SEC – Responses to Frequently Asked Questions Regarding Financial Responsibility Requirements as Applied to Security-Based Swap Activities of Broker-Dealers and Security-Based Swap Dealers.

October 8, 2021 – SEC – Responses to Frequently Asked Questions Regarding Financial Responsibility Requirements as Applied to Security-Based Swap Activities of Broker-Dealers and Security-Based Swap Dealers.

No objection if B/D or B-D/SBSD that obtained no-lien letter from bank under 17 CFR 240.15c3-3 does not get new letter if existing letter legally sufficient to cover excess securities collateral of SBS customers to deem bank a satisfactory control location. Notwithstanding SBSD’s reasonable efforts to deliver variation margin to counterparty, if counterparty elects not to receive variation margin, then variation margin is not subject to segregation rules under Rule 15c3-3 or Rule 18a-4 (17 CFR 240.18a-4). Until September 1, 2022, no objection if SBSD or B-D/SBSD is authorized to use models to compute deductions for credit risk per 17 CFR 240.18a-1(d) or 17 CFR 240.15c3-1e. FAQs also provided for differences between call report and FOCUS report part IIC.

For more information, visit www.sec.gov.



We use cookies in order to give you the best possible experience on our website. By continuing to use this site, you agree to our use of cookies.
Accept