Extensions of Time Filing Schedule
Overview
FINRA Rule 4230(a) requires clearing firms for which FINRA is the designated examining authority pursuant to SEA Rule 17d-1 to submit requests for extensions of time as contemplated by Regulation T of the Board of Governors of the Federal Reserve System1 ("Regulation T") and SEA Rule 15c3-3(n)2 to FINRA for approval. Firms are also required to file with FINRA their request for extensions of time to satisfy margin deficiencies pursuant to FINRA Rule 4210.3 FINRA has implemented an automated system for the receipt and processing of such extension of time requests (the REX system). When incorrect dates are submitted in connection with an extension request, the REX system may deny the request, resulting in firms having to resubmit the request with corrected dates. To assist firms in determining the correct filing dates around holidays, FINRA is providing the schedule below. Firms should use the dates noted in this schedule when requesting extensions of time on dates prior to and after any holiday during which exchanges or banks are closed. Additionally, please download the full extension calendar, covering all business days (not only the holidays) for extensions related to Regulation T, SEA Rule 15c3-3(m), FINRA Rule 4210(f)(6), (g)(10)(D), and FINRA Rule 4210(e)(2)(H)(ii)d.3.
Filing Schedule
When incorrect dates are submitted in connection with an extension request, the REX system may deny the request, resulting in firms having to resubmit the request with corrected dates. To assist firms in determining the correct filing dates for extension requests, FINRA has made available for download a Filing Schedule covering all business days and holidays for extensions in 2025. The Filing Schedule relates to all extensions in 2025 in connection with the rule provisions in the following chart:
Rule | Extension Due Date |
|---|---|
| Regulation T | On the 3rd business day after the trade date. |
| SEA Rule 15c3-3(m) | On the 10th business day after settlement date. |
| FINRA Rule 4210(f)(6) | On the 15th business day after the date the margin or mark to market deficiency occurs.z |
| FINRA Rule 4210(g)(10)(D) | On the 4th business day after the date the margin deficiency occurs. |
FINRA Rule 4210(e)(2)(H)(ii)d.3. (For a threshold deficiency) | On the 5th business day that the firm exceeds 25% of TNC/$30 MM threshold and the counterparty has an existing excess mark to market deficiency. |
FINRA Rule 4210(e)(2)(H)(ii)d.3. (For a counterparty deficiency) | On the 6th business day from the date the excess net mark to market deficiency occurs. |
Please note that the Filing Schedule does not cover filing dates for Regulation T extensions in connection with “DK” trades and fails and SEA Rules 15c3-3(d)(2), 15c3-3(d)(3), 15c3-3(d)(4) and 15c3-3(h). For additional information on filing extensions related to these rules and situations, please see our guidance for Extension Reason Codes.
To use the Filing Schedule correctly, the user needs to have:
- The rule provision under which the extension of time request is being filed; and
- The trade date or settlement date of the transaction, or the deficiency date.
Holiday Calendar
Holiday calendar for Regulation T extension requests for the 4th quarter of 2024 and 2025.
The securities exchanges are generally open for trading on Columbus Day and Veterans Day, which are considered a business day under Regulation T of the Federal Reserve Board, SEA Rule 15c3-3 and FINRA Rule 4210(f)(6) and (g)(10)(D). However, Columbus Day and Veterans Day are not settlement dates because banking institutions will be closed on these days and extension filings for FINRA Rule 4210(e)(2)(H)(ii)d.3. is not required.
