2025 Extensions of Time Filing Schedule
Summary
FINRA is making available on the FINRA website the Filing Schedule in connection with requests for Federal Reserve Board Regulation T, SEA Rule 15c3-3 and FINRA Rule 4210 extensions of time throughout 2025, including holidays. This information will assist firms with making accurate submissions in connection with filing requests of extensions of time throughout the year, including prior to and after a holiday when the exchanges or banks are closed in 2025.
Questions regarding this Notice may be directed to Theresa Reynolds, Senior Credit Regulation Coordinator at (646) 315-8567 or email.
Background
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 throughout the year, including around holidays observed in 2025, FINRA is providing on the FINRA website a Filing Schedule covering all business days and holidays for extensions in 2025. Firms should use the dates noted in the Filing Schedule when requesting extensions of time in 2025, especially on dates prior to and after any holiday during which exchanges or banks are closed in 2025.
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.
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.
3 See FINRA Rules 4210(f)(6), 4210(g)(10)(D), and 4210(e)(2)(H)(ii)d.3.