Repo Records and Verification Under SEC Rules 17a-4, 17a-13

Updated October 2026. First published September 2024.

A broker-dealer's repo book creates two kinds of regulatory work. The first is recordkeeping: every repo and reverse repo leg has to land in the books and records Rule 17a-3 requires, and stay there as long as Rule 17a-4 says. The second is verification: securities out on repo are securities the firm doesn't physically hold, and the quarterly securities count under Rule 17a-13 has to account for them.

Where Repo Shows Up in the Records

A repo isn't a separate record type. Its legs run through the records every broker-dealer keeps under Rule 17a-3: the blotters of daily purchases, sales, receipts, and deliveries; the general ledger; the customer and counterparty ledger accounts; and the securities record, or stock record, which shows where each position is.

Rule 17a-4(a) requires keeping those records, the ones made under 17a-3(a)(1) through (3), (5), (21), and (22), for at least six years, the first two in an easily accessible place. The master repurchase agreement with each counterparty is a written agreement relating to the firm's business, so 17a-4(b)(7) covers it too, for at least three years.

Repo in the Quarterly Securities Count

Rule 17a-13 requires a count and verification at least once each calendar quarter. Two parts of it reach repo positions directly:

Paragraph (b)(2) requires accounting for securities subject to repurchase agreements, along with those in transfer, pledged, or loaned, by comparing supporting detail records with the ledger control accounts.
Paragraph (b)(3) requires verifying securities "subject to repurchase or reverse repurchase agreements" that aren't in the firm's physical possession, but only where they've been in that status for longer than 30 days.

The 30-day line sorts the repo book in a useful way. Overnight and short-dated repo usually falls outside (b)(3) verification on count date. Term repo and open repo that has rolled for more than 30 days falls inside it, and the firm needs written confirmation from the counterparty or custodian holding the securities. Unresolved differences go into a security count difference account no later than seven business days after the count.

That makes the repo desk's data quality a 17a-13 problem. If the stock record doesn't show when a repo position started, the operations team can't tell which positions need verification. The 17a-13 reconciliation challenge for fails and loans covers the same issue for securities lending.

Treasury Repo Is Moving to Central Clearing

The SEC's December 2023 rule requires covered clearing agencies for U.S. Treasury securities to have their direct participants clear eligible secondary market cash and repo transactions. That will change who the counterparty is on many Treasury repos, and the confirmations a firm collects for its 17a-13 verification will follow. Our post on the Treasury clearing rule covers the requirements and the compliance dates.

Loffa's Quarterly Broker Statement (QBS) aggregates positions across the stock record, including repos and reverse repos, for the quarterly count, then sends the confirmations and tracks the responses.