{ "tool_id": "art-580-15c3-3a-note-h-margin-debit", "note": "Vectors computed directly from the shipped kernel. Every broker-dealer, clearing agency and figure here is SYNTHETIC and is not a copy of any real firm's reserve computation. Covers INCLUDABLE via customer_cash and via the narrow bd_treasuries_narrow path, NOT_INCLUDABLE on a false condition, and both INDETERMINATE finite-gate states (an unstated condition; missing amount).", "vectors": [ { "name": "includable-customer-cash-min-of-required-deposit", "description": "All five clearing-agency Note H conditions and the customer_cash margin source are declared true; margin on deposit exceeds margin required, so the debit is the smaller of the two: margin required.", "policy_parameters": { "broker_dealer_ref": "SYNTH-BD-001", "computation_date_label": "2026-08-07 weekly reserve computation", "currency": "USD", "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "clearing_agency_conditions": { "commission_notice_published": true, "commission_notice_dated": "2024-11-25", "per_customer_gross_margin_calc": true, "cash_investment_short_term_treasuries_only": true, "special_clearing_account_designated": true, "excess_margin_return_system": true }, "margin_source": "customer_cash", "margin_required_minor_units": 500000000, "margin_on_deposit_minor_units": 650000000 }, "output_payload": { "broker_dealer_ref": "SYNTH-BD-001", "computation_date_label": "2026-08-07 weekly reserve computation", "currency": "USD", "minor_unit_exponent": 2, "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "commission_notice_dated": "2024-11-25", "margin_source": "customer_cash", "margin_required_minor_units": 500000000, "margin_required_display": "5000000.00", "margin_on_deposit_minor_units": 650000000, "margin_on_deposit_display": "6500000.00", "conditions": [ { "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", "citation_key": "note_h_b3", "satisfied": true }, { "key": "per_customer_gross_margin_calc", "label": "Clearing agency calculates a separate, gross, per-customer margin requirement", "citation_key": "note_h_b2i", "satisfied": true }, { "key": "cash_investment_short_term_treasuries_only", "label": "Cash margin is invested only in short-term U.S. Treasury securities", "citation_key": "note_h_b2ii", "satisfied": true }, { "key": "special_clearing_account_designated", "label": "Margin held in a segregated Special Clearing Account at a Federal Reserve Bank or FDIC-insured bank", "citation_key": "note_h_b2iii_iv", "satisfied": true }, { "key": "excess_margin_return_system", "label": "Clearing agency has a system for returning excess margin no longer required", "citation_key": "note_h_b2v", "satisfied": true } ], "debit_minor_units": 500000000, "debit_display": "5000000.00", "verdict": "INCLUDABLE", "indeterminate_reason": null, "rejected_inputs": [], "citations": { "note_h_b1": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(1)", "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)." }, "note_h_b2i": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(i)", "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." }, "note_h_b2ii": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(ii)", "detail": "Cash on deposit as margin may be invested by the clearing agency only in short-term U.S. Treasury securities." }, "note_h_b2iii_iv": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(iii)-(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." }, "note_h_b2v": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(v)", "detail": "The clearing agency's rules must provide a system for promptly returning excess margin that is no longer required." }, "note_h_b3": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(3)", "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." }, "treasury_clearing_compliance_dates": { "source": "SEC Treasury-clearing adopting release and compliance-date extension (Federal Register, 2025 final rule and 2025-03-04 extension notice)", "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." } }, "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)." ], "not_proven": [ { "item": "Not legal or regulatory advice", "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": "Commission notice currency", "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": "Full reserve formula not recomputed", "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": "Clearing agency rulebook not verified", "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": "Input accuracy", "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." } ], "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.", "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." }, "golden_hash": "806c833196e231d4b96db0e2cf035c79195cdbb2f25959e5e5d252098d6146ed" }, { "name": "not-includable-condition-false", "description": "The per-customer