In June, the Financial Industry Regulatory Authority updated its interpretations of the Securities and Exchange Commission Rules 15c3-1 (net capital) and 15c3-3 (customer protection). Among other things, FINRA updated its Rule 15c3-3 interpretations concerning non-conforming subordination agreements for proprietary securities account of a broker or dealer (PAB account) exclusion, piggyback carrying arrangements, the aggregation of deposits for concentration calculation as it applies to cash deposits in reserve bank accounts, extensions of time and the calculation of the customer reserve formula as it pertains to short positions in non-customer accounts. FINRA also revised or rescinded 11 interpretations relating to Rule 15c3-1, including an interpretation relating to broker-dealers’ deposits at foreign entities and clearing deposits of introducing brokers.

FINRA’s Interpretations of Financial and Operational Rules are available here.