For Your Information - June 2002

Submission of PAIB Computation in FOCUS Filings

Beginning with the June 2002 FOCUS Report, members that hold assets of other member firms and compute a PAIB Reserve with respect to such assets will need to include the PAIB Reserve computation with their regular FOCUS filing. The PAIB Reserve computation will be included as page 9B in the Part II FOCUS filing.

For Your Information - July 2002

Revision to Net Capital Treatment of Clearing Agreement Penalty Clauses

In the Regulatory Short Takes section of the Spring 2000 Regulatory & Compliance Alert, Volume 14-1, NASD indicated that all or a portion of the amount specified in a clearing agreement as a termination fee would be treated as a charge to the introducing firm's net capital. The Question and Answer included in the Regulatory Short Take was as follows:

Q:   Is the penalty amount in a penalty clause contained in a clearing agreement a charge to net capital?

For Your Information - March 2003

This article is intended to clarify a factual reference to SEC Rule 17a-4 (f)(2)(i) previously reported in the Fall 2000, Volume 14.3, of the NASD Regulatory & Compliance Alert.

SEC Rule 17a-4 (f)(2)(i)

Q:   If a broker/dealer intends to store records using electronic storage media, can a third party vendor provide services to a broker/dealer if the third-party vendor is an affiliated company?

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