Regulatory Notice 23-04
FINRA Issues Guidance in Connection With Failures of Silicon Valley Bank and Signature Bank
SEA Rule 15c3-1 (Net Capital Requirements) and SEA Rule 15c3-3 (Customer Protection – Reserves and Custody of Securities)
FINRA is issuing this Notice to provide guidance for members affected by the recent failures of Silicon Valley Bank (SVB) and Signature Bank (Signature).
Questions concerning this Notice should be directed to your firm’s Risk Monitoring Analyst.
The following is guidance for member firms affected by the recent failures of SVB and Signature.
For Members with Deposits at SVB and Signature:
- All bank deposits at SVB and Signature may continue to be treated as allowable assets for net capital purposes.
- Balances in Customer and PAB Reserve Bank Accounts at SVB and Signature may continue to be treated as qualified reserve bank account deposits for purposes of SEA Rule 15c3-3(e).
- Any withdrawals of funds from accounts held at SVB and Signature must comply with the requirements of all applicable rules, e.g., SEA Rule 15c3-1(e) and SEA Rule 15c3-3(e)(1).