Margin Requirements - 2001 Letters

July 12, 2001
To Mr. Kevin Keogh concerning whether the proposed admission of a new class of members to a registered broker-dealer poses a violation of Regulation T (12 CFR 220). Based on the facts and circumstances, Board staff believes that the proposed members of the firm would not be customers of the broker-dealer, as defined in section 220.2, and the trading accounts managed by individual members would not be joint ventures between the broker-dealer and its customers, which would be subject to section 220.4(b)(6) of Regulation T.

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Last Update: March 06, 2017