{ "tool_id": "art-580-15c3-3a-note-h-margin-debit", "tool_version": "1.0.0", "display_name": "15c3-3a Note H Margin-Debit Computation", "mcp_name": "compute_note_h_margin_debit", "mandate_type": "analytics_mandate", "wave": 97, "gpu": false, "url": "https://ainumbers.co/chaingraph/art-580-15c3-3a-note-h-margin-debit.html", "description": "Recomputes whether a margin debit related to a broker-dealer's customer transactions in U.S. Treasury securities qualifies for inclusion in the Exchange Act Rule 15c3-3 customer or PAB reserve formula under Note H to Exhibit A (Rule 15c3-3a), and if so computes the debit amount. Note H permits that debit only once a registered clearing agency's rules satisfy several Commission-approved conditions and the margin itself comes from a permitted source. This kernel checks each condition as its own declared boolean, cited to the specific Note H subsection it comes from: Commission approval and published notice that Note H is satisfied for the named clearing agency; a separate, gross, per-customer margin calculation; cash margin invested only in short-term U.S. Treasury securities; margin held in a segregated Special Clearing Account at a Federal Reserve Bank or an FDIC-insured bank; and a system for returning excess margin no longer required. The source of the margin is separately checked against Note H's three permitted sources, including the narrow path where a broker-dealer's own Treasury securities may be used only if the customer lacked sufficient margin of its own and the broker-dealer recouped the advance by the next business day. The verdict is INCLUDABLE, NOT_INCLUDABLE, or INDETERMINATE, and INDETERMINATE covers both an unstated condition and missing margin-required or margin-on-deposit figures, neither of which is guessed toward either other verdict. Where INCLUDABLE, the debit is the smaller of the margin required and the margin actually on deposit, since Note H permits a debit no larger than either figure. Money is fixed point in integer minor units throughout with two-decimal display. Cites Exchange Act Rule 15c3-3a Note H by subsection and the SEC's Treasury-clearing compliance dates (cash trades by 2026-12-31, repo by 2027-06-30), each dated for re-verification against primary text. This kernel is a narrow sibling to the shipped art-396 15c3-3 reserve-formula tool: it recomputes only the Note H margin-debit sliver, never the full Items 1-14 reserve formula, and never edits art-396. Not legal or regulatory advice, and whether a clearing agency's rules and Commission notice actually satisfy Note H is for the broker-dealer's own compliance and financial-operations review.", "input_schema_ref": "chaingraph/art-580-15c3-3a-note-h-margin-debit.html#manifest", "consumes": [], "feeds": [], "status": "live", "conformance_fixtures": true, "compute_capability": "server", "compute_images": [ { "system": "sha256-source", "image_id": "sha256:3bdfd9647ff94c830fe925048617e9528272a1bd33da7bc0a2a640e70563eea2", "valid_from": "2026-08-07" }, { "system": "risc0", "image_id": "sha256:a1a0bc89b5b1febaeda3519f6dbade0fa5ac16beeb143c4e1b01689573567bc6", "valid_from": "2026-08-07" } ], "export_capability": [ "json" ], "compute_proof_ready": "ready", "deferred_reason": "New shard; awaiting the async GPU proving queue (S18 steady-state).", "compute_proof": { "type": "ZkVmReceipt", "system": "risc0", "receiptFormat": "groth16-bn254", "imageId": "sha256:a1a0bc89b5b1febaeda3519f6dbade0fa5ac16beeb143c4e1b01689573567bc6", "seal": "JDJbyIePdMUogrjl2GkumgKRmjLByNBRPcpx3Vp5xGsJGkd/3N9AIWqSUwt+WBN+opo5UgU/d+9+bmisFLnRHgw/CNuI3Kzz+HhttbAK0wp7O7KV9qklqPtZ2QApX3nEE65gQiSax9qziZIhkH+u1TuhzLSdrwY+5BE6ZUcnQpcU7HzBBxslNlmg9H67NPSBgnyp3wuubzgR1fMvjLFSchFBoSWozm0+qRxgRFDZfxev1v+FBLGo7nLqush8T1R2KLCicam031M4qNWazDgY9AXLmdDDCX5ciitpbvgwSuMrbxZ7m3LS3HWnDbbhjX7cPzOTbrYTDdShmk4NyVZ9yg==", "journal": { "chaingraph_version": "0.4.0", "kernel_digest": "sha256:3bdfd9647ff94c830fe925048617e9528272a1bd33da7bc0a2a640e70563eea2", "output": { "broker_dealer_ref": "SYNTH-BD-001", "citations": { "note_h_b1": { "detail": "Permitted sources of the margin on deposit are: cash the customer delivered for that customer's own U.S. Treasury securities positions; that customer's own securities held in custody that qualify as \"qualified customer securities\" under the clearing agency's Note H rules; or, narrowly, the broker-dealer's own qualifying Treasury securities where the customer lacked sufficient margin, the clearing agency called for and received the margin, and the broker-dealer recouped the advance from the customer by the next business day. Re-verify against primary text before relying on it (research finding, not a fact).", "source": "Exchange Act Rule 15c3-3a, Note H(b)(1)" }, "note_h_b2i": { "detail": "The clearing agency's rules must require a SEPARATE margin requirement calculated for each customer of the broker-dealer, with the broker-dealer delivering that customer's margin to the clearing agency on a gross basis.", "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(i)" }, "note_h_b2ii": { "detail": "Cash on deposit as margin may be invested by the clearing agency only in short-term U.S. Treasury securities.", "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(ii)" }, "note_h_b2iii_iv": { "detail": "Margin must be held in a segregated Special Clearing Account for the exclusive benefit of customers, maintained at a Federal Reserve Bank or an FDIC-insured