Securities Exchanges and Settlement Holidays* | Holiday Date | Extension Filing Day (All types except Covered Agency Transactions) | Extension Filing Day (Covered Agency Transactions Only) |
|---|---|---|---|
| Veterans Day* | 11/11/2024 | Yes | No |
| Thanksgiving | 11/28/2024 | No | No |
| Christmas Day | 12/25/2024 | No | No |
| New Year's Day | 1/1/2025 | No | No |
| Martin Luther King, Jr. Day | 1/20/2025 | No | No |
| President's Day | 2/17/2025 | No | No |
| Good Friday | 4/18/2025 | No | No |
| Memorial Day | 5/26/2025 | No | No |
| Juneteenth | 6/19/2025 | No | No |
| Independence Day | 7/4/2025 | No | No |
| Labor Day | 9/1/2025 | No | No |
| Columbus Day* | 10/13/2025 | Yes | No |
| Veterans Day* | 11/11/2025 | Yes | No |
| Thanksgiving | 11/27/2025 | No | No |
| Christmas Day | 12/25/2025 | No | No |
| New Year's Day | 1/1/2026 | No | No |
| Martin Luther King, Jr. Day | 1/19/2026 | No | No |
| *Bank holiday only, securities exchanges open, no settlement | |||
Unexpected Close of Securities Markets
Federal Reserve Board Regulation T (Extensions of Time)
- Margin extensions due on “the day of closure” may be filed either on “the day of closure” or on the next business day (as of “the day of closure”). If an extension is filed on the next business day, FINRA staff will work with firms to ensure extensions are appropriately processed. All follow-on extensions required to be filed after “the day of closure” should be filed on the normal due date, counting “the day of closure” as a business day. However, if the extension has expired or is denied, “the day of closure” should be treated as a non-business day, and securities should be liquidated when the market where the securities are traded is reopened.
FINRA Rule 4210(e)(2)(H)(ii)d.3., (f)(6), (g)(10)(D) (Margin Deficiencies)
- “The day of closure” should be counted as a regular business day for purposes of aging uncollected margin calls. Extensions of time due on “the day of closure” may be filed either on “the day of closure” or on the next business day (as of “the day of closure”). If an extension is filed on the next business day, FINRA staff will work with firms to ensure extensions are appropriately processed. All follow-on extensions required to be filed after “the day of closure” should be filed on the normal due date, counting “the day of closure” as a business day. However, if the extension has expired or is denied, “the day of closure” should be treated as a non-business day, and securities should be liquidated when the market where the securities are traded is reopened.
Exchange Act Rules 15c3-3(d), (h) and (m) (Extensions of Time)
- Extensions on customers’ sell orders under Exchange Act Rules 15c3-3(d), (h) and (m) due on “the day of closure” may be filed either on “the day of closure” or on the next business day (as of “the day of closure”). If an extension is filed on the next business day, FINRA staff will work with firms to ensure extensions are appropriately processed. All follow-on extensions required to be filed after “the day of closure” should be filed on the normal due date, counting “the day of closure” as a business day. However, if the extension has expired or is denied, “the day of closure” should be treated as a non-business day, and securities should be purchased when the market where the securities are traded is reopened.
Endnotes
1 As specified in Sections 220.4(d) and 220.8(b)(4) of Regulation T of the Federal Reserve Board, a broker-dealer must promptly cancel or otherwise liquidate a customer purchase transaction in a margin account or cash account if payment is not received within one payment period from the date of purchase or, pursuant to Section 220.4(c)(3) and 220.8(d)(1), apply to extend the time period specified. A payment period is defined in Regulation T to mean the number of business days in the standard securities settlement cycle in the United States, as defined in paragraph (a) of SEA Rule 15c6–1 (17 CFR 240.15c6–1(a)), plus two business days. The date by which firms must take action for “regular way” transactions effected on dates prior to and after a holiday when exchanges are closed is shown in the table under the column “Regulation T Extension Due Date.”
All SEA Rule 15c3-3 extension requests must be received on the due dates listed below.
(d)(2) – on the 30th calendar day after settlement date
(d)(3) – on the 45th calendar day after settlement date
(d)(4) – on the 2nd business day after the 30th calendar day from the date the segregation deficit occurred
(h) – on the 45th calendar day after settlement date
(m) – on the 10th business day after settlement date
These dates also apply to any securities traded on a foreign exchange. Firms must file SEA Rule 15c3-3 extensions on the appropriate dates regardless of the settlement cycle established by the foreign security market on which the security is traded.
2 SEA Rule15c3-3 requires firms to take prompt steps to obtain possession or control of securities pursuant to paragraph (m) through a buy-in procedure or otherwise, if securities are not received within ten business days from the settlement date of the sale, or, pursuant to paragraph (n), apply to extend the time period specified therein. The date by which firms must take such action for “regular way” transactions effected on dates prior to and after a holiday when exchanges are closed is shown in the table under the column “SEA Rule 15c3-3(m) Extension Due Date.”
3 See FINRA Rule 4210(f)(6), (g)(10)(D). and, effective on May 22, 2024, FINRA Rule 4210(e)(2)(H)(ii)d.3.