Description

A focused course, tailored for you

The Broker-Dealer FinOp Regulatory Reporting Operating Manual

Closing FOCUS, customer reserve, and net capital with the same evidence file every week, not a heroic month-end rebuild.

Net capital, the 15c3-3 customer reserve, and the FOCUS Part II tie-out are all computed off the same trial balance, but the evidence trail behind each one lives in a different folder and a different head. When a FINRA examiner asks how a single haircut percentage was arrived at, the answer takes three days.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

FinOps inside a clearing or self-clearing broker-dealer carry the FINRA Series 27 obligation personally. The work has three weekly engines: the customer reserve formula computation under SEC Rule 15c3-3, the net capital computation under Rule 15c3-1, and the FOCUS Part II or Part IIA filing. Each one pulls from the same general ledger and stock record, but the inputs flow through different reconciliations: customer free credit balances, allowable and non-allowable assets, securities haircuts by category, undue concentration adjustments, subordinated debt, and the credit balance segregation calculation. Most teams have rebuilt the spreadsheets three times in the last 18 months as the product mix shifted into bank sweep, fractional shares, and crypto custody arrangements. The exam letter does not ask for the answer. It asks for the workpaper that produced the answer, with the source extracts attached, and the explanation of why the haircut category was chosen. That document does not exist as a standing artefact in most BD finance departments. It is reassembled each time, which is why month-end is a sprint and why exam prep eats the quarter.

What you walk away with

A standing weekly customer reserve formula computation pack with every input tied to a named source extract.
A net capital workbook with haircut categories defended against the rule reference and the position file that fed each line.
FOCUS Part II and IIA tie-out templates that reconcile to the general ledger, the stock record, and the prior-period filing in one file.
A controller-ready explanation memo template for the variance conversation that happens every Tuesday.
A FINRA exam evidence binder structured the way an examiner opens it, not the way the team built it.

The 12 modules

Module 1. The weekly close cadence: customer reserve, net capital, FOCUS as one cycle

The three reporting engines share inputs but most BDs run them as three separate weeks. Module 1 redraws the cadence so the trial balance cutoff, stock record cutoff, and position file cutoff land on the same business day, and the customer reserve, net capital, and FOCUS tie-out all draw from one frozen extract. Includes the cutoff calendar template and the operations memo that resets the close schedule with custody, treasury, and trading.

Module 2. Customer reserve formula computation under SEC Rule 15c3-3

Builds the weekly customer reserve workbook from the regulation up. Credit and debit items by line, the qualifying securities calculation, the special reserve bank account funding mechanic, the friday-as-of-tuesday timing, and the documentation a FinOp signs against. Includes the reserve input source map (which GL accounts, which stock record extracts, which customer free credit balance sources) and the reserve breach response runbook.

Module 3. Net capital under Rule 15c3-1: allowable assets and the haircut grid

Rebuilds the daily or weekly net capital workbook with each haircut category tied back to the SEC rule reference and the position file extract that fed it. Equity, debt, money market, options, undue concentration, blockage on illiquid positions, and the open contractual commitments charge. Includes the haircut decision log so the same position never gets two different haircuts on two different Fridays.

Module 4. FOCUS Part II and Part IIA tie-out

FOCUS is a reconciliation, not a fresh calculation. Module 4 builds the Part II and Part IIA tie-out template that ties each line back to the general ledger, the prior period FOCUS, the supplemental schedules, and the customer reserve and net capital workbooks. Includes the variance commentary template for material movements line by line.

Module 5. Allowable assets bridge: the daily artefact that prevents the surprise

Most net capital surprises trace to an asset that was classified allowable on Monday and non-allowable on Friday. Module 5 builds the standing allowable assets bridge that shows day-over-day movement by GL account, by counterparty, and by reason code (aged receivable, unsecured advance, undue concentration). Includes the early-warning thresholds that trip an FOP escalation before the FOCUS surprises the controller.

Module 6. Stock record, securities count, and possession or control under 15c3-3

The possession or control framework decides whether a customer security needs to be segregated. Module 6 walks the stock record reconciliation, the securities count program, the location of customer fully paid and excess margin securities, the SBL and bank loan pledges, and the documentation that ties the customer protection rule to the underlying custody arrangement. Includes the standing securities count calendar and the deficit cure protocol.

Module 7. Subordinated debt, capital withdrawals, and the equity capital base

Subordinated loan agreements have to be FINRA-approved, have to be properly aged in the net capital computation, and have to be documented for the withdrawal restriction. Module 7 builds the subordinated debt schedule, the capital withdrawal pre-approval workflow, the affiliate funding and dividend constraint, and the FINOP attestation that covers the equity capital base movement.

Module 8. The Tuesday explanation memo: variance commentary the controller actually uses

Every Tuesday someone explains why net capital moved, why the reserve requirement moved, and why a customer free credit balance shifted. Module 8 builds the standing explanation memo template, the variance attribution method (rate, volume, mix, classification), and the one-page version that the CFO forwards to the Audit Committee without further edit.

Module 9. Supplemental schedules and concentration disclosures

FOCUS has supplemental schedules for clearing arrangements, customer asset segregation, money market funds held as customer assets, and concentration on a single security or counterparty. Module 9 builds the supplemental schedule pack, the concentration trigger logic, the single-counterparty exposure aggregation, and the disclosure language for the clearing agreement schedule.

Module 10. FINRA exam evidence binder, structured the way examiners open it

Examiners do not start with the workbook, they start with the workpaper index. Module 10 builds the standing exam binder structured the way FINRA exam staff actually navigate it: customer reserve walk, net capital walk, FOCUS reconciliation, customer protection rule walk, possession or control evidence, AML and large trader cross-reference. Each tab has a named owner and a refresh cadence so the binder is current the day the exam letter arrives.

