On June 25, 2025, the Securities and Exchange Commission announced an extension of the compliance deadline for broker-dealers subject to its December 2024 amendments to Rule 15c3-3—the Customer Protection Rule. The amendments require certain broker-dealers to compute reserve requirements daily rather than weekly. The new compliance deadline has been extended from December 31, 2025, to June 30, 2026, providing firms with six additional months to complete the transition.
Background on Rule 15c3-3
Rule 15c3-3, originally adopted in 1972, is a core component of the SEC's financial responsibility rules for broker-dealers. It is designed to protect customer assets by requiring broker-dealers to maintain physical possession or control of customer securities and to segregate customer funds in a special reserve account.
The 2024 amendments marked a significant shift by increasing the frequency of the reserve computation requirement from weekly to daily for firms that carry customer accounts and meet specified thresholds. The goal of this change is to enhance customer protection by reducing the lag between a firm's exposure and the funding of its reserve accounts, thereby minimizing risk during volatile market conditions.
Practical Impact of the Extension
In response to industry feedback, the Commission has recognized the operational complexities inherent in shifting to a daily computation regime—particularly for firms whose existing systems and personnel infrastructure were built around a weekly process. The extension to June 30, 2026, is intended to give broker-dealers the necessary time to:
- Upgrade or modify internal accounting and reserve computation systems;
- Establish robust testing protocols for daily reserve workflows;
- Train relevant personnel and adjust compliance frameworks accordingly.
In announcing the extension, SEC Chairman Paul S. Atkins noted, "The days of unreasonable deadlines have passed," underscoring the Commission's willingness to adopt a pragmatic approach to implementation timelines.
Our Perspective
The transition from weekly to daily reserve computations is not merely a procedural adjustment—it represents a fundamental shift in how broker-dealers must monitor liquidity, manage customer accounts, and coordinate operational systems in near-real time. For many firms, this change will require a top-down reassessment of financial operations, risk controls, and compliance infrastructure.
From our vantage point advising broker-dealers, clearing firms, and custodians, we see this extension as both necessary and welcome. It gives firms the opportunity to avoid a rushed or reactive implementation process and instead focus on building enduring systems that can withstand regulatory scrutiny and market stress.
That said, the added time should not be mistaken for a reprieve. Firms should view this extension as a window to actively test, refine, and document their updated reserve computation methodologies—preferably under simulated stress scenarios—to demonstrate readiness ahead of the new compliance deadline.
What Comes Next
We expect the SEC and its staff to continue engaging with the industry to clarify interpretive questions and implementation details leading up to the new deadline. Broker-dealers should take advantage of this period to finalize internal reviews, engage third-party vendors where appropriate, and consult legal counsel to ensure their systems and policies will be audit-ready by mid-2026.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
