On 25 June 2025, the US Securities and Exchange Commission (SEC) announced an extension of the compliance date for the amendments to US SEC Rule 15c3-3 (the broker-dealer customer protection rule) titled “Daily Computation of Customer and Broker-Dealer Reserve Requirements under the Broker-Dealer Customer Protection Rule” (Release No. 34-102022), moving the deadline from 31 December 2025 to 30 June 2026. These amendments were initially adopted on 20 December 2024 and require certain broker-dealers to perform daily reserve computations and make daily deposits into their reserve bank accounts, rather than on a weekly basis. Carrying broker-dealers that exceed a rolling 12-month average of $500 million in total credits must comply.
The final rule, was published in the Federal Register on 14 January 2025. The rule also allows broker-dealers performing daily reserve computations to reduce aggregate debit items by 2% instead of 3% as part of the calculation, and includes technical amendments to the FOCUS Report to reflect this change.
Compliance Requirements
Who is Required to Comply?
“A carrying broker-dealer that has average total credits that are equal to or greater than $500 million (‘$500 Million Threshold’) must perform the customer and/or PAB reserve computations daily, rather than weekly…” Broker-dealers that hold more than $500 million in customer + PAB credit balances (rolling 12-month average) must perform daily reserve computations and deposits.
Definition of “Average Total Credits”
“…the arithmetic mean of the sum of total credits in the customer reserve computation and the PAB reserve computation reported in the 12 most recently filed month-end FOCUS Reports.” That is to say take the sum of monthly-end total credits (customer + PAB) for the last 12 months and divide by 12. If this average ≥ $500M, if so, daily computation is mandatory.
Timing and Frequency
“…must perform the customer and PAB reserve computations… as of the close of the previous business day, and any required deposits must be made no later than one hour after the opening of banking business on the second following business day.” Therefore daily reserve computation is calculated each business day-end, and deposits must be made by next-next business day morning (T+2 by 10 AM).
Six-Month Compliance Window
“…a carrying broker-dealer must comply with the requirement… no later than six months after its average total credits equal or exceed the $500 Million Threshold.” Which states that once you cross the $500M markyou have six months to start daily reserve compliance.
Reverting to Weekly Computation
“…must continue to perform customer and PAB reserve computations daily until it provides written notification to its designated examining authority (‘DEA’)… 60 days prior to reverting to weekly computations.” In simple terms, if you fall below $500M, you cannot revert immediately. You must give your DEA 60 days’ prior notice.
Debit Reduction Benefit (from 3% to 2%)
“…carrying broker-dealers that use the alternative method and are above the $500 Million Threshold… may reduce their aggregate debit items by 2% rather than 3%.” Which basically states that if you’re doing daily computation, you get a capital relief by applying 2% debit haircut (not 3%) in net capital calculation.
Voluntary Daily Computation and Conditions
The relevant entities “…may voluntarily perform a daily customer reserve computation… and apply the 2% debit reduction… must notify their DEA at least 30-days prior… must receive prior approval from their DEA to revert.”
The SEC’s extension provides broker-dealers with additional time to update systems, train staff, and thoroughly test their daily reserve processes before the new requirements take effect.
