportMarket Valuation Report - completed on a monthly - completed on a monthly basis for all escrow accounts. A copy is sent to the basis for all escrow accounts. A copy is sent to the

Trustees by the tenth (10Trustees by the tenth (10thth) day of each month.) day of each month.

– If the market value drops below the retention amount paid to If the market value drops below the retention amount paid to the Contractor, STO notifies the Trustees, and the Trustees the Contractor, STO notifies the Trustees, and the Trustees shall notify the Contractor. shall notify the Contractor.

– The Contractor must deposit additional securities before any The Contractor must deposit additional securities before any

future retention may be paid.future retention may be paid.

Monthly Reports (continued)Monthly Reports (continued)

• Year-To-Date ReportYear-To-Date Report – generated by the STO and – generated by the STO and distributed to the Trustees’ Escrow Representative, distributed to the Trustees’ Escrow Representative, who distributes copies to the Construction who distributes copies to the Construction Administrator and the Contractor.Administrator and the Contractor.

• Investment SummaryInvestment Summary and and Statement of TransactionsStatement of Transactions – generated by Citibank for accounts pledging book – generated by Citibank for accounts pledging book entry securities and distributed to the Contractor and entry securities and distributed to the Contractor and

Trustees’ Escrow Representative.Trustees’ Escrow Representative.

Contract Retention PaymentsContract Retention Payments

• The Contractor is entitled to multiple retention The Contractor is entitled to multiple retention payments. payments.

• The total retention amount available is 5% of the total The total retention amount available is 5% of the total earned on the referenced payment request. earned on the referenced payment request.

• Payments will not be released until adequate Payments will not be released until adequate securities are on deposit, and in accordance with the securities are on deposit, and in accordance with the escrow agreement.escrow agreement.

Contract Retention Payments Contract Retention Payments (continued)(continued)

• The Contractor completes the Request for Payment of The Contractor completes the Request for Payment of Retention and submits it to the Construction Administrator Retention and submits it to the Construction Administrator for review & approval.for review & approval.

• The Construction Administrator shall verify that sufficient The Construction Administrator shall verify that sufficient securities are on deposit and the market value of the securities are on deposit and the market value of the securities is adequate.securities is adequate.

• Upon approval, the Construction Administrator shall sign Upon approval, the Construction Administrator shall sign and transmit the retention payment request to the STO for and transmit the retention payment request to the STO for review and approval.review and approval.

• Based on the amount of deposit and available retention, Based on the amount of deposit and available retention, the STO approves or rejects the request.the STO approves or rejects the request.

Contract Retention Payments Contract Retention Payments (continued)(continued)

• If approved, the STO signs and forwards the retention If approved, the STO signs and forwards the retention request to the Construction Administratorrequest to the Construction Administrator

• If there are insufficient securities on deposit, the STO If there are insufficient securities on deposit, the STO will reject the request and notify the Construction will reject the request and notify the Construction Administrator who is responsible for notifying the Administrator who is responsible for notifying the Contractor to deposit additional securities. Contractor to deposit additional securities.

• If the Contractor needs assistance in completing the If the Contractor needs assistance in completing the Request for Payment, they should contact the Request for Payment, they should contact the Construction Administrator.Construction Administrator.

Closing an Escrow AccountClosing an Escrow Account

• When the Notice of Completion has been filed, the Contractor will When the Notice of Completion has been filed, the Contractor will submit a request to the Construction Administrator to release the submit a request to the Construction Administrator to release the securities on deposit at the STO.securities on deposit at the STO.

• If no there are no claims, ongoing work or other outstanding issues, If no there are no claims, ongoing work or other outstanding issues, the Construction Administrator shall direct the Trustees’ Escrow the Construction Administrator shall direct the Trustees’ Escrow Representative to begin the release process.Representative to begin the release process.

• The Trustees’ Escrow Representative invoices the Contractor using The Trustees’ Escrow Representative invoices the Contractor using the Trustees’ Fee Schedule. The payment can be collected in the the Trustees’ Fee Schedule. The payment can be collected in the form of a check or in the form of a deduction from moneys due.form of a check or in the form of a deduction from moneys due.

• The Trustees’ Escrow Representative transmits a project completion The Trustees’ Escrow Representative transmits a project completion authorization letter to the STO stating the securities can be released authorization letter to the STO stating the securities can be released and the account closed.and the account closed.