bank.", "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(iii)-(iv)" }, "note_h_b2v": { "detail": "The clearing agency's rules must provide a system for promptly returning excess margin that is no longer required.", "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(v)" }, "note_h_b3": { "detail": "The clearing agency's Note H rules must have Commission approval, and the Commission must have published notice that the conditions of Note H are satisfied with respect to that clearing agency, before a broker-dealer may include the Note H debit for that clearing agency.", "source": "Exchange Act Rule 15c3-3a, Note H(b)(3)" }, "treasury_clearing_compliance_dates": { "detail": "Central clearing of eligible U.S. Treasury cash trades is required by 2026-12-31 and of eligible repo transactions by 2027-06-30. Stated here as a dated fact, not a live countdown.", "source": "SEC Treasury-clearing adopting release and compliance-date extension (Federal Register, 2025 final rule and 2025-03-04 extension notice)" } }, "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "commission_notice_dated": "2024-11-25", "computation_date_label": "2026-08-07 weekly reserve computation", "conditions": [ { "citation_key": "note_h_b3", "key": "commission_notice_published", "label": "Commission has approved the clearing agency's Note H rules and published notice that Note H is satisfied for it", "satisfied": true }, { "citation_key": "note_h_b2i", "key": "per_customer_gross_margin_calc", "label": "Clearing agency calculates a separate, gross, per-customer margin requirement", "satisfied": true }, { "citation_key": "note_h_b2ii", "key": "cash_investment_short_term_treasuries_only", "label": "Cash margin is invested only in short-term U.S. Treasury securities", "satisfied": true }, { "citation_key": "note_h_b2iii_iv", "key": "special_clearing_account_designated", "label": "Margin held in a segregated Special Clearing Account at a Federal Reserve Bank or FDIC-insured bank", "satisfied": true }, { "citation_key": "note_h_b2v", "key": "excess_margin_return_system", "label": "Clearing agency has a system for returning excess margin no longer required", "satisfied": true } ], "currency": "USD", "debit_display": "5000000.00", "debit_minor_units": 500000000, "fence": "This is not legal or regulatory advice. This kernel recomputes only whether a margin debit qualifies for inclusion under Note H to Exchange Act Rule 15c3-3a and, if so, its amount -- it does not recompute Items 1-14 of the Rule 15c3-3a reserve formula (see the sibling art-396 15c3-3 reserve tool for that, an independent tool never edited by this one). Whether a clearing agency's rules and Commission notice actually satisfy Note H, and whether the declared facts are accurate, are for the broker-dealer's own compliance and financial-operations review.", "indeterminate_reason": null, "margin_on_deposit_display": "6500000.00", "margin_on_deposit_minor_units": 650000000, "margin_required_display": "5000000.00", "margin_required_minor_units": 500000000, "margin_source": "customer_cash", "minor_unit_exponent": 2, "not_proven": [ { "detail": "This kernel recomputes the Note H margin-debit condition checks and debit arithmetic from caller-declared facts. It is not a substitute for counsel, FINRA/SEC guidance, or the broker-dealer's own compliance and financial-operations review.", "item": "Not legal or regulatory advice" }, { "detail": "Whether the Commission has in fact published (and not since withdrawn) a Note H(b)(3) notice for the named clearing agency is a caller-declared fact, not independently verified against the Federal Register at run time -- this is an offline, zero-network tool.", "item": "Commission notice currency" }, { "detail": "This kernel computes only the Note H margin-debit sliver. It does not recompute Items 1-14 of the Rule 15c3-3a customer/PAB reserve formula -- see the sibling art-396 15c3-3 reserve tool for that, a separate and independent tool.", "item": "Full reserve formula not recomputed" }, { "detail": "The per-customer gross calculation, cash-investment restriction, Special Clearing Account designation, and excess-margin-return-system conditions are caller-declared facts about the named clearing agency's rules, not independently checked against that clearing agency's actual rulebook filings.", "item": "Clearing agency rulebook not verified" }, { "detail": "Margin-required and margin-on-deposit figures are caller-supplied and asserted, not independently verified against the clearing agency's own margin call or the broker-dealer's books and records.", "item": "Input accuracy" } ], "note": "Deterministic Note H margin-debit includability and amount recomputation for one stated computation date. Single-run and stateless: it holds no records, runs on no schedule, and retains nothing.", "rationale": [ "Note H margin-debit includability recomputed for broker-dealer reference SYNTH-BD-001 as of 2026-08-07 weekly reserve computation, clearing agency SYNTH-FICC-LIKE-CCA.", "Every declared Note H condition resolved TRUE and a margin_source was declared.", "Verdict is INCLUDABLE. The debit is MIN(margin required, margin on deposit) = 5000000.00 USD.", "This is not legal or regulatory advice, and this kernel recomputes only the Note H margin-debit sliver of the Rule 15c3-3a reserve formula, never the full formula (see the sibling art-396 15c3-3 reserve tool for that)." ], "rejected_inputs": [], "verdict": "INCLUDABLE" } } } }