Rule 3b-14

Definition of Cash Management Securities Activities

The term cash management securities activities means securities activities that are limited to transactions involving:

a. Any taking possession of, and any subsequent sale or disposition of, collateral provided by a counterparty, or any acquisition of, and any subsequent sale or disposition of, collateral to be provided to a counterparty, in connection with any securities activities of the dealer permitted under Rule 15a-1 or any non-securities activities of the dealer that involve eligible OTC derivative instruments or other financial instruments;

b. Cash management, in connection with any securities activities of the dealer permitted under Rule 15a-1 or any non-securities activities of the dealer that involve eligible OTC derivative instruments or other financial instruments; or

c. Financing of positions of the dealer acquired in connection with any securities activities of the dealer permitted under Rule 15a-1 or any non- securities activities that involve eligible OTC derivative instruments or other financial instruments.