gross margin calculation condition is declared FALSE (the clearing agency nets across customers), so the debit is NOT_INCLUDABLE regardless of the amounts on deposit.", "policy_parameters": { "broker_dealer_ref": "SYNTH-BD-002", "computation_date_label": "2026-08-14 weekly reserve computation", "currency": "USD", "clearing_agency_name": "SYNTH-NETTING-CCA", "clearing_agency_conditions": { "commission_notice_published": true, "commission_notice_dated": "2024-11-25", "per_customer_gross_margin_calc": false, "cash_investment_short_term_treasuries_only": true, "special_clearing_account_designated": true, "excess_margin_return_system": true }, "margin_source": "customer_securities_custody", "margin_required_minor_units": 300000000, "margin_on_deposit_minor_units": 300000000 }, "output_payload": { "broker_dealer_ref": "SYNTH-BD-002", "computation_date_label": "2026-08-14 weekly reserve computation", "currency": "USD", "minor_unit_exponent": 2, "clearing_agency_name": "SYNTH-NETTING-CCA", "commission_notice_dated": "2024-11-25", "margin_source": "customer_securities_custody", "margin_required_minor_units": 300000000, "margin_required_display": "3000000.00", "margin_on_deposit_minor_units": 300000000, "margin_on_deposit_display": "3000000.00", "conditions": [ { "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", "citation_key": "note_h_b3", "satisfied": true }, { "key": "per_customer_gross_margin_calc", "label": "Clearing agency calculates a separate, gross, per-customer margin requirement", "citation_key": "note_h_b2i", "satisfied": false }, { "key": "cash_investment_short_term_treasuries_only", "label": "Cash margin is invested only in short-term U.S. Treasury securities", "citation_key": "note_h_b2ii", "satisfied": true }, { "key": "special_clearing_account_designated", "label": "Margin held in a segregated Special Clearing Account at a Federal Reserve Bank or FDIC-insured bank", "citation_key": "note_h_b2iii_iv", "satisfied": true }, { "key": "excess_margin_return_system", "label": "Clearing agency has a system for returning excess margin no longer required", "citation_key": "note_h_b2v", "satisfied": true } ], "debit_minor_units": 0, "debit_display": "0.00", "verdict": "NOT_INCLUDABLE", "indeterminate_reason": null, "rejected_inputs": [], "citations": { "note_h_b1": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(1)", "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)." }, "note_h_b2i": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(i)", "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." }, "note_h_b2ii": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(ii)", "detail": "Cash on deposit as margin may be invested by the clearing agency only in short-term U.S. Treasury securities." }, "note_h_b2iii_iv": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(iii)-(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." }, "note_h_b2v": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(v)", "detail": "The clearing agency's rules must provide a system for promptly returning excess margin that is no longer required." }, "note_h_b3": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(3)", "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." }, "treasury_clearing_compliance_dates": { "source": "SEC Treasury-clearing adopting release and compliance-date extension (Federal Register, 2025 final rule and 2025-03-04 extension notice)", "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." } }, "rationale": [ "Note H margin-debit includability recomputed for broker-dealer reference SYNTH-BD-002 as of 2026-08-14 weekly reserve computation, clearing agency SYNTH-NETTING-CCA.", "1 Note H condition is declared FALSE: per_customer_gross_margin_calc.", "Verdict is NOT_INCLUDABLE: at least one Note H condition failed, so no Note H debit may be included in the reserve formula for this margin.", "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)." ], "not_proven": [ { "item": "Not legal or regulatory advice", "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": "Commission notice currency", "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": "Full reserve formula not recomputed", "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": "Clearing agency rulebook not verified", "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": "Input accuracy", "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." } ], "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.", "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." }, "golden_hash": "64f8ce4a29e1f658dd783784ed190e2c742231df7915b5c5d9bed619b6f037d2" }, { "name": "indeterminate-condition-unstated", "description": "The Commission-notice-published condition is left unstated (neither true nor false declared). Verdict is INDETERMINATE, never guessed toward INCLUDABLE or