Module 11. Adjacent filings: SIPC, CAT, large trader, BD annual audit cross-reference

FOCUS is not the only filing. Module 11 maps the SIPC general assessment reconciliation, the CAT customer and account reporting cross-check, the large trader Form 13H interaction, and the BD annual audit evidence that PCAOB-registered auditors look for. Each filing reuses inputs from the weekly close pack so the FinOp is not running parallel data exercises for each one.

Module 12. Implementing the operating manual on your firm's stack

Module 12 is the implementation walkthrough. Takes the templates from modules 1-11 and installs them against your specific GL chart of accounts, your stock record source, your custody and clearing arrangement, your product mix (cash equities, options, fixed income, fractional, bank sweep, crypto if applicable), and your FINOP attestation workflow. Includes the 90-day rollout plan, the change control register, and the handoff memo for the operations team that owns the daily extracts.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

The weekly customer reserve formula computation lands clean by Tuesday morning, not Tuesday night.

Net capital haircut categories are defended against the rule reference and the position file in writing, before the exam letter arrives.

FOCUS Part II tie-out fits in one workbook, reconciles to the general ledger and the prior filing, and the controller signs it without a Tuesday rebuild.

The FINRA exam binder is a standing artefact refreshed weekly, not a six-week scramble after the letter lands.

What you get with this course

Customer reserve formula computation workbook with input source map.
Net capital workbook with haircut category defence log.
FOCUS Part II and IIA tie-out templates with variance commentary.
Allowable assets daily bridge with early-warning thresholds.
Stock record reconciliation and possession or control evidence pack.
Subordinated debt schedule and capital withdrawal pre-approval workflow.
Tuesday explanation memo template and one-page CFO version.
Supplemental schedules pack and concentration trigger logic.
FINRA exam evidence binder structured the way examiners open it.
SIPC, CAT, large trader, and BD annual audit cross-reference map.
90-day implementation plan tailored to your firm's stack.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours: course access provisioned in the Art of Service learning environment, all downloadable workbooks and templates available, and the hand-built implementation playbook delivered alongside, tailored to a US broker-dealer FinOp operating environment.

Before and after

Before

Customer reserve, net capital, and FOCUS run as three separate exercises each week. Workpapers are reassembled every time. The Tuesday variance memo is written from scratch. FINRA exam letters trigger six weeks of binder construction. Haircut category decisions live in a spreadsheet column and a senior FinOp's head, not in a defensible written log.

After

One frozen weekly close extract feeds all three engines. The customer reserve, net capital, and FOCUS tie-out are standing artefacts that refresh in hours. The Tuesday memo is a template the FinOp fills out. The exam binder is current the week the letter arrives. Every haircut category and allowable-asset classification has a written defence tied to the rule and the source position.

What happens if you do not address this

FINRA exam findings under 15c3-1 and 15c3-3 do not stop at a Letter of Caution. They escalate to net capital deficiency notices, restrictions on the business, and personal Series 27 exposure for the FinOp. The risk is not a missing number, it is the missing workpaper behind a number. A defensible standing evidence trail is the difference between a clean exam and a multi-year remediation.

Who it is for

Financial Operations Principal, Director of Regulatory Reporting, or Controller inside a US broker-dealer (clearing, self-clearing, or fully disclosed). Holds Series 27 or 28. Owns weekly customer reserve, daily or weekly net capital, monthly FOCUS Part II or IIA, supplemental schedules, and the FINRA examiner-of-record relationship. Probably also touches CAT, large trader, and SIPC assessment filings.

Who this is NOT for. Investment advisers (RIA) without a broker-dealer affiliate. Buy-side compliance teams. People preparing for the Series 27 exam who do not yet hold the role. Banks without a registered broker-dealer subsidiary.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable workbooks (customer reserve, net capital, FOCUS tie-out, allowable assets bridge, exam binder structure) and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Roughly 14 to 18 hours to work end to end. Most FinOps work it in 60 to 90 minute blocks across two weeks while running the live close. The workbooks become production artefacts as you go, so the time is not extra; it replaces existing manual rebuilds.

Why $199 is the right number

FINRA publishes the rule text and the Regulatory Notices but does not publish a working evidence trail. The PCAOB and AICPA publish audit guidance for the BD annual audit but assume the reporting workpapers already exist. Industry bodies run conferences with high-level sessions on net capital and customer reserve but do not hand over the workbooks. This course is the operating manual: the standing workpapers, the variance memo template, and the exam binder, ready to install against your firm's stack.

FAQ

Does this assume a clearing broker-dealer or a fully disclosed one?

Both. Modules 1 through 9 cover the calculations and tie-outs that apply to any registered BD. Module 10 (FINRA exam binder) and Module 12 (implementation) are tailored at delivery to your specific introducing or clearing model, your custody arrangement, and your product mix.

Is it tied to a specific GL system?

No. The workbooks are designed to ingest extracts from any general ledger (BRASS, ADP, Broadridge, in-house) and any stock record source. Module 12 installs them against the systems your firm actually uses.

Does it cover crypto custody or bank sweep arrangements?

Yes. The customer reserve and possession or control modules walk the special-purpose account mechanics for bank sweep and the qualifying custody arrangements for digital assets, with the haircut and allowable asset implications that follow.

Who hand-builds the implementation playbook?

Gerard. The playbook is tailored to your specific FinOp environment, your product mix, your clearing or self-clearing model, and your current pain points (reserve close speed, net capital evidence trail, exam binder gaps, FOCUS variance commentary).

How is this different from the regulatory notices on FINRA.org?

The notices give you the rule. This course gives you the standing workpaper that satisfies the rule, with the variance commentary, the haircut defence log, and the exam binder structured the way examiners actually open it.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.