Title
BSP guidelines on segregation of customer funds in securities brokering
Law
Bsp Circular No. 885
Decision Date
Aug 14, 2015
BSP Circular No. 885 mandates banks engaged in securities brokering to segregate customer funds and securities from their own assets, ensuring investor protection and transparency in transactions while establishing specific reporting and accounting requirements.
A

Key Definitions

  • Securities Brokering: Buying/selling securities for customers
  • Securities Broker: Entity registered by SEC to engage in brokering
  • Customer: Person whose funds or securities are handled
  • Customer Securities: Securities held or transacted for customers
  • Customer Funds: Funds received under brokering arrangement
  • Broker Customer Account for Settlement: Separate cash/margin account for settlement of trades
  • Broker Customer Securities Account: Account for holding customer securities such as margin securities or those prior to settlement

Segregation Requirements

  • Customer funds and securities must be segregated from the bank's own assets/liabilities
  • Separate accounts required:
    1. Broker Customer Account for Settlement of Customer Trades (funds account)
    2. Broker Customer Securities Account (securities account)
  • Banks must implement risk management systems to protect customer assets and prevent conflicts of interest

Accounting and Record Keeping

  • Banks must keep current books and records located at the bank’s principal office
  • Customer funds recorded as liabilities under "Broker Customer Account for Settlement of Customer Trades"
    • Funds held in a fiduciary capacity
    • Free from liens and not liable for bank’s debts
    • Non-interest bearing and not insured deposits
    • Excluded from BSP reserve coverage
  • Customer securities recorded off-balance sheet under "Broker Customer Securities Account"
    • Also held in fiduciary capacity and free from liens
    • Excluded from reserve requirements

Receivership Provisions

  • Upon appointment of a receiver, the securities business must be closed promptly
  • Outstanding contracts may be transferred to another Exchange Member if applicable
  • Customers to be informed in writing about account transfers or receivership status

Reporting Requirements

  • Banks with securities brokering licenses must submit monthly reports with weekly end balances of cash and securities
  • This report is a Category A-1 report
  • Detailed amendments to the Financial Reporting Package (FRP) include recognition of:
    • Broker Customer Accounts for settlement
    • Broker Customer Securities Accounts
    • Income from securities brokering activities
    • Special reserve accounts for securities brokers

Amendments to Financial Reporting Package

  • Revised balance sheet, income statements, and schedules per BSP Circular No. 512 and Circular No. 644
  • Specific line item instructions added for broker customer accounts and securities
  • Treatment of cash segregated for brokering and securities held for customers clarified

Transition Period and Effectivity

  • Reporting in amended FRP formats and submission of new reports begin with period ending September 30, 2015
  • Additional reports submitted within 15 banking days after month-end
  • Reports considered provisional and subject to BSP revision after six months
  • Circular takes effect 15 days after publication in Official Gazette or newspaper of general circulation

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