Division of Trading and Markets: Frequently Asked Questions – Rule 15c3-3 and Daily Customer and PAB Reserve Computations

Responses to Frequently Asked Questions Regarding Daily Customer Reserve and PAB Reserve Computation Requirements (December 8, 2025)

The Division of Trading and Markets (“Division”), U.S. Securities and Exchange Commission (“Commission”), has prepared the following responses to questions about broker-dealers that hold customer cash and securities (“carrying broker-dealers”) and perform a daily reserve computation for accounts of customers (“customer reserve computation”) and accounts of other broker-dealers (“PAB reserve computation”) under Rule 15c3-3 under the Securities Exchange Act of 1934 (“Exchange Act”).  These responses represent the views of the staff of the Division.  They are not a rule, regulation, or statement of the Commission.  The Commission has neither approved nor disapproved this content.  These responses, like all staff statements, have no legal force or effect: they do not alter or amend applicable law, and they create no new or additional obligations for any person.

The staff may update these questions and answers periodically.  In each update, the questions added after publication of the last version will be marked with “MODIFIED” or “NEW.”

Compliance Date for Required Daily Customer and/or PAB Reserve Computations

Question 1: What is the compliance date for a carrying broker-dealer with average total credits that are equal to or greater than $500 million to begin required daily customer and/or PAB reserve computations under paragraph (e)(3)(i)(B)(1) of Rule 15c3-3?

Answer: A carrying broker-dealer with average total credits that are equal to or greater than $500 million using each of the 12 filed month-end FOCUS Reports from January 31, 2025, through December 31, 2025, must perform customer and PAB reserve computations daily beginning no later than June 30, 2026 (i.e., six months after December 31, 2025).[1]

Test Customer and/or PAB Reserve Computations

Question 2: Can a carrying broker-dealer perform test customer and/or PAB reserve computations prior to beginning daily required or voluntary customer or PAB reserve computations under paragraph (e)(3) of Rule 15c3-3?

Answer: Yes, a carrying broker-dealer may perform test customer and/or PAB reserve computations to test its new daily processes, procedures, and systems for compliance prior to beginning to perform required or voluntary daily customer and PAB reserve computations under paragraph (e)(3) of Rule 15c3-3.[2]  These test reserve computations should not result in any withdrawals from the carrying broker-dealer’s customer or PAB reserve bank account.

In addition, documenting the purpose of test customer and/or PAB reserve computations would help broker-dealers differentiate these tests from required or voluntary computations performed under the rule.  This documentation would assist in demonstrating compliance with paragraph (e)(3) of Rule 15c3-3 during an exam.

2% Aggregate Debit Items Charge in the Customer Reserve Computation

Voluntary Daily Customer Reserve Computations

Question 3: Can a carrying broker-dealer that elects the alternative method for net capital under paragraph (a)(1)(ii) of Rule 15c3-1 apply the 2% aggregate debit items charge (rather than the 3% aggregate debit items charge) if the carrying broker-dealer voluntarily performs a daily customer reserve computation?

Answer: Yes.  A carrying broker-dealer that elects the alternative method for net capital under paragraph (a)(1)(ii) of Rule 15c3-1[3] and voluntarily performs a daily customer reserve computation may apply the 2% aggregate debit items charge beginning on or after March 14, 2025,[4] if it notifies its designated examining authority (“DEA”) in writing at least 30 days prior to beginning the daily customer reserve computation.[5] 

Required Daily Customer Reserve Computations

Question 4: Are carrying broker-dealers that elect the alternative method for net capital under paragraph (a)(1)(ii) of Rule 15c3-1 and that are required to perform a daily customer reserve computation under paragraph (e)(3)(i)(B)(1) of Rule 15c3-3 required to notify their DEA prior to applying the 2% aggregate debit items charge in performing its customer reserve computation?

Answer: No.  Carrying broker-dealers that elect the alternative method for net capital and that are required to perform a daily customer reserve computation under paragraph (e)(3)(i)(B)(1) of Rule 15c3-3 may apply the 2% aggregate debit items charge in performing their customer reserve computation under paragraph (a)(1)(ii)(A) under Rule 15c3-1 without any prior DEA notification.[6]   

Sweep Program Cash and the Customer Reserve Computation 

Question 5: Can a carrying broker-dealer reduce a required deposit (i.e., excess of total credits over total debits) to its customer reserve bank account(s) by the amount of credits included in such customer reserve computation which are transferred, on the business day following the “as of” date of the computation, to a Sweep Program under paragraph (j)(2)(ii) of Rule 15c3-3 (hereinafter “sweep credits”)?

Answer: Staff would not object if a carrying broker-dealer reduces a required deposit to its customer reserve bank account(s) by the amount of sweep credits included in such customer reserve computation which are transferred, on the business day following the “as of” date of the computation, to a Sweep Program under paragraph (j)(2)(ii) of Rule 15c3-3.[7]  A carrying broker-dealer may not consider any sweep credits in determining whether it may make a withdrawal from its customer reserve bank account(s) under paragraph (g) of Rule 15c3-3.

Non-Computation Days for Certain Holidays and Certain Business Days Adjacent to Holidays for Carrying Broker-Dealers Performing a Daily Customer and/or PAB Reserve Computation

Question 6: Can a carrying broker-dealer that performs a required[8] daily customer and/or PAB reserve computation treat Federal Holidays, Good Friday, and certain other business days adjacent to holidays as non-computation days (“Additional Days”) for purposes of paragraph (e)(3) of Rule 15c3-3?

Answer: Staff would not object if a carrying broker-dealer that performs a required daily customer and/or PAB reserve computation does not perform a customer and/or PAB reserve computation on the following days: (1) a Federal Holiday;[9] (2) Good Friday; or (3) the following Additional Days:[10]