OTC Derivatives Dealers

Summary

SEC rules provide for alternative regulatory scheme

OTC derivatives dealers are treated as a special class of broker-dealers, per 1998 SEC rule changes
Exempt from specified broker-dealer requirements:

Rule 3b-12 OTC Derivatives Dealer - Defined

Rule 15a-1 Limitations on securities activities

Rule 15b9-2 Exempt from SRO membership

Rule 15c3-1(a)(5) Alternative net capital treatment

Rule 15c3-4 Internal risk management controls

Rule 17a-3(a)(10) Recordkeeping obligations

Rule 17a-12 Reporting responsibilities

Rule 36a1-1 Exempt from broker-dealer margin rules

Rule 36a1-2 Exempt from SIPA

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