Rule 15c3-1; Net Capital Requirements for Brokers and Dealers

ICR 201907-3235-012

OMB: 3235-0200

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2019-08-13
IC Document Collections
IC ID
Document
Title
Status
42976
Unchanged
236947
New
236945
New
236941
New
236939
New
236938
New
208585
Unchanged
208584
Unchanged
207432
Unchanged
206989
Unchanged
206988
Unchanged
206987
Unchanged
206986
Unchanged
206985
Unchanged
206984
Unchanged
206983
Unchanged
206981
Unchanged
206980
Unchanged
206979
Unchanged
206978
Unchanged
206977
Unchanged
206976
Unchanged
206975
Unchanged
206974
Unchanged
190804
Unchanged
190803
Unchanged
190802
Unchanged
ICR Details
3235-0200 201907-3235-012
Historical Active 201703-3235-004
SEC TM-270-197
Rule 15c3-1; Net Capital Requirements for Brokers and Dealers
Revision of a currently approved collection   No
Regular
Approved without change 12/09/2019
Retrieve Notice of Action (NOA) 08/26/2019
  Inventory as of this Action Requested Previously Approved
07/31/2020 36 Months From Approved 07/31/2020
3,576 0 1,940
74,675 0 65,916
379,000 0 160,000

Rule 15c3-1 was adopted in 1971 to ensure that brokers and dealers maintain sufficient liquid assets in excess of liabilities to promptly satisfy the claims of customers in the event the broker or dealer fails.

US Code: 15 USC 78b, 78c, 78o, 78o-4, 78q, 78w Name of Law: Sections 2, 3, 15, 15B, 17 and 23 of the Securities Exchange Act of 1934.
  
PL: Pub.L. 111 - 203 701-774 Name of Law: Dodd-Frank Act
US Code: 15 USC 78o-10 Name of Law: Securities Exchange Act of 1934 (Section 15F)
US Code: 15 USC 78c-5 Name of Law: Securities Exchange Act of 1934 (Section 3E)

3235-AL12 Final or interim final rulemaking 84 FR 43872 08/22/2019

No

27
IC Title Form No. Form Name
Rule 15c3-1; Appendix G monthly reports for new ANC firms
Rule 15c3-1; Appendix G quarterly reports for new ANC firms
Rule 15c3-1; Appendix G annual reports for new ANC firms
Rule 15c3-1; Appendix G recordkeeping for existing ANC firms
Rule 15c3-1; Appendix G recordkeeping for new ANY firms (ongoing)
Rule 15c3-1; Appendix G notification provision for existing ANC firms
Rule 15c3-1; Appendix G notification provision for new ANC firms
Rule 15c3-1; Appendix G updating risk management profile for existing ANC firms
Rule 15c3-1; Appendix G recordkeeping for new ANC firms (initial)
Rule 15c3-1; Appendix E computations for ANC firms
Rule 15c3-1; Paragraph (c)(2)(iv)(B): Disclosures and Agreements
Rule 15c3-1; Paragraph (c)(2)(i)(G)(2): Capital Withdrawal Liability
Rule 15c3-1; Notices
Rule 15c3-1; Opinion of counsel to file consolidated financial reports under Appendix C
Rule 15c3-1 -- Creating procedures to determine creditworthiness to avoid 15% haircut
Rule 15c3-1 -- Reviewing procedures to determine creditworthiness to avoid 15% haircut
Rule 15c3-1; Reviewing and back testing models for existing ANC firms
Rule 15c3-1; Reviewing and back testing models for new ANC firms
Rule 15c3-1; Appendix G monthly reports for existing ANC firms
Rule 15c3-1; Appendix G quarterly reports for existing ANC firms
Rule 15c3-1; Appendix G annual reports for existing ANC firms
Rule 15c3-1; Appendix G updating risk management profile for new ANC firms
NEW: Rule 15c3-4: Risk management control system
NEW: 15c3-1(c)(2)(xiv): Account control agreements – Opinion of Counsel
NEW: 15c3-1(c)(2(vi)(O)(l)(iii): Industry sector classification
NEW: 15c3-1(c)(2)(xiv): Account control agreements – Outside Counsel Review (Hours)
NEW: 15c3-1 Account Control Agreements – Outside Counsel Review (Costs)

  Total Approved Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 3,576 1,940 0 1,636 0 0
Annual Time Burden (Hours) 74,675 65,916 0 8,759 0 0
Annual Cost Burden (Dollars) 379,000 160,000 0 219,000 0 0
Yes
Changing Regulations
No
On June 21, 2019, in accordance with Section 764 of the Dodd-Frank Act, the Commission adopted amendments to Rule 15c3-1 to set forth net capital requirements for broker-dealers that also register as nonbank security-based swap dealers. The proposal was previously submitted to OIRA in 201603-3235-008. However, based on comments received on the proposal, the Commission added several new ICs and did not adopt one. In addition, this package includes one IC that was discussed in the notice of proposed rulemaking but inadvertently left out of the Supporting Statement and the ROCIS submission for the proposed rule. NOTE: Rule 15c3-1 contains pre-existing collections of information that were not part of the notice and comment process in the recent rulemaking and, therefore, are not being revised. Only the collections of information labeled as "NEW" are changing the burden. Accordingly, we have requested an expiration date commensurate with the current expiration date of 7/31/2020.

$0
No
    No
    No
No
Yes
No
Uncollected
Sheila Swartz 202 551-5545

  No

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
 
 
 
 
 
 
 
    (i) Why the information is being collected;
    (ii) Use of information;
    (iii) Burden estimate;
    (iv) Nature of response (voluntary, required for a benefit, or mandatory);
    (v) Nature and extent of confidentiality; and
    (vi) Need to display currently valid OMB control number;
 
 
 
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
08/26/2019


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