Rule 15c3-3
SUPPORTING STATEMENT
A. Justification
1. Necessity For Information Collection
During the “Paperwork Crisis” of 1967-1970, many brokers-dealers mishandled and misused customer funds and securities because they had inadequate and inefficient record keeping and segregation systems. Furthermore, the “bear market” of 1969-1970 caused many firms that lacked sufficient capital to utilize, properly or otherwise, customer funds and securities to obtain financing for their continued operation. In order to rectify these problems, the Securities and Exchange Commission (“Commission”) adopted Rule 15c3-3 (“Rule”) (17 CFR 240.15c3-3) (“Exhibit A”) to provide increased protection for the funds and securities of customers. The Rule is an integral part of the Commission’s financial responsibility program for brokers-dealers.
The Rule applies to all broker-dealers that hold securities or cash belonging to customers. Under the Rule, these broker-dealers must obtain and maintain possession or control of all the fully-paid and excess margin securities of their customers. In addition, they must make a periodic computation (“reserve computation”) to ascertain the amount of money they are holding that constitutes customer funds or funds obtained from the use of customer securities. If this amount known as “customer credits” exceeds the amount of money customers owe the firm (i.e., customer debits), the broker-dealer must deposit the excess in a special reserve bank account for the exclusive benefit of the firm’s customers (“Special Reserve Bank Account”).1 In this way, the Rule protects customer assets by requiring firms to maintain possession or control of customer securities, and by permitting firms to use customer money only to the extent necessary to finance customer related business.
The Commission is statutorily authorized by Section 15(c)(3) of the Securities Exchange Act of 1934 (“Act”) (15 U.S.C. 782(c)(3)) to adopt rules as necessary for the protection of investors and to provide safeguards with respect to the financial responsibility and related practices of brokers and dealers. Further statutory authority is found in Sections 17(a) and 23(a) of the Act (15 U.S.C. 78q and 78w).
The Rule requires broker-dealers to make the reserve computation on either a weekly or monthly basis. It also requires them (1) to maintain a description of the procedures utilized to comply with the possession and control requirements of the Rule; (2) to maintain a written notification from the bank where the Special Reserve Bank Account is located that all assets in the account are for the exclusive benefit of the broker-dealer’s customers; and (3) to give telegraphic notice to the Commission, and the appropriate Self-Regulatory Organization (“SRO”) if they fail to make a required deposit into the Special Reserve Bank Account.
In addition, the Commission adopted changes to Rule 15c3-3 on September 9, 2002 to require that a broker-dealer that effects transactions in security futures products or “SFPs” for customers also must (1) establish written policies and procedures for determining whether customer SFPs will be placed in a securities account or a futures account, and, if applicable, the process by which a customer may elect the type of account in which SFPs will be held, (2) provide each customer that plans to effect SFP transactions with a disclosure document containing certain information, (3) make a record of each change in account type, and (4) send each SFP customer notification of any change of account type.2
Finally, in March 2007, the Commission proposed for comment amendments3 to its net capital, customer protection, books and records, and notification rules for broker-dealers under the Exchange Act. More specifically, the proposed amendments to Rule 15c3-3 would require a broker-dealer, under certain circumstances, to (1) obtain written permission from broker-dealer (“PAB”) account holders to use their fully paid and excess margin securities,4 (3) perform a PAB reserve computation,5 (4) obtain written notification from a bank holding its PAB Special Reserve Account that the bank has received notice that the assets in the account are being held for the benefit of PAB account holders,6 (5) enter into a written contract with a bank holding its PAB Special Reserve Accounts in which the bank agrees the assets in the account would not be used as security for a loan to the broker-dealer and would not be subject to a right, charge, security interest, lien, or claim of any kind in favor of the bank,7 and (6) obtain the affirmative consent of a customer before changing the terms under which the customer’s free credit balances are invested.8 As a result of these proposed amendments in the 2007 proposing release, the one-time and annual hour burdens, as well as the total annualized cost burden would increase for Rule 15c3-3. This supporting statement describes the impact of these proposed amendments on the currently approved inventory for this collection of information, as well as provides revised burden estimates as a result of the proposed amendments to Rule 15c3-3 discussed in the 2007 proposing release.9
2. Purpose of, and Consequences of Not Requiring, the Information Collection
The Rule is an integral part of the Commission’s financial responsibility program for broker-dealers. Its purpose is to protect the rights of customers to promptly obtain their property from a broker-dealer. The reserve and notice requirements in the Rule facilitate the process by which the Commission and the various SROs monitor how broker-dealers are fulfilling their custodial responsibilities to investors. With the exception of the telegraphic notice requirement, governmental agencies do not regularly receive any of the information described above. Instead, the information is stored by the broker-dealer and made available to the various securities regulatory authorities as required to facilitate examinations and investigations. If broker-dealers were not required to create and maintain this information, the Commission’s ability to fulfill its statutory directive to protect investors would be diminished.