Closing an Escrow Account Closing an Escrow Account (continued)(continued)

• The STO invoices the Contractor using the STO Fee The STO invoices the Contractor using the STO Fee Schedule.Schedule.

• Once the STO receives the fees in full, the securities Once the STO receives the fees in full, the securities are released to the Contractor and the account is are released to the Contractor and the account is closed. closed.

• The STO will send copies of the confirmed release The STO will send copies of the confirmed release form(s) (DR, DM, &/or VR) to the Trustees’ Escrow form(s) (DR, DM, &/or VR) to the Trustees’ Escrow Representative and the Contractor.Representative and the Contractor.

(Option 3)(Option 3)Combination of Trustees Withheld Combination of Trustees Withheld Retention and STO Escrow AccountRetention and STO Escrow Account

• Trustees may combine the two retention options. This Trustees may combine the two retention options. This usually occurs at the end of the project.usually occurs at the end of the project.

• Trustees establish cut-off point when Contractor is not Trustees establish cut-off point when Contractor is not allowed to deposit additional securities into the allowed to deposit additional securities into the escrow account with STO. Instead Trustees will escrow account with STO. Instead Trustees will process payment request and hold the retention process payment request and hold the retention amount in the contract account. amount in the contract account.

• In this scenario the total of both accounts shall equal In this scenario the total of both accounts shall equal no less than 5% of the entire contract.no less than 5% of the entire contract.

Trustees’ Escrow Fee Schedule for Trustees’ Escrow Fee Schedule for Administering Escrow AgreementAdministering Escrow Agreement

• The Cost to Establish an Escrow Account is $150.The Cost to Establish an Escrow Account is $150.• Includes the Trustees’ costs for developing the escrow agreement, Includes the Trustees’ costs for developing the escrow agreement,

opening the escrow account, and receiving initial securities pledged. opening the escrow account, and receiving initial securities pledged. The Contractors shall submit this fee when they return the signed The Contractors shall submit this fee when they return the signed escrow agreement counterparts. The fee is the same regardless to escrow agreement counterparts. The fee is the same regardless to number of securitiesnumber of securities..

• The Cost to Terminate an Escrow Account is $50.The Cost to Terminate an Escrow Account is $50.• Includes costs related to release of securities pledged and closing of Includes costs related to release of securities pledged and closing of

escrow account. The fee is the same regardless to number of securities.escrow account. The fee is the same regardless to number of securities.

• The Cost to Process Payments of Retention is $50.00.The Cost to Process Payments of Retention is $50.00.• Includes the costs for processing each release of retentionIncludes the costs for processing each release of retention..

• The Cost to Process a Deposit, Exchange or Withdraw The Cost to Process a Deposit, Exchange or Withdraw Securities is $50.00.Securities is $50.00.

• Includes costs relating to the deposit of additional securities, exchanges Includes costs relating to the deposit of additional securities, exchanges or the withdrawal of securities (cost is $50 for each instrument). or the withdrawal of securities (cost is $50 for each instrument).

STO’s Escrow Fee Schedule for STO’s Escrow Fee Schedule for Administering Escrow AgreementAdministering Escrow Agreement

• The Cost to Establish an Escrow Account is $120.The Cost to Establish an Escrow Account is $120.• Includes STO’s costs for opening the escrow account, receiving initial Includes STO’s costs for opening the escrow account, receiving initial

securities pledged, and the evaluation of securities. The fee is the same securities pledged, and the evaluation of securities. The fee is the same regardless to number of securitiesregardless to number of securities..

• The Cost to Terminate an Escrow Account is $90.The Cost to Terminate an Escrow Account is $90.• Includes costs related to release of securities pledged and closing of Includes costs related to release of securities pledged and closing of

escrow account. The fee is the same regardless to number of securities.escrow account. The fee is the same regardless to number of securities.

• The Cost to Process Payments of Retention is $45.00.The Cost to Process Payments of Retention is $45.00.• Includes the costs for processing each release of retentionIncludes the costs for processing each release of retention..

• The Cost to Process a Deposit, Exchange or Withdraw The Cost to Process a Deposit, Exchange or Withdraw Securities is $90.00.Securities is $90.00.

• Includes costs relating to the deposit of additional securities, exchanges Includes costs relating to the deposit of additional securities, exchanges or the withdrawal of securities (cost is $90 for each instrument). or the withdrawal of securities (cost is $90 for each instrument).

QUESTIONS????QUESTIONS????