Extensions of Time Under Reg T and the Customer Protection Rule
Chapters in this video
- 0:00 The two triggers and their automatic consequences
- 1:06 Regulation T payment-date math: S+2 in a T+1 world
- 2:38 The exam trap: extensions do not erase violations
- 3:30 FINRA's four-factor review and the non-automatic rule
- 4:55 Pattern of inadequate funding and account restrictions
- 5:25 Clearing-firm monthly report: 5 business days
- 6:01 The four-step supervisory rule web
- 6:38 Rapid-fire exam recap
What this video covers
- The two distinct triggers for a margin-extension request: Federal Reserve Regulation T (Reg T) payment failure versus Securities and Exchange Commission (SEC) customer-protection delivery failure
- The automatic default consequence for each trigger: 90-day cash-account freeze for Reg T non-payment, forced buy-in or sell-out for customer-protection non-delivery
- The Reg T payment-date math under T+1 settlement: settlement plus two business days (S+2), which equals trade plus three (T+3) from the trade date
- Why a FINRA extension buys time but does not erase the underlying violation, and what documentation the firm must still maintain
- The four specific factors FINRA reviews (customer history, market conditions, firm's good-faith effort, anticipated cure date) and why extensions are never automatic
- What constitutes a pattern of inadequate funding (repeat extensions), the mandatory principal-imposed account restrictions, and the distinction between introducing-firm and clearing-firm responsibilities
- The clearing-firm monthly extension-ratio report and its strict 5-business-day filing deadline after the reporting month ends
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