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The Securities and Exchange Commission and the Commodity Futures Trading Commission today issued a joint request for public comment on potential approaches to further harmonize regulatory frameworks applicable to portfolio margining across securities,โฆ
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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. Treasuryโฆ
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
- SEC issues conditional exemptive order and approves FICC's proposed rule change
April 15, 2026 (prior to Federal Register publication); - Exemptive order and rule approval made available on SEC.gov; related CFTC order on CFTC.gov
- 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.
AI-generated analysis. May contain errors or omissions โ verify with the
original SEC source
before acting. Full disclaimer.
Broker DealerHedge FundAsset Manager
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Broker DealerBank
FINRA publishes Notices to provide firms with timely information on a variety of issues.ย To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
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FINRA publishes Notices to provide firms with timely information on a variety of issues.ย To obtain a Notice published prior to 1995, please contact FINRA MediaSource at (240) 386-4200.
Broker DealerBankAsset Manager
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 SECโFSA Dialogue builds upon longstanding efforts between the twoโฆ
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Engagement
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Derivatives and Other Balance Sheet Items (OBS)
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Deferred Annuities
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Certificates of Deposit (CDs)
Broker DealerBankWealth Manager
Cash Equivalents
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Capital Acquisition Brokers
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Annual Audit
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Alternative and Complex Products
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Regulatory Notice 25-03
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Regulatory Notice 25-12
Broker DealerBank
Information Notice - 11/7/25
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
- Notice published; 2026 Filing Schedule made available on FINRA website
- 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)
- (d)(2)
- (d)(3), (h)
- (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.
AI-generated analysis. May contain errors or omissions โ verify with the
original FINRA source
before acting. Full disclaimer.
Broker Dealer
Regulatory Notice 25-19
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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, staffโฆ
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