SEC Staff Issues Guidance for Broker Dealers on Daily Reserve Computation Requirements

The SEC Division of Trading and Markets issued updated guidance on daily customer and broker-dealer reserve computation requirements under SEA Rule 15c3-3 ("Customer protection-reserves and custody of securities").

In updated FAQs, the Division clarified that "carrying broker-dealers" with average total credits of $500 million or more must begin performing daily customer and PAB reserve computations no later than June 30, 2026. The Division stated that the compliance date is triggered when a broker-dealer meets the $500 million threshold using the 12 month-end FOCUS Reports filed from January 31, 2025, through December 31, 2025.

The Division permits broker-dealers to perform test reserve computations before beginning required or voluntary daily computations, provided these tests do not result in withdrawals from reserve accounts. The SEC recommended documenting the purpose of test computations to differentiate them from required computations during examinations.

Broker-dealers that elect the alternative net capital method under Rule 15c3-1(a)(1)(ii) and voluntarily perform daily customer reserve computations may apply a "2% aggregate debit items charge (rather than 3%)" if they notify their designated examining authority in writing at least 30 days before beginning daily computations. Broker-dealers required to perform daily computations may apply the 2% charge without prior notification.

The Division permitted broker-dealers to skip reserve computations on Federal Holidays, Good Friday, and specified business days adjacent to holidays, including the Friday before Memorial Day and the Friday after Thanksgiving.