SEC Footnote 74 Provides Alternative for Broker-Dealers Who Don’t Hold Customer Funds
The SEC recently provided non-carrying broker dealers with an alternative option as to how they can maintain their exemptive status under SEC Rule 15c-3-3.
ACI Managing Partner, Jay Gettenberg, has worked closely with the Public Company Accounting Oversight Board (PCAOB) and FINRA in recent years to address the practical reality that there are FINRA member firms who do not hold customer funds, yet do not technically qualify under any of the four exemptions listed on the X-17A-5 Focus Report.