NOT_INCLUDABLE.", "policy_parameters": { "broker_dealer_ref": "SYNTH-BD-003", "computation_date_label": "2026-08-21 weekly reserve computation", "currency": "USD", "clearing_agency_name": "SYNTH-NEW-ENTRANT-CCA", "clearing_agency_conditions": { "per_customer_gross_margin_calc": true, "cash_investment_short_term_treasuries_only": true, "special_clearing_account_designated": true, "excess_margin_return_system": true }, "margin_source": "customer_cash", "margin_required_minor_units": 100000000, "margin_on_deposit_minor_units": 120000000 }, "output_payload": { "broker_dealer_ref": "SYNTH-BD-003", "computation_date_label": "2026-08-21 weekly reserve computation", "currency": "USD", "minor_unit_exponent": 2, "clearing_agency_name": "SYNTH-NEW-ENTRANT-CCA", "commission_notice_dated": null, "margin_source": "customer_cash", "margin_required_minor_units": 100000000, "margin_required_display": "1000000.00", "margin_on_deposit_minor_units": 120000000, "margin_on_deposit_display": "1200000.00", "conditions": [ { "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", "citation_key": "note_h_b3", "satisfied": null }, { "key": "per_customer_gross_margin_calc", "label": "Clearing agency calculates a separate, gross, per-customer margin requirement", "citation_key": "note_h_b2i", "satisfied": true }, { "key": "cash_investment_short_term_treasuries_only", "label": "Cash margin is invested only in short-term U.S. Treasury securities", "citation_key": "note_h_b2ii", "satisfied": true }, { "key": "special_clearing_account_designated", "label": "Margin held in a segregated Special Clearing Account at a Federal Reserve Bank or FDIC-insured bank", "citation_key": "note_h_b2iii_iv", "satisfied": true }, { "key": "excess_margin_return_system", "label": "Clearing agency has a system for returning excess margin no longer required", "citation_key": "note_h_b2v", "satisfied": true } ], "debit_minor_units": 0, "debit_display": "0.00", "verdict": "INDETERMINATE", "indeterminate_reason": "At least one Note H condition (or the margin_source itself) was not declared true or false, so includability cannot be decided.", "rejected_inputs": [], "citations": { "note_h_b1": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(1)", "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)." }, "note_h_b2i": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(i)", "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." }, "note_h_b2ii": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(ii)", "detail": "Cash on deposit as margin may be invested by the clearing agency only in short-term U.S. Treasury securities." }, "note_h_b2iii_iv": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(iii)-(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." }, "note_h_b2v": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(v)", "detail": "The clearing agency's rules must provide a system for promptly returning excess margin that is no longer required." }, "note_h_b3": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(3)", "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." }, "treasury_clearing_compliance_dates": { "source": "SEC Treasury-clearing adopting release and compliance-date extension (Federal Register, 2025 final rule and 2025-03-04 extension notice)", "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." } }, "rationale": [ "Note H margin-debit includability recomputed for broker-dealer reference SYNTH-BD-003 as of 2026-08-21 weekly reserve computation, clearing agency SYNTH-NEW-ENTRANT-CCA.", "1 condition was not declared true or false: commission_notice_published.", "Verdict is INDETERMINATE: At least one Note H condition (or the margin_source itself) was not declared true or false, so includability cannot be decided.", "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)." ], "not_proven": [ { "item": "Not legal or regulatory advice", "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": "Commission notice currency", "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": "Full reserve formula not recomputed", "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": "Clearing agency rulebook not verified", "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": "Input accuracy", "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." } ], "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.", "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." }, "golden_hash": "28cfcdf745fd627b383fe109bd897afc4a2c6837e5d6ef2a4f59b94ac708376a" }, { "name": "includable-bd-treasuries-narrow-path-min-of-deposit", "description": "The narrow bd_treasuries_narrow margin source is used; both its sub-conditions (customer lacked sufficient assets, margin recouped by next business day) are declared true alongside every clearing-agency condition. Margin on deposit is smaller than margin required, so the debit