Rule 15c3-3 also requires that a broker-dealer provide each customer that wishes to engage in SFP activities with a disclosure document and notification of any change of account type. Without these disclosures and notifications, customers may be uncertain or confused, if a liquidation were to occur, as to which regulatory scheme is applicable to their account.
3. Role of Improved Information Technology and Obstacles to Reducing Burden
Nothing in Rule 15c3-3 would prevent a broker-dealer from using computers or other mechanical devices to generate, obtain, disclose or maintain the records and information required under these Rules, and most firms subject to Rule 15c3-3 presently utilize automated systems to comply with it. The Commission is not aware of any technical or legal obstacle to reducing the burden through the use of improved information technology.
4. Efforts to Identify Duplication
Not applicable.
5. Effects On Small Entities
Most small broker-dealers are exempt from the requirements of Rule 15c3-3 pursuant to paragraph 15c3-3(k). In addition, those small broker-dealers that are not exempt from the Rule can make the required computation monthly so long as they have aggregate indebtedness not exceeding 800 percent of net capital and carry aggregate customer funds not exceeding $1,000,000.
6. Consequences of Less Frequent Collection
If the required information were not collected or were collected less frequently, the level of protection afforded to the public by Rule 15c3-3 would be reduced.
7. Inconsistencies with Guidelines In 5 CFR 1320.5(d)(2)
The collection is in a manner consistent with the guidelines set forth in 5 CFR 1320.5(d)(2).
8. Consultations Outside the Agency
All Commission rule proposals are published in the Federal Register for public comment. The comment period for the 2007 proposing release that discusses the proposed amendments to Rule 15c3-1 was 60 days.10 This comment period afforded the public an opportunity to respond to the proposal. No PRA comments were received in response to this request.
9. Payments or Gifts to Respondents
Not applicable.
10. Assurance of Confidentiality
The information collected under this Rule is kept confidential to the extent permitted by the Freedom of Information Act and any other applicable law.
11. Sensitive Questions
Questions of a sensitive nature are not asked.
12. Estimate of Respondent Reporting Burden
As of December 31, 2006, there were approximately 344 broker-dealers fully subject to the Rule (i.e., broker-dealers that can not claim any of the exemptions enumerated at paragraph (k)), of which approximately 9 make daily, 245 make weekly, and 90 make monthly, reserve computations.11 The rule requires that each broker-dealer make a record of each such computation.12 The variation in size and complexity between these firms makes it very difficult to develop a meaningful figure for the amount of time required to make a record of each reserve computation. Based on experience in the area, Commission staff estimates that it takes between one and five hours, and that the average time spent across all the firms is 2.5 hours. Accordingly, Commission staff estimates that the resulting burden totals 45,960 hours annually ((2.5 hours x 240 computations x 9 respondents that calculate daily) + (2.5 hours x 52 computations x 245 respondents that calculate weekly) + (2.5 hours x 12 computations x 90 respondents that calculate monthly)).
A broker-dealer required to maintain the Special Reserve Bank Account prescribed by Rule 15c3-3 must obtain and retain a written notification from each bank in which it has a Special Reserve Bank Account to evidence bank’s acknowledgement that assets deposited in the Account are being held by the bank for the exclusive benefit of the broker-dealer’s customers.13 As stated previously, 344 broker-dealers are presently fully-subject to Rule 15c3-3. In addition, 140 broker-dealers operate in accordance with the exemption provided in paragraph (k)(2)(i) which also requires that a broker-dealer maintain a Special Reserve Bank Account. Broker-dealers generally maintain longstanding relationships with banks where they hold their Special Reserve Bank Accounts and thus do not need to obtain these letters often. The staff estimates that of the total broker-dealers that must comply with this rule, only 25%, or 121 ((344 + 140) x .25) must obtain 1 new letter each year (either because the broker-dealer changed the type of business it does and became subject to either paragraph (e)(3) or (k)(2)(i) or simply because the broker-dealer established a new Special Reserve Bank Account). The staff estimates that it would take a broker-dealer approximately 1 hour to obtain this written notification from a bank regarding a Special Reserve Bank Account.14 Therefore, Commission staff estimates that broker-dealers will spend approximately 121 hours each year to obtain these written notifications.
