I can answer.  Your IRA is almost certainly held at a Citi brokerage entity (as 
opposed to a banking entity) and brokerage bankruptcies are governed by the 
SIPA (Securities Investors Protection Act ) rules as opposed to the Bankruptcy 
Code.  Brokerage bankruptcies were quite common pre-New Deal, and occasionally 
still happen (Lehman, MF Global).  To summarize a very complicated situation, 
the assets will be presumptively liquidated very quickly and distributed as 
soon as possible (brokerages do not reorganized for all practical purposes).  
First, secured creditors get paid, but this will not affect you because by rule 
the brokerages cannot give customer property (assets held by the brokerage on 
behalf of the customers) as collateral (except under certain circumstances that 
will not have applied to you).  Next in priority will be customers like you.  
To avoid fights over whose bond belongs to who, SIPA treats all customers as 
creditors and not owners, and puts all customer claims (claims of customers for 
whom the brokerage acted as broker) into one big class, and the class then 
share all customer property pro rata.  If there is anything left over, then 
general unsecured creditors (e.g., lenders who lent money to the brokerage) 
will share pro rata.

As a practical matter, provided the brokerage followed the regulatory rules, it 
is almost impossible for the brokerage to be actually insolvent as to the 
customer claims.  Therefore, instead of going into the market and selling all 
of the securities as soon as possible (which could really negatively affect 
prices), it is much more common for the individual customer accounts to be 
transferred to a solvent brokerage within a matter of days (the Lehman 
brokerage accounts were moved to Barclays within one week of the Lehman 
bankruptcy), so you would not experience anything other than a letter informing 
you that your account was moved.  This is very similar to what happens when the 
FDIC takes over a bank and the deposit accounts get transferred.  MF Global is 
a scandal, because money was improperly transferred from the brokerage unit to 
proprietary trading affiliate when they were desperate for cash.

David Shemano

From: [email protected] 
[mailto:[email protected]] On Behalf Of [email protected]
Sent: Monday, June 04, 2012 11:06 AM
To: Progressive Economics
Subject: [Pen-l] IRA question

I have an IRA with Citi. Most of the money is in bonds: Ginny Mae, Treasury 
Bonds, Russian bank bonds, etc. Some is in money market which my broker says is 
insured.

If something happens to Citi, can I lose money? That is, is Citi just an 
intermediary? Are the bonds that I own still good in the event of a Citi 
failure?

Thanks,

Joanna
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