SEC Customer Protection Rule 15c3-3
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- Course Code: 302
- Certificate: Yes
- CPE Credits: 7
- Level: Beginner-intermediate
- Prerequisites: None
- Method: Live & Virtual
- Venue: MicroTek
- Time: 9:00 am – 5:00 pm
- Registration: 8:30 am
- Dress Code: Business Casual
- Category: Tax and Accounting
- Course Duration: 1 Day
- Available Course date: 06/25/2019
- Available Course date: 09/27/2019
Updated to include upcoming Rule changes. Learn what the direct effects upon SEC Rule 15c3-3 will be once the SEC proposed Rule 18a-4 for Securities Based Swap Dealers and changes to the FINRA Margin Rule 4210 for TBAs become effective.
This intensive course will review the details of the SEC Customer Protection Rule 15c3-3. It will explain in detail how contents of a customer’s and PAB account, portfolio positions and money balances, are required to be protected by the securities industry. It will also detail how various calculations are preformed on a daily, weekly and monthly basis to ensure this protection. It will define specifics of what protection means and how it is achieved in the broker/dealer community.
The seminar includes numerous exercises to ensure the student has a thorough, real-world understanding of the material covered. The course does not require more than basic math skills.
- Overview of Rules of Financial Responsibilities of Brokers and Dealers
- Origins of the Customer Protection Rule.
- Definition of customer, non-customer and PAB as it pertains to rule 15c3-3
- What does the rule mean by “possession or control?”
- What components of a customer’s account need to be afforded protection and what components do not.
- How do we accomplish protection of customer and PAB securities and funds?
- What if protection of customer and PAB assets is not achieved?
- Examples of how to calculate protection requirements
- portfolio securities
- money balances.
- Review of Reserve Fund Calculation –Customer and PAB
- Review of PAB Calculation
- Customer / Non-Customer / PAB
- Qualified Security
- Fully-Paid Security
- Margin Security
- Excess Margin Security
- Free Credit Balance
PHYSICAL POSSESSION OR CONTROL
- What is Possession or Control?
- What needs to be in a Broker/Dealers Possession or Control?
- When does Possession or Control need to be obtained?
- How do broker/dealers accomplish possession or control?
- Exceptions to Possession or Control
CONTROL OF SECURITIES
- Clearing Corporation
- Custody of a bank under specific circumstances
- Special Omnibus Account
- Items in transfer
- Foreign Depository
- Other Bank Depositories
- Items in transit
- Other approved locations
REQUIREMENTS OF P&C
- Determination made each business day
- Monthly for inactive margin accounts
- Time frames for
- Stock Loan
- Fail to Receive
- Bona Short Position
- Written Procedures
- Accomplishing possession or control
- Notification to PAB account holders
SPECIAL RESERVE BANK ACCOUNT
- Computation date
- Deposit and Withdrawal Time Frames
- Allowable deposits
- Deposit Limitations
- Notification of Banks
- Purpose of Computation
- Includable – Excludable items
- Stock record allocation
- Components of formula
- Hindsight Deficiencies
- PAB Computation
Mark E. Axelrod MBA, CPA is currently Vice President of Regulatory Reporting for Deutsche Bank Securities, Inc. After obtaining his undergraduate degree from Syracuse University in 1973 and his Masters of Business Administration from Pace University in 1978 Mark joined the Public Account Firm of Oppenheim, Appel, Dixon & Co., which at the time was …
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