United States

Updated FAQs: Broker-dealer financial reporting rule


The staff of the SEC Division of Trading and Markets recently updated the frequently asked questions (FAQs) concerning the July 30, 2013 amendments to the broker-dealer financial reporting rule originally issued in Final Rule 34-70073, Broker-Dealer Reports. Questions added November 29, 2018 address the following matters, among others:

  • The scope of Internal Control Over Compliance as it relates to compliance with the Account Statement Rule of a broker-dealer’s designated examining authority
  • Claiming exemptions from Rule 15c3-3 in an exemption report
  • The appropriate treatment under the Rule 15c3-3 Customer Reserve Formula for research and brokerage services with commission dollars generated by account transactions liabilities under section 28(e) of the Exchange Act where the broker-dealer does not remit cash to the counterparty but pays invoices meeting the safe harbor
  • Verification of all securities subject to paragraph (b)(3) of Exchange Act Rule 17a-13