In addition, a broker-dealer must immediately notify the Commission and its designated examining authority if it fails to make a required deposit to its Special Reserve Bank Account.15 Commission staff estimates that broker-dealers file approximately 65 such notices per year.16 Based on staff experience with the industry, it would take a broker-dealer approximately 30 minutes to file the notice required under the Rule. Therefore, Commission staff estimates that broker-dealers would spend a total of approximately 33 hours each year to comply with the notice requirement of Rule 15c3-3.
In addition, a broker-dealer that effects transactions in SFPs for customers17 also will have paperwork burdens associated with the requirement in paragraph (o) of Rule 15c3-3 to make a record of each change in account type.18 More specifically, a broker-dealer that changes the type of account in which a customer’s SFPs are held must create a record of each change in account type that includes the name of the customer, the account number, the date the broker-dealer received the customer’s request to change the account type, and the date the change in account type took place. As of December 31, 2006, broker-dealers that were also registered as FCMs reported that they maintained 38,815,092 customer accounts.19 The staff estimates that 8% of these customers may engage in SFP transactions20 (38,815,092 accounts x 8% = 3,105,207). Further, the staff estimates that 20% per year may change account type.21 Thus, broker-dealers may be required to create this record for up to 621,041 accounts (3,105,207 accounts x 20%). The staff believes that it will take approximately 3 minutes to create each record.22 Thus, the total annual burden associated with creating a record of change of account type will be 31,052 hours (621,041 accounts x (3min/60min)).
Consequently, the staff estimates that the total annual burden hours associated with current Rule 15c3-3 would be approximately 77,166 hours (45,960 hours + 121 hours + 33 hours + 31,052 hours).
B. Summary of Reporting Burden Under 2007 Proposed Amendments to Rule 15c3-323
PAB Customer Reserve Account Recordkeeping Requirements
Under the 2007 proposing release, this proposed amendment to Rule 15c3-3 would require a broker-dealer to perform a PAB reserve computation and obtain certain agreements and notices related to proprietary account of another broker-dealer (referred to as “PAB accounts”) and, therefore, would impose recordkeeping burdens on a broker-dealer to the extent it: (1) has to perform a PAB computation; (2) chooses to use PAB securities and, therefore, needs to obtain agreements from PAB accountholders; and (3) opens a PAB reserve account at a new bank. The customer agreement requirement would be a one-time burden. It is standard for a broker-dealer to enter into a written agreement with an accountholder concerning the terms and conditions under which the account would be maintained. Therefore, requiring a written agreement would not result in additional burden. Rather, additional burdens would arise from the need to amend existing agreements and the standard agreement template that would be used for future customers.
Based on FOCUS Report filings, the Commission estimates that there are approximately 2,533 existing PAB customers and, therefore, broker-dealers would have to amend approximately 2,533 existing PAB agreements. The Commission further estimates that, on average, a firm would spend approximately 10 hours of employee resources amending each agreement. The Commission also estimates, based on FOCUS Reports, that approximately 75 broker-dealers carry PAB accounts and, therefore, these 75 firms would have to amend their standard PAB agreement template. The Commission estimates a firm would spend, on average, approximately 20 hours of employee resources on this task. Therefore, the Commission estimates the total one-time burden to the industry from these requirements would be approximately 26,830 total hours.24
Under the 2007 proposing release, the proposed requirements to perform a PAB computation and obtain agreements and notices from banks holding PAB accounts would result in annual burdens based on the number of broker-dealers that hold PAB accounts and the number of times per year these broker-dealers open new PAB bank accounts. Currently, to obtain the relief provided in the PAIB Letter,25 broker-dealers are required to obtain the agreements and notices from the banks. The Commission understands that broker-dealers generally already obtain these agreements and notices. Therefore, the Commission estimates there would be no additional burden imposed by this requirement.
