The SEC has extended the July 14, 2011 compliance date for certain provisions of Rule 15c3-5 under the Securities Exchange Act of 1934. Rule 15c3-5 requires brokers or dealers with access to trading securities directly on an exchange or alternative trading system ("ATS") and broker-dealer operators of an ATS that provide access to trading securities directly on their ATS to a person other than a broker-dealer, to establish, document and maintain a system of risk management controls and supervisory procedures. The new compliance date for (i) all Rule 15c3-5 requirements as they apply with respect to fixed income securities and (ii) the requirements of Rule 15c3-5(c)(1)(i) as it applies with respect to all securities, is November 30, 2011. (Rule 15c3-5(c)(1)(i) addresses financial risk management controls and supervisory procedures designed to prevent the entry of orders that exceed appropriate pre-set credit or capital thresholds.) The compliance date for all other provisions of Rule 15c3-5 remains July 14, 2011. For a more detailed discussion of Rule 15c3-5, see the November 16, 2010 Alert.
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