The SEC Division of Trading and Markets recently released Frequently Asked Questions (FAQs) related to the 15c3-3 daily reserve computations for customer accounts and the proprietary accounts of broker-dealers (PAB).
Key Points
- Compliance Date: Carrying broker-dealers with average total credits of $500 million or more (based on 12 month-end FOCUS Reports from January 31 to December 31, 2025) must begin daily customer and PAB reserve computations by June 30, 2026.
- Test Computations: Broker-dealers may conduct test computations to validate new processes before beginning to perform required or voluntary daily computations. These tests should not result in reserve account withdrawals, but should be documented for compliance purposes.
- 2% Aggregate Debit Items Charge:
- Voluntary Daily Computations: Broker-dealers using the alternative net capital method under Rule 15c3-1(a)(1)(ii) may apply a 2% reduction to the aggregate debit items charge (instead of 3%) on or after March 14, 2025, if broker-dealers voluntarily perform daily computations, with written notice given to their Designated Examining Authority (DEA) at least 30 days in advance.
- Required Daily Computations: If carrying broker-dealers elect the alternative method for net capital and are required to perform a daily customer reserve computation, the 2% charge on aggregate debit items can be applied directly without notification to their DEA.
- Sweep Program: Broker-dealers may reduce required deposits to customer reserve accounts by credits transferred to a Sweep Program under Rule 15c3-3(j)(2)(ii) on the next business day after the computation. However, these sweep credits cannot be used for making a determination if broker-dealers make a withdrawal from the reserve bank account.
- Non-Computation Days: Staff will not object to skipping required daily computations on federal holidays and certain articulated adjacent business days that pose operational challenges.
How Forvis Mazars Can Help
In the heavily regulated financial services industry, leaders face more challenges than ever, from striving to meet shareholder and regulatory expectations to pursuing digital innovation. Forvis Mazars’ advisors can assist you with the analysis, design, and implementation of strategic changes to your reserve computation process under SEC Rule 15c3-3. We possess the regulatory domain knowledge and industry experience that you can trust, combining a focus on Unmatched Client Experience® with the resources of a global firm.
We work closely with financial institution clients to provide a range of services from guidance on applying the debit items charge and documenting test computations, to advice on integrating daily customer and PAB reserve requirements into your operating model. Our professionals are driven by shared passions to serve companies on financial services industry-leading projects, and we look forward to helping your organization achieve its goals.
If you have any questions or need assistance, please reach out to a professional at Forvis Mazars.