The proposed amendment requiring a PAB computation would produce a one-time burden. Based on FOCUS Report filings, the Commission estimates that approximately 75 broker-dealers would perform a PAB computation. These firms already perform a reserve computation for domestic broker-dealer customers under the PAIB letter. Nonetheless, the Commission estimates these firms would spend, on average, approximately 30 hours of employee resources per firm updating their systems to implement changes that would be necessitated by our proposed amendment. Therefore, the Commission estimates that the total one-time burden to the industry arising from this proposed requirement would be approximately 2,250 hours.26
The proposed amendment requiring a PAB computation also would produce an annual burden. Based on FOCUS Report filings, the Commission estimates that approximately 71 broker-dealers would perform the PAB computation on a weekly basis and four broker-dealers would perform it on a monthly basis. The Commission further estimates that a broker-dealer would spend, on average, approximately 2.5 additional hours to complete the Rule 15c3-3 reserve computation as a result of the proposed amendment. Therefore, the Commission estimates that the total annual burden to the industry from this proposed requirement would be approximately 9,350 hours.27
ii. Affirmative Consent
Under the 2007 proposing release, this proposed amendment to Rule 15c3-3 would require a broker-dealer to obtain the affirmative consent of a new customer before changing the terms under which the customer’s free credit balances are treated and provide notice to existing customers prior to changing how their free credit balances are treated. The broker-dealer also would be required to make certain disclosures.
This proposed requirement would result in one-time and annual burdens to the broker-dealer industry. The Commission notes, however, that the requirement only would apply to a firm that carries customer free credit balances and opts to have the ability to change how its customers’ free credit balances are treated.
Based on staff experience, the Commission estimates that 50 broker-dealers would choose to provide existing and new customers with the disclosures and notices required under the proposed amendment in order to have the ability to change how their customers’ free credit balances are treated. The Commission further estimates these firms would spend, on average, approximately 200 hours of employee resources per firm updating their systems (including processes for generating customer account statements) to incorporate changes that would be necessitated by the proposed amendment. Therefore, the Commission estimates that the total one-time burden to the industry arising from this proposed requirement would be approximately 10,000 hours.28
As for annual burden, the Commission estimates these proposed requirements would impact 5% of the total broker-dealer customer accounts per year. Based on FOCUS Report filings, the Commission estimates there are approximately 109,300,000 customer accounts and, consequently, 5% of the accounts (5,465,000 accounts per year) would be impacted. The Commission further estimates that a broker-dealer would spend, on average, four minutes of employee resources to process an affirmative consent for new customers and a disclosure for existing customers. Therefore, the Commission estimates that the annual burden to the industry arising from the requirement would be approximately 364,333 hours.29
13. Estimate of Total Annualized Cost Burden
A. Estimate of Total Annualized Cost Burden under Rule 15c3-3
In addition, a broker-dealer that effects transactions in SFPs for customers30 also will have an annualized cost burden associated with the requirements in paragraph (o) of current Rule 15c3-3 to (1) provide each customer that plans to effect SFP transactions with a disclosure document containing certain information,31 and (2) send each SFP customer notification of any change of account type.32
Pursuant to Rule 15c3-3(o)(2)(i), a broker-dealer that effects transactions in SFPs for customers must provide each customer that engages in SFP transactions with a disclosure document containing certain information. The costs of printing and sending the disclosure document to customers will be based on the number of customer accounts that will be opened by customers to effect transactions in SFPs. As stated previously, the staff estimates that 8% of the accounts held by broker-dealers that are also registered as FCMs, or 3,105,207 accounts, may engage in SFP transactions.33 The staff estimates that the cost of printing and sending each disclosure document will be approximately $.12 per document sent.34 Thus, the staff estimates that the cost of printing and sending the disclosure document required pursuant to paragraph 15c3-3(o)(2)(i) will be approximately $372,625 (3,105,207 accounts x $.12).
