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Several foreign exchange executives at major firms, speaking on the condition that they not be named, said they did not engage in these rollovers.
This time it involves a charge of wire fraud conspiracy against two of its foreign exchange executives, who are accused of "front-running" a trade by the bank's client to generate a $3 million profit.
The guidelines, which were written by a committee of top foreign exchange executives and representatives of the Federal Reserve Bank of New York and updated in September, are not binding.
Some foreign exchange executives said they would treat the premium like a loan because it would be a year before they could exercise the option to recoup the premium and more.
These deals were technically options trades, but they were effectively loans to Mr. Rusnak and his bank, Allfirst Financial, from Citibank, Bank of America,, Deutsche Bank and Bank of New York, say foreign exchange executives, including someone from a bank that made one of the deals.
"The Guidelines for Foreign Exchange Trading Activities," written by foreign exchange executives and representatives of the Federal Reserve Bank of New York for this unregulated market, state: "Significant book profits or losses, unusual requests, and transactions or patterns of activity inconsistent with a customer's profile should be referred to management".
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A foreign exchange executive in New York was somewhat more direct.
"The pressures on people to produce revenues is extraordinary," a foreign exchange executive said.
A top foreign exchange executive said: "In a competitive marketplace, people don't think through these things.
"It has caught people off guard and people are just staying away," said one top foreign exchange executive about speculating on the yen.
But just days before the big game, Mr. Rusnak knew he would not be going and told a foreign exchange executive at another bank to close out his trades.
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