Customer Protection Rule, SEC Rule 15c3-3

Auction Rate Securities

Temporary Relief from the Requirements of FINRA and SEC Rules Regarding the Net Capital Charges Applicable to Credit Extended on Non-Marginable ARPS  
Update to the April 11, 2008, Interpretive Letter: Auction Rate Preferred Securities (April 24, 2008)  
 

Buy-Sell Transactions

Buy-Sell Transactions are Considered Reverse Repurchase Positions  
 

Credits

CBOE Member is not a Customer  
Continuous Net Settlement  
Credit Balances in all Suspense Accounts  
Credit Balances Resulting From Principal Purchases From Customers*  
Customer Checks that are not deposited are Credits in the Reserve Formula  
Customer Credit Balances Related to Deposits in a Special Trust or Agency Account*  
Customer Credit Offset by Securities in Legal Transfer*  
Customer Payments Prior to Settlement Date  
Fails Resulting From Transactions in Joint International Arbitrage Accounts With Customers*  
Fails to Receive and When-issued Short Positions Relating to Unit Investment Trusts*  
Foreign Broker-dealers Considered as Customers  
NSCCs RECAPS Program  
Overdrafts in Bank Accounts*  
Postdated Customer Checks*  
Prepayments of Fails to Receive  
Proprietary Short Sales to Customers  
Reconfirmation of Securities In Transfer  
Registration Fee/Commission Refund as a Credit in the Reserve Formula*  
Same Customer on Both Sides of a Repurchase/Reverse Repurchase Transaction*  
Short Credit Balances*  
Short Securities Positions in Suspense Accounts with Related Credit Balances  
TEFRA Accounts Payable  
Zero Balance or Overdraft Bank Accounts*  
 

Debits

Accrued Custodial Fees Receivable - IRA Accounts  
Accrued Interest Receivable on Customers Margin Debits*  
Continuous Net Settlement  
Credit Balances Resulting From Principal Purchases From Customers*  
Customer Credit Offset by Securities in Legal Transfer*  
Debits in Customers' Accounts Collateralized by Restricted Securities Are Not Included in Reserve Formula Computation  
Dividends and Interest Receivable*  
Estate Account Debit Balances  
Fail to Deliver Securities in Transfer*  
Fails Resulting From Transactions in Joint International Arbitrage Accounts With Customers*  
Non-purpose Loan Receivables*  
NSCCs RECAPS Program  
Paying Customers Prior to Settlement Date*  
SEC Rule 15c3-3(a)(5)-Definition-Excess Margin Securities  
 

Exemptions

Exemptions, Checks Written by Introducing Firm on Behalf of the Clearing Firm  
Exemptions, Commission Recapture/Commission Rebate Program of Introducing Brokers  
Receipt of Customer Funds and Securities  
Receipt of Securities by Introducing Broker-Dealers  
Sale of Registered Investment Company Shares  
Self- Clearing of Commodities Transactions  
 

PAIB

Customers' Unsecured/Partly Secured Deficit Offset by Correspondents Deposits*  
DVP/RVP Accounts  
 

Physical Possession or Control of Securities

ADRs and Ordinary Shares  
Bonds Called For Redemption  
Bonds Tendered For Early Redemption  
Borrowing Required in Lieu of Buy-in  
Broker-Dealers Acting as 'Finders' or 'Conduits'  
Buy-in of Mortgage Backed Securities  
Commingled Securities under Custody Agreements  
Conversion of Securities Recalled from Loan to Fails to Receive  
Convertible Securities  
Credit Unions and Savings and Loan Associations as Control Locations  
Customer Bulk Deposit Accounts at OCC  
Deficiency of less than a Full Unit of Trading  
Designation of Margin and Excess Margin Securities  
Dividend Claim against Customer  
Dividends Payable, Suspense, and Difference Accounts  
Foreign-Issued, Foreign-Settled Securities  
Foreign Futures and Option Transactions  
Holding Valueless or Non-Transferable Customer Securities  
Issuers of Commercial Paper as Control Locations  
Long Option Positions  
Mutual Funds- Acknowledgement Letters  
Omnibus Account  
Records That Reflect Excess/Deficit Condition for Possession and Control Purposes  
Requirement to Reduce Securities to Possession or Control Applies to Municipal Transactions  
Rule 144 Securities in Transfer  
Same-day Turnarounds  
Same-day Turnarounds concerning Securities Borrowed and Fails to Deliver  
Securities Depository Position Report of Transfer Items  
Segregation Management Allocation System  
Special Custody Account for Accommodation Transfers as a Good Control Location  
Stock Splits  
Use of Nominee Name to Hold Customer Fully Paid Securities  
Use of Same-Day Turnarounds Privilege  
Use of Securities Subject to a Buy-in Procedure  
Validations of Items In Transfer Carried In A Special Omnibus Account  
 

Requirement to Reduce Securities to Possession or Control

Delivery of Securities to a Customer that Creates or Increases a Deficiency  
Increasing a Deficit By Trading Short From Inventory  
 

Reserve Bank Account

Borrowed Treasury Securities  
Conditions For Deposit Of Qualified Securities in a Reserve Bank Account  
Exempt Securities  
Fed Funds may be non- qualified Reserve Deposits  
Hindsight Notification for a Reserve Deficiency  
Money Market Deposit Account (MMDA)  
Money Market Funds  
Multiple Reserve Bank Account Withdrawals  
Offshore Funds are Not Permitted for Reserve Deposit Requirements  
Qualified Securities On Deposit  
Repurchase Agreements  
Requirement To Make Reserve Deposit When A Subsequent Calculation Shows No Deposit Is Required  
Reserve Account Notification Letter  
Reserve Bank Account Cash Deposits with Parent and/or Affiliated Bank  
Reserve Deposits Made From Overdrawn Account  
Sale And Delivery Of Securities Deposited In The Reserve Account  
Self-Clearing Broker- Dealers with no Customers  
 

Reserve Computation

Banks and Institutions are Customers*  
CBOE Member is not a Customer  
Credit Balances Arising from Limited Partnership Unit Sale  
Cross Liens Prohibited on Customers Securities*  
Customers' Unsecured/Partly Secured Deficit Offset by Correspondents Deposits*  
Money Market Deposit Account (MMDA)  
Netting of Money Market Fund Payables by Amounts Receivable from Money Market Funds*  
Non-Regulated Commodity Accounts  
PAIB Proprietary Accounts  
PAIB Reserve Deposit  
Prepaid Investment Advisory Fees*  
Proprietary Long Positions Allocated to Unsecured Customer Short Positions  
Reducing Credits To Avoid Deposit Is Prohibited  
Self-Clearing Broker- Dealers with no Customers  
Validations of Items In Transfer Carried In A Special Omnibus Account  
When Customer Securities Are Fully Paid  
Zero Balance or Overdraft Bank Accounts*  
 

Unendorsed Stock Certificates

Unendorsed Stock Certificates, Customer Debits, Inadequately Secured  
Last Updated: 4/11/08