FINRA – Announced Update of the Interpretations of Financial and Operational Rules

July 22, 2021 – FINRA issued RN 21-27 on updates to interpretations of financial and operational rules. Related to interpretations for SEA Rule 15c3-1 (net capital requirements, 17 CFR 240.15c3-1) and Rule 15c3-3 (reserves and custody of securities, 17 CFR 240.15c3-3).

The following interpretations have been added:
SEA Rule 15c3-1(c)(1)(i)/02 (Indebtedness in the Proprietary Trading Account of a Broker-Dealer) on page 182
SEA Rule 15c3-1(c)(2)(i)(G)/01 (Services Arrangement with a Parent or an Affiliate) on page 226
SEA Rule 15c3-1(c)(2)(iv)(B)/16 (Deficits or Unsecured Balances in Securities Transactions with a Federal Reserve Bank) on page 283
SEA Rule 15c3-1(c)(2)(iv)(C)/095 (Unsecured Receivables and Related Payables) on page 298
SEA Rule 15c3-1(c)(2)(viii)(C)/033 (Offsetting Sale Commitments in an Unregistered Offering) on page 653
SEA Rule 15c3-1(e)/01 (Services Arrangement with a Parent or an Affiliate) on page 855
SEA Rule 15c3-3(j)(2)(ii)(B)(3)(i)(C)/01 (Changing, Adding or Deleting Products Available Through a Sweep Program) on page 2467
SEA Rule 15c3-3(Exhibit A – Note E(5))/02 (Exclusion of Omnibus Accounts from the Requirements of Note E(5)) on page 2606
SEA Rule 15c3-3(Exhibit A – General)/012 (Netting a Customer’s Account Balances when Preparing the Reserve Formula Computation under the Alternative Standard) on page 2622
SEA Rule 15c3-3 (Exhibit A – Item 10)/10 (Term Debits in Customers’ Accounts Collateralized by Securities Subject to Restrictions on Use) on page 2729

The following interpretations have been revised:
SEA Rule 15c3-1(a)/01 (Additional Net Capital Requirement) on page 1
SEA Rule 15c3-1(c)(1)/11 (Accrued Liability for Concessions or Commissions Payable) on page 153
SEA Rule 15c3-1(c)(2)(iv)(C)/091 (Concessions Receivable from Individual Variable Annuities are Allowable for 30 Days; from Group Variable Annuities an Offset is Permitted) on page 296
SEA Rule 15c3-1(c)(2)(viii)(C)/032 (Offsetting Sale Commitments in a Registered Offering) on page 653
SEA Rule 15c3-3(a)(1)/01 (Customer/Non-Customer Classification) on page 2003
SEA Rule 15c3-3 (Exhibit A – Item 10)/07 (Debit Balances in Customers’ Accounts Collateralized by Control or Restricted Securities) on page 2728

The following interpretations have been rescinded:
SEA Rule 15c3-1(c)(2)(iv)(C)/09 (Commissions or Concessions Receivable versus Commissions or Concessions Payable) on page 296
SEA Rule 15c3-3(Exhibit A – Item 11)/041 (Federal Reserve Bank as a Non-Customer) on page 2744

For more information, visit www.finra.org.

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