{
  "tool_id": "art-396-compute-15c3-3-reserve",
  "inventory_version": "1.0.0",
  "authored_at": "2026-08-23",
  "authored_by": "AUTHORING-STANDARD-ADOPT-1",
  "cohort_role": "gapped — chosen because its ONLY pinned clause snapshot is a head-of-provision EXEMPTION list, which the enumeration audit named as the dominant silent-green vector. It is the cleanest available test of whether the convention finds a gap that every existing gate is green on.",
  "error_direction": "conservative_toward_no_finding",
  "error_direction_rationale": "⛔ THE HARMFUL DIRECTION, and it is not a close call. The node's cited clause is 17 CFR 240.15c3-3(k), which says the RULE DOES NOT APPLY to a broker-dealer meeting the listed conditions. compute() exercises none of the (k) branches, so an exempt broker-dealer receives a confident reserve-requirement figure it does not owe — and, worse, compute({}) returns deposit_sufficient:true with NO_DEPOSIT_REQUIRED_DEBITS_EXCEED_CREDITS on an EMPTY input, so a caller supplying nothing at all is told no deposit is required. Understatement of a required deposit misses the violation the rule exists to prevent.",
  "derived_from": [
    { "digest": "sha256:b59c85bda8a9837400e25f5d515b48e364b7232c01caff7fcdfd72cb8788e8a6", "clause_path": "(k)(1)-(3)" }
  ],
  "branches": [
    {
      "id": "art-15c3-3-reserve-formula",
      "clause": "17 CFR 240.15c3-3(e), Exhibit A",
      "branch": "The reserve computation itself — total credits less total debits, and the resulting deposit requirement.",
      "disposition": "represented",
      "evidence": "reserve_requirement_musd"
    },
    {
      "id": "art-15c3-3-deposit-sufficiency",
      "clause": "17 CFR 240.15c3-3(e)",
      "branch": "Whether the account balance meets the computed requirement.",
      "disposition": "represented",
      "evidence": "deposit_sufficient"
    },
    {
      "id": "art-15c3-3-pab-variant",
      "clause": "17 CFR 240.15c3-3(e)",
      "branch": "The PAB (proprietary accounts of broker-dealers) variant of the computation.",
      "disposition": "represented",
      "evidence": "pab_variant"
    },
    {
      "id": "art-15c3-3-k1-mutual-fund-and-insurance-separate-account-dealer",
      "clause": "17 CFR 240.15c3-3(k)(1)(i)-(iii)",
      "branch": "The section DOES NOT APPLY to a broker-dealer meeting ALL of: dealer transactions limited to redeemable investment-company securities or insurance separate-account interests; broker transactions limited to the three (k)(1)(ii)(a)-(c) activities; and prompt transmission of all funds and securities with no holding of, or owing to, customers.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_no_finding",
      "note": "⛔ FINDING. compute() has no input for any of the three conditions and no code path that reaches this exemption. A (k)(1) broker-dealer is handed a reserve requirement the rule says it does not owe."
    },
    {
      "id": "art-15c3-3-k1iv-insurance-company-carve-back",
      "clause": "17 CFR 240.15c3-3(k)(1)(iv)",
      "branch": "A CARVE-BACK on (k)(1): a registered broker-dealer insurance company does NOT get the exemption merely by participating in transactions that are part of the business of insurance. An exception to an exception.",
      "disposition": "unrepresented_known",
      "error_direction": "undirected",
      "note": "⛔ FINDING. Unrepresented in the same way as (k)(1), and worth listing separately because it is the branch a partial implementation is most likely to miss: an author who codes (k)(1)(i)-(iii) and stops has built an exemption WIDER than the rule. Direction is undirected because it cuts the opposite way to its parent."
    },
    {
      "id": "art-15c3-3-k2i-special-account-broker-dealer",
      "clause": "17 CFR 240.15c3-3(k)(2)(i)",
      "branch": "The section does not apply to a broker-dealer who carries no margin accounts, promptly transmits all customer funds and securities, holds nothing for and owes nothing to customers, and effects all financial transactions with customers through a designated Special Account for the Exclusive Benefit of Customers.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_no_finding",
      "note": "⛔ FINDING."
    },
    {
      "id": "art-15c3-3-k2ii-introducing-broker-fully-disclosed",
      "clause": "17 CFR 240.15c3-3(k)(2)(ii)",
      "branch": "The section does not apply to an introducing broker-dealer that clears all customer transactions on a fully disclosed basis with a clearing broker-dealer and promptly transmits all customer funds and securities to it.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_no_finding",
      "note": "⛔ FINDING, and the highest-volume one: (k)(2)(ii) is the exemption most introducing brokers rely on, so it is the branch a real caller is most likely to sit inside while receiving a confident reserve figure."
    },
    {
      "id": "art-15c3-3-k3-commission-granted-exemption",
      "clause": "17 CFR 240.15c3-3(k)(3)",
      "branch": "On written application the Commission may exempt a broker-dealer, unconditionally or on specified terms, where it finds comparable safeguards and no public-interest need.",
      "disposition": "unrepresented_known",
      "error_direction": "conservative_toward_no_finding",
      "note": "⛔ FINDING. A discretionary, order-based exemption. Unlike (k)(1)-(2) it cannot be inferred from facts at all — it is an external fact about a Commission order, so the only faithful representation is a declared caller input plus a refusal when it is absent. Neither exists."
    },
    {
      "id": "art-15c3-3-credit-and-debit-item-composition",
      "clause": "17 CFR 240.15c3-3 Exhibit A",
      "branch": "Which amounts are credit items and which are debit items in the formula.",
      "disposition": "out_of_scope_by_input",
      "assumption_of_use": {
        "value": "credit_items[] and debit_items[]",
        "source": "17 CFR 240.15c3-3 Exhibit A",
        "owner": "the CALLER, who classifies each amount. ⚠ Nothing here validates the classification, and compute({}) treats an ABSENT set as an EMPTY one — which is how an empty input becomes an affirmative 'no deposit required'."
      }
    }
  ]
}