REGULATION is a full time business and is completely out of control.....here is a sample of a course that most banks and investment firms will have to pay for their employees to attend and learn...dont get me wrong this is an important rule and goal..but cmon
SEC Customer Protection Rule 15c3-3
February 27, 2013
Bayards, New York City (Downtown)
7 CPE Credits
This intensive course, which sold out the last time it was offered, will review the details of the Customer Protection Rule 15c3-3 of the SEC. It will go into detail as to how contents of a customer’s account, portfolio positions and money balances, are required to be protected by the securities industry. It will also detail how various calculations are preformed on a daily, weekly and monthly basis to ensure this protection. It will define specifics of what protection means and how it is achieved in the broker/dealer community.
The seminar includes various exercises to ensure the student has a thorough, real-world understanding of the material covered. The course does not require more than basic math skills.
1. Definition of “customer” as it pertains to rule 15c3-3
2. What does the rule mean by “possession or control?”
3. What components of a customer’s account need to be afforded protection and what components do not.
4. How do we accomplish protection of customer securities as well as customer funds?
5. What if protection of customer assets is not achieved?
6. Examples of how to calculate protection requirements for both portfolio securities and money balances.
7. Review of Reserve Fund Calculation
8. What is a “qualified security?"
-Fully – Paid Security
-Excess Margin Security
-Free Credit Balance
Physical Possession or Control
-What is P&C?
-What needs to be in a Broker/Dealers P&C?
-When does P&C need to be obtained?
-Exceptions to P&C
Control of Securities
-Custody of a bank under specific circumstances
-Special Omnibus Account
-Items in transfer
-Other Bank Depositories
-Items in transit
-Other approved locations
Requirements of P&C
-Determination made each business day
-Monthly for inactive margin accounts
-Time frames for
-Fail to Receive
-Bona Short Position
Special Reserve Bank Account
-Deposit and Withdrawal Time Frames
-Notification of Banks
-Purpose of Computation
-Includable - Excludable items
-Stock record allocation
-Components of formula
Proposed Rule Change
-Cash Balance Limitations
-Definition of Qualified Securities
-Reduction of Aggregate Debit Items
-Seg deficits allocating to proprietary and non-customer locations
the cost ? $1000 per employee+ thousands of man hours...reduced productivity...yadda yadda yadda