SEC keeps speedy stock trade paperwork humming without new burdens
Published Date: 9/25/2026
Notice
Summary
The SEC is asking for approval to keep collecting info under Rule 15c6-2, which helps brokers settle stock trades faster—within one business day instead of two. This rule affects brokers and dealers who must have clear written policies or agreements to confirm trades quickly. No new costs or deadlines are introduced, but the rule’s paperwork requirements continue to keep the trading process smooth and speedy.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 4 costs, 0 mixed.
Must have written policies or agreements
If you are a broker-dealer that handles institutional trades, Rule 15c6-2 requires you to either enter into written agreements or establish, maintain, and enforce written policies and procedures to complete allocations, confirmations, and affirmations ‘‘as soon as technologically practicable and no later than the end of trade date.’’ The required policies must identify technology and processes, set target trade-date time frames, describe procedures to communicate and fix trade discrepancies, address delays by other parties, and measure and document completion rates.
Estimated paperwork time burdens
The SEC estimates about 396 broker-dealers would be subject to Rule 15c6-2. Of those, about 36 firms would incur a one-time burden of 240 hours to create required policies and procedures, and respondent broker-dealers would incur an ongoing estimated annual burden of 480 hours each. The SEC estimates total industry burdens of 192,960 hours (20,160 hours for firms with both initial and ongoing burdens plus 172,800 hours for firms with only ongoing burdens).
Recordkeeping and retention requirements
Rule 15c6-2 imposes recordkeeping obligations on broker-dealers to maintain policies and procedures consistent with the rule. Under Exchange Act Rule 17a-4(b)(7), written agreements must be preserved for at least three years, with the first two years in an easily accessible place, and compliance and procedures manuals must be maintained until three years after they are no longer used.
Rule applies to institutional trades and DTC participants
The collection applies to broker-dealers that are parties to institutional transactions. The SEC estimates about 145 broker-dealers participate directly in the Depository Trust Company (DTC) and estimates an additional ~251 broker-dealers serve institutional customers, for about 396 broker-dealers that would be subject to Rule 15c6-2's requirements.
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