Pursuant to Rule 15c3-3(o)(3)(ii), a broker-dealer that changes the type of account in which a customer’s SFPs are held must promptly notify the customer in writing of the date that change became effective. The staff estimates that 621,041 accounts (3,105,207 accounts x 20%) may change account type per year,35 thus broker-dealers would be required to send this notification to 621,041 customers. The staff believes that firms will use the least cost method to comply with these requirements, and will probably include this notification with other mailings sent to the customer. The staff estimates that the cost of printing and posting each notification will be approximately $.12 per document sent36 (again, the rule is flexible enough that a broker-dealer may send this notification with other customer mailings, such as confirmations or customer account statements). Therefore, the staff estimates that the cost of sending this notification to customers will be about $74,525 (621,041 accounts x $.12).
Under the 2007 proposing release, the proposed amendments to Rule 15c3-3 would apply to broker-dealer who choose to provide existing and new customers with the disclosures and notices required under the proposed amendment in order to have the ability to change how their customers’ free credit balances are treated. The Commission estimates that these firms would consult with outside counsel in making these systems changes, particularly with respect to the language in the disclosures and notices. The Commission estimates that, an outside counsel would spend, on average, approximately 50 hours assisting a broker-dealer in updating its systems for a one-time aggregate burden to the industry of 2,500 hours.37 The Commission further estimates that this work would be split between a partner and associate, with an associate performing a majority of the work. Therefore, the Commission estimates that the average hourly cost for an outside counsel would be approximately $400 per hour. For these reasons, the Commission estimates that the average one-time cost to a broker-dealer would be approximately $20,00038 and the one-time cost to the industry would be approximately $1,000,000.39
For purposes of the 83-I, the Commission is annualizing this cost over the three year approval period ($1,000,000/3) to reflect an annualized cost of $333,333.
14. Estimate of Cost to Federal Government
The government would experience no additional costs relating to the records broker-dealers must create pursuant to 15c3-3, but are not required to file with the Commission. However, the government would experience some costs associated with reviewing the notices broker-dealers are required to file pursuant to Rule 15c3-3. The staff estimates that reviewing these filings requires, on average, approximately fifteen minutes of Regulation Specialist staff time per filing at approximately $70 an hour (based on an annual salary of $84,000, adding average fringe benefits of 26% and average overhead of 25%, and dividing by 1,800 hours in a year). Consequently, the staff estimates that, the additional cost to the Federal Government associated with reviewing approximately 60 such notices per year would be $1,050 (15 hours x $70).
15. Explanation of Changes in Burden
The changes in the reporting burden are a result of the proposed amendments to Rule 15c3-3 as discussed in the 2007 proposing release (discussed in detail in Sections 12B and 13.B. above).40 Under the 2007 proposing release, the proposed amendments to Rule 15c3-3 would require a broker-dealer to perform a PAB reserve computation and obtain certain agreements and notices related to proprietary account of another broker-dealer (referred to as “PAB accounts”) and, therefore, would impose recordkeeping burdens on a broker-dealer to the extent it: (1) has to perform a PAB computation; (2) chooses to use PAB securities and, therefore, needs to obtain agreements from PAB accountholders; and (3) opens a PAB reserve account at a new bank. These proposed amendments to Rule 15c3-3 would add 29,080 (26,830 + 2,250) one-time burden hours to this collection of information, as well as increase the annual hour burden by 9,350 hours.
In addition, the amendment to Rule 15c3-3 to add new paragraph (j) would apply to broker-dealers who choose to provide existing and new customers with the required disclosures in order to have the ability to change how their customers’ free credit balances are treated. This amendment would add 10,000 one-time burden hours, as well as 364,333 annual hours to this collection of information. Finally, the amendment to paragraph (j) to Rule 15c3-3 relating to customers’ free credit balances also would result in an increase to the total annualized cost burden of $333,333 per year.
16. Information Collection Planned for Statistical Purposes
This provision is not applicable because compliance with the Rule will not require the employment of statistical methods.
17. Explanation as to Why Expiration Date Will Not Be Displayed
Not applicable.
18. Exceptions to Certificate
Not applicable.
B. Collection of Information Employing Statistical Methods
Not applicable.
1 For purposes of this PRA, the term Special Reserve Bank Account includes accounts set up in accordance with both paragraph (e)(1) and paragraph (k)(2)(i).