is capped at margin on deposit.", "policy_parameters": { "broker_dealer_ref": "SYNTH-BD-004", "computation_date_label": "2026-08-28 weekly reserve computation", "currency": "USD", "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "clearing_agency_conditions": { "commission_notice_published": true, "commission_notice_dated": "2024-11-25", "per_customer_gross_margin_calc": true, "cash_investment_short_term_treasuries_only": true, "special_clearing_account_designated": true, "excess_margin_return_system": true }, "margin_source": "bd_treasuries_narrow", "customer_insufficient_assets_declared": true, "margin_called_and_received_next_business_day": true, "margin_required_minor_units": 750000000, "margin_on_deposit_minor_units": 600000000 }, "output_payload": { "broker_dealer_ref": "SYNTH-BD-004", "computation_date_label": "2026-08-28 weekly reserve computation", "currency": "USD", "minor_unit_exponent": 2, "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "commission_notice_dated": "2024-11-25", "margin_source": "bd_treasuries_narrow", "margin_required_minor_units": 750000000, "margin_required_display": "7500000.00", "margin_on_deposit_minor_units": 600000000, "margin_on_deposit_display": "6000000.00", "conditions": [ { "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", "citation_key": "note_h_b3", "satisfied": true }, { "key": "per_customer_gross_margin_calc", "label": "Clearing agency calculates a separate, gross, per-customer margin requirement", "citation_key": "note_h_b2i", "satisfied": true }, { "key": "cash_investment_short_term_treasuries_only", "label": "Cash margin is invested only in short-term U.S. Treasury securities", "citation_key": "note_h_b2ii", "satisfied": true }, { "key": "special_clearing_account_designated", "label": "Margin held in a segregated Special Clearing Account at a Federal Reserve Bank or FDIC-insured bank", "citation_key": "note_h_b2iii_iv", "satisfied": true }, { "key": "excess_margin_return_system", "label": "Clearing agency has a system for returning excess margin no longer required", "citation_key": "note_h_b2v", "satisfied": true }, { "key": "customer_insufficient_assets_declared", "label": "Customer did not have sufficient margin of its own (narrow bd_treasuries_narrow path)", "citation_key": "note_h_b1", "satisfied": true }, { "key": "margin_called_and_received_next_business_day", "label": "Broker-dealer recouped the advanced margin from the customer by the next business day (narrow bd_treasuries_narrow path)", "citation_key": "note_h_b1", "satisfied": true } ], "debit_minor_units": 600000000, "debit_display": "6000000.00", "verdict": "INCLUDABLE", "indeterminate_reason": null, "rejected_inputs": [], "citations": { "note_h_b1": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(1)", "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)." }, "note_h_b2i": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(i)", "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." }, "note_h_b2ii": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(ii)", "detail": "Cash on deposit as margin may be invested by the clearing agency only in short-term U.S. Treasury securities." }, "note_h_b2iii_iv": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(iii)-(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." }, "note_h_b2v": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(v)", "detail": "The clearing agency's rules must provide a system for promptly returning excess margin that is no longer required." }, "note_h_b3": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(3)", "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." }, "treasury_clearing_compliance_dates": { "source": "SEC Treasury-clearing adopting release and compliance-date extension (Federal Register, 2025 final rule and 2025-03-04 extension notice)", "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." } }, "rationale": [ "Note H margin-debit includability recomputed for broker-dealer reference SYNTH-BD-004 as of 2026-08-28 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) = 6000000.00 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)." ], "not_proven": [ { "item": "Not legal or regulatory advice", "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": "Commission notice currency", "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": "Full reserve formula not recomputed", "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": "Clearing agency rulebook not verified", "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": "Input accuracy", "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." } ], "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.", "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." }, "golden_hash": "1372d84881d31b17823598084d6f7af4bd1f1bda9392b15614e3ded40451a6f2" }, { "name": "indeterminate-amounts-missing", "description": "Every