On January 13, the SEC published to the Federal Register a final amendments to Rule 15c3-3 – the Broker-Dealer Customer Protection Rule – to require daily reserve calculations for certain large broker-dealers. The Broker-Dealer Customer Protection Rule mandates that broker-dealers segregate customer cash and securities, maintaining a reserve of cash or qualified securities equal to the net cash owed to customers in a “Special Reserve Bank Account for the Exclusive Benefit of Customers.” It also requires a separate reserve computation for proprietary accounts of broker-dealers (PAB accounts).

The amendments apply to broker-dealers with average total credits of $500 million or more, requiring them to compute customer and PAB reserve amounts daily. Broker-dealers exceeding this threshold from July 31, 2024, to June 30, 2025, must comply by December 31, 2025. Voluntary daily computation requires 30 days’ notice to the broker-dealer’s designated examining authority (e.g. FINRA). If broker-dealers fall below the $500 million threshold, they can revert to weekly computations after 60 days’ notice.