Prudential / Capital Requirements Regulations in United States

The Securities and Exchange Commission today issued a conditional exemptive order that permits customer cross-margining of cash market positions in U.S. Treasury securities cleared by a registered clearing agency and futures positions in U.S. Treasury…

AI Analysis

The SEC has issued a conditional exemptive order and approved a proposed rule change by the Fixed Income Clearing Corporation (FICC) to enable customer cross-margining between cash U.S. Treasury positions cleared at FICC and futures positions cleared at the Chicago Mercantile Exchange (CME), extending a benefit previously limited to clearing members. This development enhances Treasury market liquidity and resilience by allowing dually registered broker-dealers/futures commission merchants (FCMs) to offer more efficient margin calculations to customers, aligning SEC and CFTC efforts in modernizing clearing infrastructure.

What Changed

- Exemptive Order: Provides relief from the SEC's broker-dealer customer protection rule (Rule 15c3-3), permitting dually registered broker-dealer/FCMs that are joint clearing members of FICC and CME...
Rule Change Approval: Approves FICC's filing to incorporate a Third Amended and Restated Cross-Margining Agreement with CME into its Government Securities Division rules, enabling cross-margining at...
Scope Expansion: Shifts from prior restrictions where only clearing members could cross-margin, now extending to eligible customers of qualifying firms, with safeguards for customer fund segregation...

Suggested Considerations

Qualifying Firms: Review and ensure compliance with exemptive order conditions (e.g., customer eligibility, account segregation, risk controls) before offering cross-margining; update internal policies, systems, and customer agreements to support combined margin calculations in futures accounts.
Operational Updates: Implement changes to clearing and margining processes aligned with the Third Amended Cross-Margining Agreement; conduct testing with FICC and CME for customer-level arrangements.
Documentation and Reporting: Maintain records demonstrating adherence to Rule 15c3-3 exemptions and notify customers of new margining options; monitor for CFTC parallel requirements on commingled funds.
Legal/Compliance Review: Assess dual SEC/CFTC registration status and joint membership; consult with counsel on condition-specific interpretations.

Key Dates

April 15, 2026

- SEC issues conditional exemptive order and approves FICC's proposed rule change

Post

April 15, 2026 (prior to Federal Register publication); - Exemptive order and rule approval made available on SEC.gov; related CFTC order on CFTC.gov

TBD (after Federal Register publication) DEADLINE

- Official effective date upon Federal Register publication (no specific comment or implementation deadline specified in announcement)

Compliance Impact

Urgency: High - This enables immediate operational opportunities for margin efficiency but requires swift review of systems and controls to meet conditional safeguards, avoiding customer protection violations under Rule 15c3-3. Firms risk regulatory scrutiny or missed liquidity benefits if unprepared, especially amid ongoing Treasury clearing mandates; proactive adoption supports market resilience goals without mandatory overhaul.

References

AI-generated analysis. May contain errors or omissions — verify with the original SEC source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading Investment Management

Topics:

Prudential / Capital Requirements

Broker DealerHedge FundAsset Manager

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🇺🇸 CFTC News high

April 15th 2026

CFTC Approves Order to Further Strengthen U.S. Treasury Market Liquidity

No description available.

Sectors:

Capital Markets & Trading

Topics:

Prudential / Capital Requirements Operational Resilience / Outsourcing Market Abuse / Surveillance

Broker DealerBank

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🇺🇸 FINRA regulatory_notice medium

April 6th 2026

Election Notice - 4/6/2026

FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.

Sectors:

Banking & Credit Investment Management Wealth & Private Banking

Topics:

Authorisation & Licensing Prudential / Capital Requirements Reporting & Disclosure

Broker DealerWealth ManagerAll Firms

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🇺🇸 CFTC News medium

April 3rd 2026

CFTC Chairman Selig Announces Deputy General Counsel Appointments

No description available.

Sectors:

Banking & Credit Capital Markets & Trading

Topics:

Authorisation & Licensing Prudential / Capital Requirements

BankBroker Dealer

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🇺🇸 FINRA regulatory_notice medium

March 18th 2026

Regulatory Notice 26-08

FINRA publishes Notices to provide firms with timely information on a variety of issues. To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Prudential / Capital Requirements Authorisation & Licensing

Broker DealerBankAsset Manager

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🇺🇸 SEC News low

February 27th 2026

SEC, FSA Hold Spring Financial Regulatory Dialogue

The U.S. Securities and Exchange Commission (SEC) and the Financial Services Agency of Japan (FSA) convened the Spring SEC-FSA Financial Regulatory Dialogue in Tokyo on Feb. 27, 2026.The SEC–FSA Dialogue builds upon longstanding efforts between the two…

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure Authorisation & Licensing

BankAsset ManagerBroker Dealer

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🇺🇸 CFTC News low

February 2nd 2026

CFTC Staff Issues Interpretation on Legacy Swap Status

No description available.

