Rule 15c3-1: Capital Adequacy
Method: Instructor-led training
Time: 8:30 am - 5:00 pm
Instructor: Tom Santulli
Fee: Call for details (212) 851-8414 or email at
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Download Course Agenda
The Rule 15c3-1: Capital Adequacy course is intended to provide an understanding of the financial/operational responsibilities mandated by the Securities and Exchange Commission Regulation 240.15c3-1 and how these requirements impact daily business activities. The course includes accounting and periodic reporting requirements, net capital calculations and broker-dealer contractual commitments.
Learning objectives:
- Explore historical circumstances leading to the current financial and record keeping rules
- Discuss the reporting and accounting records maintained by broker-dealers
- Review the overlapping relationships of the Net Capital Rule 15c3-1, Customer Protection Rule 15c3-3, and the record keeping and financial reporting requirements of Rules 17a-3, 17a-4 and 17a-5
- Identify minimum “dollar” net capital requirements triggered as a result of broker-dealers activities
- Learn the distinctions between Aggregate Indebtedness and Aggregated Debit requirements
- Analyze Debt to Debt/Equity Requirements of Rule 15c3-1
- Discuss the components of a Non Allowable Asset and the causes of Operational Penalties
- Review “haircut” reductions in the market value of proprietary inventory positions
- Explore marketability requirements of Rule 15c3-1
- Describe contractual commitments and “moment in time” requirements
Who should attend:
- Supervisory financial and operations staff, auditors, legal/compliance and risk management staff, sales professionals, and regulatory reporting training staff.
Rule 15c3-1: Capital Adequacy - Course Agenda
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8:30 am – 9:00 am
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Registration and Continental Breakfast
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9:00 am – 10:00 am
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Background History of the Rule
- Pre-1934 SEC regulation
- Securities & Exchange Acts of 1933 & 1934
- Pre 1975 SEC/NYSE regulations and reporting requirements
- The paperwork crisis and broker-dealer failures
- Securities Investor Protection Act
- Capital adequacy and customer asset protection rules
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10:00 am – 10:15 am
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Break
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10:15 am - 12:00 pm
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Current Financial/Operational/Record Keeping Requirements
- Books and records requirements SEC Rules 17a-3,4,5
- Firm and customer asset segregation SEC Rule 15c 3-3
- Net Capital Liquidity Requirements SEC rule 15c3-1
Financial/Operational Reporting Requirements
- The FOCUS Report and Annual Audit Report
- Rule 15c3-3 Reserve requirements Cash vs. Securities
- SEC/FINRA regulatory oversight and exception reporting
Broker/Dealer Accounting
- GAAP accounting
- Recording securities locations
- Unique transactions-Deliveries-Lending-Subordinated Debt
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12:00 pm – 1:00 pm
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Lunch
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1:00 pm – 3:00 pm
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The Net Capital Computation
- Minimum Net Capital “24/7” requirements
- Types of Broker/Dealers
- Aggregate Indebtedness (“AI”) vs. Aggregate Debits (“ADI”)
- Debt to Net Worth requirements
- Components of the computation
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3:00 pm – 3:15 pm
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Break
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3:15 pm – 5:00 pm
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The Net Capital Computation (continued)
- Non Allowable Assets-noncurrent and unsecured
- Operational penalties
- Marketable and non-marketable Securities
- Securities “Haircuts” categorization and optimization
- Contractual commitments and moment in time requirements
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