SRO rules impact on Bank Trust Departments (from ABA Trust Letter)

[fidu]

New SRO rule - obligation of investment analyst to disclose 1% ownership positions implemented and effective on 11/10/2002. Article says that "in order to support compliance with the new disclosure requirement, trust departments of banks that are ffiliated with investment banking firms will be required to track beneficial ownership interests and report them to affiliated firms" so that the affiliate/Investment bank can disclose.

arent the beneficial ownership interests of the stocks in an EB trust held in trust departments FBO the trust. Is the bank the beneficial owner. i think the plan is the beneficial owner, and therefore think this rule is ignoreable.

thoughts?

thanks.