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Rule mapRule text checked October 27, 2026

Regulatory Compliance Mapping

This page maps each Loffa product to the rules it serves. Each entry says what the rule requires and what the product does about it, and links the rule text. The last section lists what stays with your firm.

Products and services
5
3 software products and 2 services run by Loffa staff
Requirements mapped
6
From Regulation T, SEC Rules 17a-3, 17a-4, and 17a-13, and a 1994 SEC staff letter
FVD and QBS retention
8years
Three of them in the application. Shorter on request if you keep your own copies.
PBIN agreement records
Life + 6years
Kept for the life of the agreement, then 6 more years
Matrix

Which Product Serves Which Rule

  • The software does the work
  • Loffa staff do it for you
  • Covered in a consulting gap review
Requirements as rows and Loffa products as columns. Each cell says how the product supports the requirement, or that it isn't mapped.
Requirement FVDFreefunds Verified Direct PBINPrime Broker Integrated Network QBSQuarterly Broker Statement CSDCompliance Service Desk CCSCompliance Consulting Services
Exception to the 90-day freezeReg T, 12 CFR 220.8(c)(2)(ii) Software Not mapped Not mapped Not mapped Not mapped
Prime brokerage conditionsSEC staff letter, Jan. 25, 1994 Not mapped Software Not mapped Not mapped Not mapped
Verify securities out of your possession for more than 30 daysSEC Rule 17a-13(b)(3) Not mapped Not mapped Software Loffa staff do it for you Gap review
Record unresolved count differences within 7 business daysSEC Rule 17a-13(b)(5) Not mapped Not mapped Software Loffa staff do it for you Gap review
Preserve records for the required periodSEC Rule 17a-4 Software, for communications under paragraph (b)(4) Not mapped Software Not mapped Gap review
Make and keep current the required books and recordsSEC Rule 17a-3 Not mapped Not mapped Not mapped Not mapped Gap review

A blank cell means the product’s own page doesn’t tie it to that rule. The entries below say what each rule requires and what each product does.

By product

What Each Rule Requires, and What the Product Does

FVD sends and answers Letters of Free Funds between executing brokers and custodians, and keeps every request and response. The executing broker uses FVD-S, and the custodian or carrying broker uses FVD-R.

FVD keeps letters
8 years, 3 in the application
Rule 17a-4(b)(4) minimum
3 years, the first 2 easily accessible

Regulation T 12 CFR 220.8(c)(2)(ii)

The rule requires

When a nonexempt security in a customer’s cash account is sold or delivered to another broker-dealer before the customer has paid for it in full, the customer loses the privilege of delaying payment beyond trade date for 90 calendar days. Paragraph (c)(2)(ii) lifts that freeze if the security went to another broker-dealer for deposit in a cash account that holds enough funds to pay for it.

Your firm may rely on that broker-dealer’s written statement, accepted in good faith, that the funds are there. That statement is the Letter of Free Funds.

FVD does

FVD-S builds a standard letter from the DVP trade and sends it, encrypted, to the custodian. FVD-R gives the custodian one channel for incoming letters and indexes the ones that still arrive by email or fax, so staff can verify each letter and respond. FVD tracks each letter’s status and deadline.

Rule text: 12 CFR 220.8, Cornell LII

SEC Rule 17a-4 17 CFR 240.17a-4(b)(4)

The rule requires

Paragraph (b)(4) covers originals of the communications a broker-dealer receives and copies of the ones it sends, when they relate to its business. Paragraph (b) sets a minimum of 3 years, the first 2 in an easily accessible place. A Letter of Free Funds request and the custodian’s response are communications under this paragraph.

FVD does

FVD writes each request, response, and status change to write-once (WORM) storage as it’s sent, with its timestamps, the trade details on the letter, and the user who acted. It keeps them 8 years, three of them in the application. Firms that keep their own copies can ask for a shorter period.

When an examiner asks about one letter, you pull its full history from one place.

Rule text: 17 CFR 240.17a-4, Cornell LII

PBIN is a shared network where prime brokers, executing brokers, and clearing firms manage their prime brokerage agreements and the SIA forms that document them.

PBIN keeps agreement records
Life of the agreement plus 6 years
Forms
SIA Form 150 and the SIA-151 clearance agreement

SEC staff prime broker letter January 25, 1994

The letter requires

In a letter dated January 25, 1994, the SEC’s Division of Market Regulation told the industry’s Prime Broker Committee that it wouldn’t recommend enforcement action over prime brokerage arrangements that meet the letter’s conditions.

The conditions include written agreements. Before any prime brokerage activity starts, the prime broker and each executing broker sign a contract that sets out their obligations, and each of them has a contract with the customer, signed by the customer. The industry puts the contract between the prime broker and each executing broker on paper with SIA Form 150. The SIA-151 is a separate clearance agreement between the customer and the clearing broker on the executing side.

PBIN does

PBIN takes in SIA-150 and SIA-151 forms digitally, checks each one for completeness, and routes it to the counterparties for review and signature. It tracks every agreement from submission through execution, amendment, and renewal, and alerts you to expirations, pending approvals, and counterparty actions.

