SEC Requests Extension on Rule 15b9-1 Paperwork Burden
Published Date: 9/14/2026
Notice
Summary
No summary available.
Analyzed Economic Effects
2 provisions identified: 0 benefits, 2 costs, 0 mixed.
Brokers must join SRO unless exempt
Section 15(b)(8) and amended Rule 15b9-1 require a broker or dealer to become a member of a registered national securities association unless it effects transactions solely on an exchange of which it is a member or qualifies for narrow exceptions. The amended rule permits exemption only where (1) transactions result solely from orders routed by an exchange to comply with Rule 611 of Regulation NMS or the Options Order Protection and Locked/Crossed Market Plan, or (2) transactions are solely for executing the stock leg of a stock‑option order.
Stock‑option exemption: policies and retention
If you are a broker or dealer relying on the Rule 15b9-1 stock‑option order exemption, you must establish, maintain, and enforce written policies and procedures and preserve a copy of those policies consistent with 17 CFR 240.17a-4 until three years after they are replaced. The SEC estimates it takes about 8 hours to establish the policies (annualized to 2.67 hours per year), and about 48 hours per year to maintain and enforce them per broker/dealer; the agency estimates 3 non‑FINRA brokers or dealers may rely on the exemption, for an aggregate industry burden of about 152.01 hours per year.
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