Regulatory Notice 23-04

The Financial Industry Regulatory Authority (FINRA) has published a Regulatory Notice (23-4) to provide guidance to member firms as regards the treatment of deposits at the Silicon Valley Bank (SVB) and Signature Bank for purposes of meeting own funds and custody requirements and the withdrawal of funds from accounts held with the institutions. Specifically, FINRA states the following – as quoted:
>- All bank deposits at SVB and Signature may continue to be treated as allowable assets for net capital purposes.
>- Balances in Customer and PAB [Proprietary Accounts of Broker-Dealers] Reserve Bank Accounts at SVB and Signature may continue to be treated as qualified reserve bank account deposits for purposes of SEA Rule 15c3-3(e).
>- Any withdrawals of funds from accounts held at SVB and Signature must comply with the requirements of all applicable rules, e.g., SEA Rule 15c3-1(e) and SEA Rule 15c3-3(e)(1).