On June 25, 2025, the U.S. Securities and Exchange Commission (SEC) voted to extend the compliance deadline for recent amendments to Exchange Act Rule 15c3-3 (the “Customer Protection Rule”) to June 30, 2026.[1] The amendments, adopted on December 20, 2024,[2] increase the frequency of required reserve computations for carrying broker-dealers from weekly to daily. The original compliance deadline had been set for December 31, 2025.
Recent Amendments
The Customer Protection Rule “requires broker-dealers that maintain custody of customer securities and cash (‘Carrying Broker-Dealers’) to have a special reserve account at a bank that must hold cash and/or qualified securities in an amount determined by a computation of the net cash owed to the carrying broker-dealer’s customers.”[3] Carrying Broker-Dealers were previously required to make this computation and any necessary deposits to the special reserve account on a weekly basis. The recent amendments, however, require broker-dealers maintaining average total credits equal to or greater than $500 million to perform reserve computations and corresponding deposits daily.
The recent amendments also modify Rule 15c3-1 (the “Broker-Dealer Net Capital Rule”), in connection with the Customer Protection Rule, to permit Carrying Broker-Dealers that “perform daily customer reserve computation[s] to decrease the required 3 percent ‘buffer’ in the [special reserve account] by reducing the customer-related receivables, or ‘aggregate debit items,’ charge from 3 percent to 2 percent in the computation.”[4]
SEC Chairman Atkins’ Response
Regarding the extension, SEC Chairman Paul S. Atkins remarked, “by extending this compliance date, [the SEC is] giving broker-dealers additional time to implement daily computation under Rule 15c3-3,” and “to avoid operational challenges [associated] with meeting the initial compliance date.”
[1] See SEC Extends Compliance Date to Help Broker-Dealers Fully Test and Implement Daily Reserve Computation Requirement (June 25, 2025).
[2] See SEC Adopts Rule Amendments to the Broker-Dealer Customer Protection Rule (Dec. 20, 2024).
[3] See Enhancements to the Broker-Dealer Customer Protection Rule (Dec. 20, 2024).
[4] See SEC Adopts Rule Amendments to the Broker-Dealer Customer Protection Rule, footnote 2.
[View source.]
