The FINRA 2017 Holiday Schedule has been released for trade dates, settlement dates, and margin extensions in 2017. Broker-dealers and municipal securities dealers should consult the schedule when requesting extensions of time for “regular way” transactions effected on dates before and after a holiday when the exchanges are closed. FINRA hopes this schedule will reduce the number of requests for Federal Reserve Board Regulation T and Securities Exchange Act (SEA) Rule 15c3-3 extensions that are denied around holidays due to incorrect due dates specified when the requests are made.
Pursuant to 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 of the date of purchase – or, pursuant to Sections 220.4(c) and 220.8(d)(1), the broker-dealer must apply to extend the time period specified. In the 2017 schedule below, the date by which firms must take such actions for “regular way” transactions effected on dates before and after a holiday when the exchange is closed is shown in the column titled “Regulation T Date”.
SEA Rule 15c3-3 requires that firms take prompt steps to obtain possession or control of securities pursuant to paragraph (m) through a buy-in procedure. Otherwise, pursuant to paragraph (n), if securities are not received within ten business days of the settlement date of the sale, firms must apply to extend the time period specified therein.
All extension requests for SEA Rule 15c3-3 must be received by the due dates listed below. These dates also apply to any securities traded on a foreign exchange. SEA Rule 15c3-3 extensions must be filed on the appropriate dates, regardless of the settlement cycle established by the foreign exchange on which the security is traded.
| SEA Rule 15C3-3 Subparagraph | Date Due |
| (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 |
In the 2017 schedule below, the date by which firms must take such actions for “regular way” transactions effected on dates before and after a holiday when the exchange is closed is shown in the column titled “SEA Rule 15c3-3(m) Extension Date”.
2017 Holiday Trade Date, Settlement Date, and Margin Extensions Schedule
New Year’s Day
Monday, January 2, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Dec 23 | Dec 29 | Jan 3 | Jan 13 |
| 26 (Markets Closed) | N/A | N/A | N/A |
| 27 | 30 | 4 | 17 |
| 28 | Jan 2 | 5 | 18 |
| 29 | 4 | 6 | 19 |
| 4 | 6 | 19 | 30 |
| 6 | 19 | 30 | 5 |
| 19 | 30 | 5 | 9 |
| 30 | 5 | 9 | 20 |
| Jan 2 (Markets Closed) | N/A | N/A | N/A |
| 3 | 6 | 10 | 23 |
Martin Luther King, Jr. Day
Monday, January 16, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Jan 9 | Jan 12 | Jan 17 | Jan 27 |
| 10 | 13 | 18 | 30 |
| 11 | 17 | 19 | 31 |
| 12 | 18 | 20 | Feb 1 |
| 13 | 19 | 23 | 2 |
| 16 (Markets Closed) | N/A | N/A | N/A |
| 17 | 20 | 24 | 3 |
Presidents’ Day
Monday, February 20, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Feb 13 | Feb 16 | Feb 21 | Mar 3 |
| 14 | 17 | 22 | 6 |
| 15 | 21 | 23 | 7 |
| 16 | 22 | 24 | 8 |
| 17 | 23 | 27 | 9 |
| 20 (Markets Closed) | N/A | N/A | N/A |
| 21 | 24 | 28 | 10 |
Good Friday
Friday, April 14, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Apr 7 | Apr 12 | Apr 18 | Apr 26 |
| 10 | 13 | 18 | 28 |
| 11 | 17 | 19 | May 1 |
| 12 | 18 | 20 | 2 |
| 13 | 19 | 21 | 3 |
| 14 (Markets Closed) | N/A | N/A | N/A |
| 17 | 20 | 24 | 4 |
Memorial Day
Monday, May 29, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| May 22 | May 25 | May 30 | Jun 9 |
| 23 | 26 | 31 | 12 |
| 24 | 30 | Jun 1 | 13 |
| 25 | 31 | 2 | 14 |
| 26 | Jun 1 | 5 | 15 |
| 29 (Markets Closed) | N/A | N/A | N/A |
| 30 | 2 | 6 | 16 |
Independence Day
Tuesday July 4, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Jun 27 | Jun 30 | Jul 5 | Jul 17 |
| 28 | Jul 3 | 6 | 18 |
| 29 | 5 | 7 | 19 |
| 30 | 6 | 10 | 20 |
| Jul 3 | 7 | 11 | 21 |
| 4 (Markets Closed) | N/A | N/A | N/A |
| 5 | 10 | 12 | 24 |
Labor Day
Monday, September 4, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Aug 28 | Aug 31 | Sept 5 | Sept 15 |
| 29 | Sept 1 | 6 | 18 |
| 30 | 5 | 7 | 19 |
| August 31 | 6 | 8 | 20 |
| *Sept 1 | 7 | 11 | 21 |
| 4 (Markets Closed) | N/A | N/A | N/A |
| *5 | 7 | 11 | 21 |
*Double Settlement Day Scenario (Holiday: September 4, 2017; Trade Dates: September 1 and 5, 2017; Double Settlement Day: September 7, 2017)
Columbus Day
Monday, October 9, 2017. The securities exchanges will be open. Therefore, it is considered a business day for receiving both customers’ securities under SEA Rule 15c3-3 and customers’ payments under Regulation T of the Federal Reserve Board. It is not, however, a settlement date, as banking institutions will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Oct 2 | Oct 4 | Oct 6 | Oct 18 |
| 3 | 5 | 9 | 19 |
| 4 | 6 | 10 | 20 |
| 5 | 10 | 12 | 24 |
| 6 | 11 | 13 | 25 |
| 9 | 11 | 13 | 25 |
| 10 | 12 | 16 | 26 |
Veteran’s Day
Saturday, November 11, 2017. As the exchanges are normally closed on Saturdays, there will be no changes to the schedule. Regular way settlement will occur as expected.
Thanksgiving Day
Thursday, November 11, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Nov 16 | Nov 20 | Nov 22 | Dec 5 |
| 17 | 21 | 24 | 6 |
| 20 | 22 | 27 | 7 |
| 21 | 24 | 28 | 8 |
| 23 (Markets Closed) | N/A | N/A | N/A |
| 24 | 28 | 30 | 12 |
Christmas Day
Monday, December 25, 2017. The securities exchanges will be closed.
| Trade Date | Settlement Date | Regulation T Date | SEA Rule 15c3-3(m) Extension Date |
| Dec 18 | Dec 20 | Dec 22 | Jan 5 |
| 19 | 21 | 26 | 8 |
| 20 | 22 | 27 | 9 |
| 21 | 26 | 28 | 10 |
| 22 | 27 | 29 | 11 |
| 25 (Markets Closed) | N/A | N/A | N/A |
| 26 | 28 | Jan 2, 2018 | 12 |
Finally, firms should be aware that the SEC is proposing an amendment to SEA Rule 15c6-1(a) to shorten the standard settlement cycle from T+3 to T+2 for most broker-dealer transactions. Industry representatives – such as SIFMA, the Depository Trust & Clearing Corporation, and the Investment Company Institute – have identified September 5, 2017 as the date the transition will begin. Firms should consider the move to a shortened settlement cycle (T+2) for all trade dates beginning September 5, 2017, in anticipation of this change.
