Co-authored by Ross Pazzol and James M. Brady.
The Securities and Exchange Commission has extended the compliance date for broker-dealers from certain large trader recordkeeping, reporting and monitoring requirements. The SEC implemented large trader requirements in two phases, the first of which began on November 30, 2012. Phase one includes recordkeeping and reporting requirements for clearing broker-dealers of large traders that (i) are US-registered broker-dealers or (ii) trade via sponsored access arrangements.
Phase two, which was originally scheduled to take effect on May 1, 2013, includes the remaining large trader recordkeeping, reporting and monitoring provisions. However, the SEC has determined to delay the implementation of phase two to November 1, 2013 to give the SEC more time to evaluate the implementation issues presented in phase one. The delayed implementation also will allow broker-dealers subject to phase two more time to prepare for compliance with the large trader requirements applicable to them under phase two.
The SEC’s exemptive order is available here.