Resource Page for the SEC’s July 2013 Financial Responsibility Rule Amendments
In July, 2013, the SEC approved amendments to the financial responsibility and broker-dealer reporting rules. For the convenience of member firms, FINRA staff is compiling on this page key FINRA and SEC materials relating to the new amendments and their implementation.
SEC Rule Releases
- Financial Responsibility Rules for Broker-Dealers (Exchange Act Release No. 70072) (amending SEA Rules 15c3-1, 15c3-1a, 15c3-3, 15c3-3a, 17a-3, 17a-4 and 17a-11)
- Broker-Dealer Reports (Exchange Act Release No. 70073) (amending SEA Rules 17a-5 and 17a-11 and adopting Form Custody)
SEC Exemptive Order
- Order Providing Broker-Dealers a Temporary Exemption from the Requirements of Certain New Amendments to the Financial Responsibility Rules for Broker-Dealers under the Securities Exchange Act of 1934 (Exchange Act Release No. 70701) (granting temporary exemption, until March 3, 2014, from the amendments to the following financial responsibility rules adopted pursuant to Exchange Act Release No. 70072: Rule 15c3-3, except paragraph (j)(1); Rule 15c3-3a; Rule 17a-3; Rule 17a-4; and paragraph (c)(2)(iv)(E)(2) of Rule 15c3-1)
SEC No-Action Letters
- Securities Industry and Financial Markets Association, Re: Certain Amendments to Rule 15c3-3 (February 5, 2015)
- Financial Industry Regulatory Authority, Re: Broker-Dealers Holding Cash in a Reserve Account at a Non-Affiliated U.S. Branch of a Foreign Bank under Rule 15c3-3 (February 26, 2014)
- Securities Industry and Financial Markets Association, Re: Certain Amendments to Rule 15c3-3 (February 26, 2014)
SEC Division of Trading and Markets Staff FAQs
- Frequently Asked Questions Concerning the Amendments to Certain Broker-Dealer Financial Responsibility Rules, Division of Trading and Markets (March 6, 2014)
- Frequently Asked Questions Concerning the July 30, 2013 Amendments to the Broker-Dealer Financial Reporting Rule, Division of Trading and Markets (Updated November 29, 2018)
FINRA Regulatory Notices
Updates to the Interpretations of Financial and Operational Rules
The SEC staff communicates and issues oral and written interpretations to the financial responsibility and reporting rules, which FINRA publishes in the Interpretations of Financial and Operational Rules on the FINRA website. In connection with the adoption of the new amendments, FINRA has published the following Regulatory Notices announcing updates to the Interpretations of Financial and Operational Rules:
- Regulatory Notice 14-06 (February 7, 2014)
- Regulatory Notice 14-12 (March 24, 2014)
- Regulatory Notice 14-25 (June 23, 2014)
- Regulatory Notice 15-25 (June 29, 2015)
FINRA System Updates
FINRA updated the Regulatory Extension (REX) system to enable firms to file extension of time requests relating to new SEA Rule 15c3-3(d)(4) as adopted by the SEC in July 2013:
- Regulatory Notice 14-13 (March 25, 2014)
FINRA is making available a set of Frequently Asked Questions and a new template for members to comply with SEA Rule 17a-5(f)(2) (Statement Regarding Independent Public Accountant) as amended by the SEC in July 2013:
- Regulatory Notice 14-39 (October 8, 2014)