2 Exchange Act Release No. 46473 (Sep. 9, 2002), 67 FR 58284 (Sep. 13, 2002).
3 Exchange Act Release No. 55341 (Feb. 23, 2007), 72 FR 69412 (Mar. 19, 2007).
4 Proposed amendment adding paragraph (b)(5) to Rule 15c3-3.
5 Proposed amendment revising paragraph (e)(1) of Rule 15c3-3.
6 Proposed amendment revising paragraph (f) of Rule 15c3-3.
7 Id.
8 Proposed amendment adding paragraph (j) to Rule 15c3-3.
9 See supra note 3.
10 Exchange Act Release No. 55341 (Feb. 23, 2007), 72 FR 12862 (Mar. 19, 2007).
11 Per December 31, 2006 FOCUS II reports filed with the Commission by broker-dealers in compliance with Rule 17a-5 (17 CFR 240.17a-5).
12 17 CFR 240.15c3-3(e)(3).
13 17 CFR 240.15c3-3(f).
14 The language in these letters is largely standardized.
15 17 CFR 15c3-3(i).
16 From October 1, 2006 to August 27, 2007, broker-dealers had filed 60 such notices with the Commission. This amounts to approximately 5.45 notices per month. (5.45 x 12 months) = 65.4, or approximately 65 notices per year.
17 Broker-dealers that do not engage in an SFP business with or for customers are not affected by this section of Rule 15c3-3. Broker-dealers that engage in an SFP business must also register with the CFTC as a futures commission merchant (“FCM”). As of January 31, 2007 there were 64 broker-dealers that were also registered as FCMs.
18 17 CFR 240.15c3-3(o)(3)(i).
19 Per December 31, 2006, FOCUS Schedule 1 filings.
20 The staff derived its estimate from the number of active options accounts and conversations with industry representatives.
21 Broker-dealers that engage in an SFP business may choose not to allow customers to change account type because it may be costly to facilitate such conversions. In addition, once a customer has researched the issue and made a choice as to account type, it may be unlikely for the customer to change his or her account type.
22 In fact, the staff believes that most firms will have this process automated. To the extent that no person need be involved in the generation of this record, the burden will be very minimal.
23 See supra note 3.
24 (2,533 PAB customers x 10 hours per customer) + (75 firms x 20 hours per firm) = 26,830 hours.
25 See Letter from Michael A. Macchiaroli, Associate Director, Division of Market Regulation, Commission, to Raymond J. Hennessy, Vice President, NYSE, and Thomas Cassella, Vice President, NASD Regulation, Inc. (Nov. 10, 1998).
26 75 broker-dealers x 30 hours per firm = 2,250 hours.
27 ([71 weekly filers] x [52 weeks] x [2.5 hours per computation]) + ([4 monthly filers] x [12 months] x [2.5 hours per computation]) = 9,350 total hours.
28 50 broker-dealers x 200 hours per firm = 2,250.
29 5,465,000 accounts x 4 minutes/account = 364,333 hours. For purposes of the Form 83I only, the number of responses per respondent is reported as an average of 109,300 per broker-dealer (5,465,000/50 = 109,300 average accounts per broker-dealer).
30 Broker-dealers that do not engage in an SFP business with or for customers are not affected by this section of Rule 15c3-3.
31 17 CFR 240.15c3-3(o)(2).
32 17 CFR 240.15c3-3(o)(3)(ii).
33 The staff derived its estimate from the number of active options accounts and conversations with industry representatives.
34 This estimate is based on past conversations with industry representatives regarding other rule changes which required similar printing and postage costs. Postage may be minimized by including the disclosure document with other information mailed to customers. In addition, to account for inflation, we have included an inflation factor of 18% (based on the CPI from 2001 to 2007)(the prior conversations with industry representatives regarding postage costs took place in 2001).
35 As of December 31, 2006, broker-dealers that were also registered as FCMs reported that they maintained 38,815,092 customer accounts (per FOCUS Schedule 1 Filings filed by the broker-dealers with the Commission). The staff estimates that 8% of these customers may engage in SFP transactions (38,815,092 accounts x 8% = 3,105,207). Further, the staff estimates that 20% per year may change account type. Thus, broker-dealers may be required to create this record for up to 621,041 accounts (3,105,207 accounts x 20%).
36 See supra note 38.
37 50 broker-dealers x 50 hours per firm = 2,500 hours.
38 $400 per hour x 50 hours = $20,000.
39 50 broker-dealers x $20,000 = $1,000,000.
40 See supra note 3.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Extension of Rule 15c3-3 |
| File Modified | 0000-00-00 |
| File Created | 2021-02-01 |