Broker-Dealer Operations

15c3-3 customer reserve and TRACE/CAT reporting, chained together

For broker-dealer operations and compliance teams who need a reserve-formula computation and a trade-reporting timeliness check that both attest their arithmetic against caller-supplied inputs, and want to see how the pieces fit alongside the rest of AINumbers' securities compliance tools.

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Scope. This pack covers two provable ChainGraph nodes: the SEC Rule 15c3-3 Exhibit A customer reserve formula, and a FINRA Rule 6730 TRACE timeliness lint paired with a CAT equity/option event structural check. Both are simplified over a representative subset of their respective rule texts and neither audits the source of the figures supplied -- see each tool's own scope note for exactly what it does and does not attest.

15c3-3 Customer Reserve Formula Calculator

Exhibit A credit items against allowable debit items (margin-account haircut, failed-to-deliver aging exclusion) to a reserve requirement and deposit-sufficiency verdict, with a PAB variant flag.

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TRACE / CAT Reporting Lint

TRACE trade-report timeliness against a caller-declared trading calendar, plus a CAT equity/option event structural format-lint.

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Why these two belong in one chain

A broker-dealer's weekly 15c3-3 reserve computation and its day-to-day TRACE/CAT trade reporting are run by different desks on different cadences, but they describe the same operational reality: whether the firm is meeting its baseline regulatory obligations for a given reporting period. Chaining the reserve calculator's verdict into the reporting-lint's context gives a single hash-anchored record that both figures were computed for the same period, without either tool needing to know anything about the other's internal rule logic.

How the two tools fit together

  1. Compute the reserve requirement with the 15c3-3 Customer Reserve Formula Calculator, supplying the period's credit and debit line items and the reserve account balance. The tool applies the Exhibit A aging exclusion to failed-to-deliver debits older than 30 days and the 1% collateral haircut to margin-account debits, then reports the requirement, the surplus or shortfall against the deposited balance, and a deposit-sufficiency verdict.
  2. Lint the period's TRACE and CAT reporting with the TRACE / CAT Reporting Lint, supplying the execution and report timestamps, the firm's declared trading calendar (weekend days and holidays -- there is no built-in market calendar), and a representative CAT equity or option event. The tool computes the FINRA Rule 6730 reporting deadline with weekend/holiday-aware rollover and reports a timely/late verdict, alongside a structural pass/fail on the CAT event's required fields.
What this chain proves, and what it never proves. The chain attests that both computations ran over the inputs as supplied, hash-anchored so the pairing can't be silently edited after the fact. It does not attest that the supplied credit/debit line items or trade timestamps are accurate, does not audit their source records, and is not a determination of regulatory compliance. The CAT lint checks a representative subset of required event fields, not the full CAT NMS Plan Reporting Technical Specification. This workflow processes zero PII: only line-item labels, dollar figures, and timestamps are consumed.

Family linkage

This pack is the first broker-dealer operations entry in AINumbers' securities compliance family, alongside the existing US Wealth & Advisory — Reg BI Suitability chain, which covers portfolio-level suitability and Form CRS disclosure. Where Reg BI Suitability addresses what a firm owes an individual customer at the point of recommendation, this pack addresses the firm's own reserve and reporting obligations as an operating broker-dealer -- the two chains cover distinct stages of the same regulatory surface and are meant to be read together for a fuller picture of broker-dealer compliance coverage on AINumbers.