Note H condition is declared true, but margin_on_deposit_minor_units is absent, so no debit can be computed. Verdict is INDETERMINATE, and the missing input is named in rejected_inputs.", "policy_parameters": { "broker_dealer_ref": "SYNTH-BD-005", "computation_date_label": "2026-09-04 weekly reserve computation", "currency": "USD", "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "clearing_agency_conditions": { "commission_notice_published": true, "commission_notice_dated": "2024-11-25", "per_customer_gross_margin_calc": true, "cash_investment_short_term_treasuries_only": true, "special_clearing_account_designated": true, "excess_margin_return_system": true }, "margin_source": "customer_cash", "margin_required_minor_units": 200000000 }, "output_payload": { "broker_dealer_ref": "SYNTH-BD-005", "computation_date_label": "2026-09-04 weekly reserve computation", "currency": "USD", "minor_unit_exponent": 2, "clearing_agency_name": "SYNTH-FICC-LIKE-CCA", "commission_notice_dated": "2024-11-25", "margin_source": "customer_cash", "margin_required_minor_units": 200000000, "margin_required_display": "2000000.00", "margin_on_deposit_minor_units": null, "margin_on_deposit_display": null, "conditions": [ { "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", "citation_key": "note_h_b3", "satisfied": true }, { "key": "per_customer_gross_margin_calc", "label": "Clearing agency calculates a separate, gross, per-customer margin requirement", "citation_key": "note_h_b2i", "satisfied": true }, { "key": "cash_investment_short_term_treasuries_only", "label": "Cash margin is invested only in short-term U.S. Treasury securities", "citation_key": "note_h_b2ii", "satisfied": true }, { "key": "special_clearing_account_designated", "label": "Margin held in a segregated Special Clearing Account at a Federal Reserve Bank or FDIC-insured bank", "citation_key": "note_h_b2iii_iv", "satisfied": true }, { "key": "excess_margin_return_system", "label": "Clearing agency has a system for returning excess margin no longer required", "citation_key": "note_h_b2v", "satisfied": true } ], "debit_minor_units": 0, "debit_display": "0.00", "verdict": "INDETERMINATE", "indeterminate_reason": "margin_required_minor_units and/or margin_on_deposit_minor_units were not supplied, so no debit could be computed.", "rejected_inputs": [ { "where": "margin_on_deposit_minor_units", "reason": "absent", "supplied": null } ], "citations": { "note_h_b1": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(1)", "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)." }, "note_h_b2i": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(i)", "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." }, "note_h_b2ii": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(ii)", "detail": "Cash on deposit as margin may be invested by the clearing agency only in short-term U.S. Treasury securities." }, "note_h_b2iii_iv": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(iii)-(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." }, "note_h_b2v": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(2)(v)", "detail": "The clearing agency's rules must provide a system for promptly returning excess margin that is no longer required." }, "note_h_b3": { "source": "Exchange Act Rule 15c3-3a, Note H(b)(3)", "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." }, "treasury_clearing_compliance_dates": { "source": "SEC Treasury-clearing adopting release and compliance-date extension (Federal Register, 2025 final rule and 2025-03-04 extension notice)", "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." } }, "rationale": [ "Note H margin-debit includability recomputed for broker-dealer reference SYNTH-BD-005 as of 2026-09-04 weekly reserve computation, clearing agency SYNTH-FICC-LIKE-CCA.", "Verdict is INDETERMINATE: margin_required_minor_units and/or margin_on_deposit_minor_units were not supplied, so no debit could be computed.", "1 supplied value was not usable and was treated as absent. Each one is named in rejected_inputs rather than silently dropped.", "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)." ], "not_proven": [ { "item": "Not legal or regulatory advice", "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": "Commission notice currency", "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": "Full reserve formula not recomputed", "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": "Clearing agency rulebook not verified", "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": "Input accuracy", "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." } ], "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.", "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." }, "golden_hash": "91f02562048752cfb7f7ac3da47b1b101ba68bc8650e1179f9086dc0fdc2086c" } ] }