August 12, 2020

Volume X, Number 225

August 11, 2020

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August 10, 2020

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SEC Raises Filing Threshold of Rule 17h Reporting Requirements for Broker-Dealers

On June 29, the Securities and Exchange Commission issued an order raising the filing threshold for broker-dealers’ Form 17-H filings made pursuant to the Securities Exchange Act of 1934 Rules 17h-1T and Rule 17h-2T. The updated threshold will exempt broker-dealers that (1) do not hold funds or securities for, or owe money or securities to, customers and do not carry customer accounts, or (2) are exempt from Rule 15c3-3 pursuant to paragraph (k)(2) of that rule and that maintain total assets of less than $1 billion and capital, including debt subordinated in accordance with appendix D of Rule 15c3-1 under the Securities Exchange Act of 1934 of less than $50 million.

The press release is available here.

The SEC Order is available here.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume X, Number 192


About this Author

Susan Light, Katten Law Firm, Finance Law Attorney, New York

Susan Light focuses her practice on financial services regulatory matters. She counsels broker-dealers, hedge funds, investment banks and financial services clients on enforcement issues involving the Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), other self-regulatory organizations (SROs) and state and federal regulatory authorities. She has particular experience related to sales practice issues, financial and operational issues, anti-money laundering, crowdfunding, cybersecurity, and cryptocurrencies.

Michael T. Foley, Katten, Lawyer, Finance, FINRA, Chicago
Special Counsel

Michael Foley represents broker-dealers, investment advisers and other financial services industry participants with respect to a broad spectrum of legal and regulatory matters arising under the federal securities laws.

Michael has nearly 20 years of experience in private practice and in-house at both a large, full-service broker-dealer and at an online discount broker-dealer, advising broker-dealers and other financial institutions regarding compliance with the federal securities and commodities laws, and with the regulations of the US Securities and Exchange Commission, the US Commodity Futures Trading Commission and financial industry self-regulatory organizations. 

Jack West Financial Attorney Katten

Jack West is an associate in the Financial Markets and Funds practice.