Sectors:

Banking & Credit Capital Markets & Trading

Topics:

Prudential / Capital Requirements Authorisation & Licensing

BankBroker Dealer

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🇺🇸 FINRA regulatory_notice low

January 24th 2026

Engagement

Sectors:

Investment Management Capital Markets & Trading Consumer Credit

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Reporting & Disclosure

Broker DealerAsset ManagerWealth Manager

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🇺🇸 FINRA regulatory_notice low

January 24th 2026

Derivatives and Other Balance Sheet Items (OBS)

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure

Broker DealerAsset ManagerBank

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🇺🇸 FINRA regulatory_notice low

January 24th 2026

Deferred Annuities

Sectors:

Investment Management Insurance & Pensions Capital Markets & Trading

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Reporting & Disclosure

Broker DealerAsset ManagerWealth Manager

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Certificates of Deposit (CDs)

Sectors:

Banking & Credit Investment Management Wealth & Private Banking

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Reporting & Disclosure

Broker DealerBankWealth Manager

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🇺🇸 FINRA regulatory_notice low

January 24th 2026

Cash Equivalents

Sectors:

Banking & Credit Investment Management Wealth & Private Banking

Topics:

Prudential / Capital Requirements Reporting & Disclosure Authorisation & Licensing

Broker DealerWealth ManagerBank

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Capital Acquisition Brokers

Sectors:

Capital Markets & Trading Investment Management Wealth & Private Banking

Topics:

Authorisation & Licensing Consumer Protection / Conduct Prudential / Capital Requirements

Broker DealerWealth ManagerAll Firms

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Annual Audit

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Prudential / Capital Requirements Authorisation & Licensing

Broker DealerAsset ManagerBank

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Alternative and Complex Products

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Consumer Protection / Conduct Prudential / Capital Requirements Authorisation & Licensing

Broker DealerWealth ManagerAsset Manager

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-03

Sectors:

Banking & Credit Investment Management Capital Markets & Trading

Topics:

Reporting & Disclosure Prudential / Capital Requirements Authorisation & Licensing

Broker DealerBankAsset Manager

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🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-12

Sectors:

Banking & Credit Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure

Broker DealerBank

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🇺🇸 FINRA Guidance medium

January 24th 2026

Information Notice - 11/7/25

AI Analysis

FINRA's Information Notice 11/7/25 publishes a **2026 Filing Schedule** on its website to guide clearing firms on accurate submission dates for extensions of time under Federal Reserve Regulation T, SEA Rule 15c3-3, and FINRA Rule 4210, accounting for holidays and business days. This matters because the automated REX system rejects incorrect dates, forcing resubmissions that delay compliance and risk regulatory violations amid shortened settlement cycles.

What Changed

No new regulatory requirements or rule amendments; this is guidance providing a pre-calculated Filing Schedule for 2026 to prevent errors in the REX system. It emphasizes using schedule dates around holidays when exchanges or banks close, and confirms fixed SEA Rule 15c3-3 deadlines (e.g., 30th/45th calendar days post-settlement, 10th business day for (m) possession/control, regardless of foreign settlement cycles).

Suggested Considerations

Access and reference the 2026 Filing Schedule on FINRA's website (via https://www.finra.org/rules-guidance/notices/information-notice-20251107 or related pages) for all REX system submissions.
Input schedule-specific dates for extensions, particularly around 2026 holidays when exchanges/banks close, to avoid automatic denials.
File SEA Rule 15c3-3 extensions on exact due dates listed above, even for foreign-traded securities.
Contact Theresa Reynolds (646-315-8567 or email) for questions.
Update internal compliance calendars, training, and systems to integrate the schedule.

Key Dates

November 7, 2025

- Notice published; 2026 Filing Schedule made available on FINRA website

Throughout 2026

- Use Filing Schedule for all extension requests, especially pre/post-holidays (e.g., Veterans Day 11/11/2026 bank holiday, Thanksgiving 11/26/2026, Christmas 12/25/2026)

30th calendar day after settlement

- (d)(2)

45th calendar day after settlement

- (d)(3), (h)

2nd business day after 30th calendar day from segregation deficit

- (d)(4)

Compliance Impact

Urgency: Medium - Proactive guidance prevents operational disruptions from REX rejections, but no immediate deadlines or penalties for non-use; however, inaccurate filings risk delayed margin compliance, customer liquidations under Regulation T, or possession/control failures under SEA Rule 15c3-3, especially in holiday periods with T+1 settlement pressures. Firms should integrate now (as of January 2026) to ensure Q1 readiness.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINRA source before acting. Full disclaimer.

Sectors:

Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure

Broker Dealer

View Original

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Regulatory Notice 25-19

Sectors:

Capital Markets & Trading Investment Management

Topics:

Reporting & Disclosure Prudential / Capital Requirements

Broker DealerAsset Manager

View Original

🇺🇸 CFTC News medium

December 22nd 2025

Michael Selig Sworn In as 16th CFTC Chairman

No description available.

Sectors:

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

Topics:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

BankBroker DealerCrypto Exchange

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🇺🇸 CFTC News medium

December 22nd 2025

Acting Chairman Caroline D. Pham Announces Departure from CFTC

No description available.

Sectors:

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

Topics:

Authorisation & Licensing Prudential / Capital Requirements Senior Managers / Governance

BankBroker DealerCrypto Exchange

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🇺🇸 CFTC Speech

December 12th 2025

Remarks by Acting Chairman Caroline D. Pham before the Financial Stability Oversight Council

No description available.

Sectors:

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

Topics:

Prudential / Capital Requirements Technology & Cyber Authorisation & Licensing

BankBroker DealerCrypto Exchange

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🇺🇸 SEC News medium

September 30th 2025

SEC Continues Efforts to Assist Market Participants During Implementation of Treasury Clearing Rules

The Securities and Exchange Commission today enhanced its efforts to assist broker-dealers and other market participants on the path to central clearing of U.S. Treasury securities, developing a one-stop webpage that puts the latest status updates, staff…

Sectors:

Banking & Credit Capital Markets & Trading

Topics:

Prudential / Capital Requirements Reporting & Disclosure

Broker DealerBank

View Original

🇺🇸 CFTC Speech

September 29th 2025