Only authorized representatives of each counterparty can see the agreement data. Access is role-based, with multi-factor sign-in. PBIN keeps agreement records for the life of the agreement plus 6 years.

How the letter and Regulation T meet at the executing broker

QBS runs the counterparty side of the Rule 17a-13 quarterly securities count. It covers borrows, loans, repos, and fails, from your stock record to the confirmations and any differences they show.

Difference deadline
7 business days after the count
QBS keeps count records
8 years, 3 in the application

SEC Rule 17a-13 17 CFR 240.17a-13(b)(3)

The rule requires

At least once each calendar quarter, a broker-dealer covered by the rule verifies the securities it controls but doesn’t physically hold, such as securities in transfer, pledged, loaned, borrowed, failed to receive or deliver, or subject to repurchase agreements, once they’ve been in that status for longer than thirty days.

The rule spaces the counts at least 2 months and at most 4 months apart. People without direct responsibility for the securities, or for keeping the records involved, must make or supervise the work.

QBS does

QBS pulls borrows, loans, repos, reverse repos, and fails to deliver and receive from your stock record. For each position open more than 30 days, it generates the confirmation, packaged by account or by DTC number, and tracks the counterparty’s response. It flags non-responses for alternative verification.

It also holds counts to the 2-to-4-month spacing and has separation-of-duties controls for who supervises them.

Rule text: 17 CFR 240.17a-13, Cornell LII

SEC Rule 17a-13 17 CFR 240.17a-13(b)(5)

The rule requires

No later than 7 business days after each required quarterly count and verification, the firm records every unresolved difference on its books in a security count difference account. Each entry shows the security involved and the date of comparison.

QBS does

QBS lists each count difference and tracks it against the 7-business-day deadline. It posts the ones still unresolved to the security count difference account.

SEC Rule 17a-4 17 CFR 240.17a-4

The rule requires

Rule 17a-4 sets how long a broker-dealer preserves its records. Records listed in paragraph (a) are kept at least 6 years, and those in paragraph (b) at least 3. In both cases the first 2 years are kept in an easily accessible place.

QBS does

QBS writes every confirmation, counterparty response, count record, and difference resolution to WORM storage with a time-stamped audit trail. It keeps them 8 years, three of them in the application, or less if your firm keeps its own copies and asks.

Rule text: 17 CFR 240.17a-4, Cornell LII

Compliance Service Desk

Managed service

CSD is a team of Loffa compliance operators who run your daily and quarterly regulatory tasks, under your procedures and on your timeline.

SEC Rule 17a-13 (b)(3) and (b)(5)

CSD does

CSD’s operators run the whole quarterly count for you, from planning and execution through reconciliation and exception resolution, and document every count. The rule’s requirements are in the QBS entry.

CSD also runs free funds letter processing, trade confirmation management, reconciliations, document retrieval for exams and audits, and regulatory reporting. Its product page doesn’t tie those tasks to specific rules, so the matrix doesn’t either.

CCS is advisory work on your compliance setup: architecture reviews, gap analysis, workflow redesign, and exam preparation.

SEC Rules 17a-3, 17a-4, and 17a-13 Gap analysis

The rules require

Rule 17a-3 lists the books and records a broker-dealer must make and keep current, from blotters and ledgers to trade confirmations and account records. Rule 17a-4 sets how long they’re kept, and Rule 17a-13 sets the quarterly count.

CCS does

CCS checks your processes against these three rules, ranks each gap by risk, and gives you a remediation plan. It also reviews how you capture, archive, and supervise business communications, and runs mock audits before an exam. CCS recommends. Your firm decides what to change.

Rule text: 17 CFR 240.17a-3, Cornell LII
Your side

What Stays With Your Firm

Loffa retains the records its products process. That doesn’t make Loffa your books-and-records keeper, and your firm’s own Rule 17a-4 obligations stay with your firm.

Loffa told SEC staff the same thing in 2003. The staff’s no-action letter to Loffa records that Loffa won’t keep or maintain the books and records Rules 17a-3 and 17a-4 require on behalf of broker-dealers, and that it will tell broker-dealers so.

The products also leave these decisions with you.

  • Whether to accept a Letter of Free Funds in good faith. Regulation T lets your firm rely on the statement. FVD delivers it and keeps the record.
  • Whether an account goes into the 90-day freeze, and what to do when a letter goes unanswered.
  • Whether a prime brokerage arrangement meets the 1994 letter’s conditions, and whether to keep trading under it. PBIN holds and routes the forms.
  • How to resolve a count difference, and which alternative procedure to use when a counterparty doesn’t confirm. QBS flags both. Your procedures decide.
  • Who makes or supervises the quarterly count. Rule 17a-13 requires someone without direct responsibility for the securities or the records involved, and your firm assigns that person.
  • Your written procedures. CSD works under them and CCS recommends changes, but your firm writes and approves them.
  • Your own copies of the records, if you ask Loffa for a shorter retention period.

This page explains rules for orientation and isn’t legal advice. For how a rule applies to your firm, read the rule text and ask your counsel or compliance advisor.

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