FINRA published, and set compliance dates for, a new Supplemental Liquidity Schedule ("SLS") to the Financial and Operational Combined Uniform Single Report ("FOCUS Report"). FINRA's actions were taken pursuant to FINRA Rule 4524 ("Supplemental FOCUS Information") for "members with the largest customer and counterparty exposures."
As previously covered, the SLS is applicable to members (i) with $25 million or more in free credit balances as defined under SEA Rule 15c3-3(a)(8) ("Customer protection-reserves and custody of securities") or (ii) with at least $1 billion in aggregate outstanding repurchase agreements, securities loan contracts and bank loans, as reported on their most recent FOCUS Report. For any period in which a member meets the $25 million or $1 billion threshold, FINRA stated that the member must complete the SLS by the last business day of each month and file it within 24 business days of the end of the month.
The new requirement goes into effect on March 1, 2022; broker-dealers must complete the first SLS as of the end of March 2022, and file it by May 4, 2022.
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