Carrying/Clearing Firm Support

ACI provides specialized support to carrying and clearing broker-dealers, who face heightened regulatory scrutiny and operational complexity beyond the scope of a non-carrying firm. We help you meet these obligations reliably and in full compliance.

Our services for carrying/clearing firms include:

Rule 15c3-3 Customer Reserve Calculations

SEC Rule 15c3-3 requires carrying firms to maintain a reserve bank account to protect customer funds by segregating customer funds from firm funds. ACI performs these complex reserve formula computations in accordance with regulatory requirements, ensuring accuracy, completeness and timeliness.

Rule 17a-13 Quarterly Box Count Support

SEC and FINRA rules require carrying firms to conduct physical securities counts at least quarterly. ACI assists with the planning, execution and documentation of box counts to ensure accuracy, reconciliation and compliance with Rule 17a-13.

Back-Office Processes and Procedures

A well-functioning back office is critical to regulatory compliance and operational efficiency. ACI designs and maintains back-office procedures tailored to your firm’s clearing operations.

Customized processes aligned with FINRA and SEC rules
Documentation and workflow automation
Ongoing updates to reflect regulatory and operational changes
Guidance and review of operational policies and procedures to ensure alignment with regulatory requirements and best practices

Operational Recordkeeping Requirements

SEC and FINRA rules require broker-dealers to create and maintain records as part of their daily business operations. FINRA Rules 17a-3 and 17a-4 govern the creation, maintenance and retention requirements for books and records. ACI helps firms maintain compliance with these requirements by ensuring appropriate books and records are created and maintained correctly.

Guidance on processes and controls to ensure books and records are kept current
Creation, maintenance and retention of required reports
Alignment of record repositories with appropriate regulatory standards
Review of audit trail requirements and regulatory requirements for authorized access and control

Stress and Liquidity Management Framework

Robust stress testing and liquidity planning are key components of financial resilience, particularly in light of proposed FINRA Rule 4610. ACI helps firms build practical frameworks to meet regulatory expectations and internal risk thresholds.

Questions on ACI’s services for carrying/clearing firms or your regulatory obligations in general? Here’s what you need to know.

What exactly is SEC Rule 15c3-3 and why is it important?

SEC Rule 15c3-3, also known as the Customer Protection Rule, requires carrying firms to maintain physical control of fully paid and excess margin securities, as well as hold a reserve of cash or qualified securities in a bank account for the exclusive benefit of customers – ensuring protection in case of insolvency.

Are any broker-dealers exempt from reserve requirements?

Yes. Broker-dealers that qualify under SEC Rule 15c3-3(k) – such as firms that introduce their customers’ business on a fully disclosed basis to a clearing broker and firms that promptly forward customer funds and securities – are exempt from reserve and custody requirements, provided they claim the exemption in their FOCUS filings and submit an annual Exemption Report. Separately, some firms – typically firms conducting private placements and proprietary trading firms with no customer accounts or assets – may be considered “non-covered broker-dealers” under SEC and FINRA guidance. These firms are not required to maintain a reserve account and should not claim a (k) exemption, but must file an Exemption Report confirming their non-custodial status. ACI can help determine whether your firm qualifies for an exemption or non-covered status, and ensure your filings reflect the most current regulatory expectations.

What is the Supplemental Liquidity Schedule (SLS)?

The SLS is a FINRA-required filing that provides a detailed look at a firm’s funding sources, liquidity risk and maturity mismatches. ACI ensures the SLS is prepared and filed in coordination with month-end reporting and is appropriate for your regulatory framework.

What is a Special Reserve account and why is correct titling important?

An Exclusive Benefit of Customers (EBOC) account is a specially titled reserve account that must clearly state that its purpose is for customer protection, not firm use, and that no party has a right to lien on the assets in the account. Proper titling is critical – regulators may view omissions (e.g., missing “exclusive benefit”) as non-compliance. ACI ensures compliant account opening, titling and bank agreements.