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

ICR 201912-3235-005

OMB: 3235-0200

Federal Form Document

Forms and Documents
Document
Name
Status
Supplementary Document
2020-04-20
Supplementary Document
2020-04-20
Supporting Statement A
2020-01-16
Supplementary Document
2020-01-16
IC Document Collections
IC ID
Document
Title
Status
42976
Modified
236947
Unchanged
236945
Unchanged
236941
Unchanged
236939
Unchanged
236938
Unchanged
208585
Modified
208584
Unchanged
207432
Modified
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
Modified
190802
Unchanged
ICR Details
3235-0200 201912-3235-005
Active 201907-3235-012
SEC TM-270-197
Rule 15c3-1; Net Capital Requirements for Brokers and Dealers
Extension without change of a currently approved collection   No
Regular
Approved without change 06/11/2020
Retrieve Notice of Action (NOA) 04/20/2020
  Inventory as of this Action Requested Previously Approved
06/30/2023 36 Months From Approved 07/31/2020
3,502 0 3,576
76,981 0 74,675
299,000 0 379,000

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)

Not associated with rulemaking

  85 FR 6653 02/05/2020
85 FR 21898 04/20/2020
No

27
IC Title Form No. Form Name
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 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 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 3,502 3,576 0 0 -74 0
Annual Time Burden (Hours) 76,981 74,675 0 0 2,306 0
Annual Cost Burden (Dollars) 299,000 379,000 0 0 -80,000 0
No
No
The change in burden between this supporting statement and the supporting statement uploaded on August 13, 2019 is due to the following: The estimated number of Rule 15c3-1 notices filed decreased from 902 to 844 and the estimated number of capital withdrawal requests filed decreased from 90 to 84. This caused the burden associated with 15c3-1 notices to decrease from 451 hours to 422 hours and the burden associated with capital withdrawal requests to decrease from 90 hours to 84 hours. Additionally, fewer firms are filing consolidated financial reports, resulting in the number of firms filing an opinion of counsel under Appendix C of Rule 15c3-1 decreasing from approximately 20 to approximately 10. This caused the cost burden associated with opinions of counsel to decrease from $160,000 per year to $80,000 per year. The burden associated with reviewing procedures to determine creditworthiness increased from 1,169 hours per year to 3,510 hours per year because this burden was erroneously annualized in prior submissions. Therefore, the aggregate hour burden estimate increased from approximately 74,675 hours to approximately 76,981 hours and the aggregate cost burden estimate decreased from approximately $379,000 to approximately $299,000.

$0
No
    No
    No
No
Yes
No
No
Valentina Deng 202 551-5778

  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.
04/20/2020


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