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Notice 2026-32: Alternative method for carrying broker-dealers to demonstrate satisfaction of adequate net worth requirement for nonbank trustees

May instead demonstrate satisfaction of Rule 15c3-1 (SEC Net Capital Rule) and Rule 15c3-3 (SEC Customer Protection Rule)

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MAY 21, 2026

The IRS today released Notice 2026-32, providing that broker-dealers that carry customer accounts, and receive or hold funds or securities for those customers, may, in lieu of demonstrating satisfaction of the adequacy of net worth requirement for nonbank trustees under Treas. Reg. § 1.408-2(e)(5)(ii), demonstrate satisfaction of Rule 15c3-1 (SEC Net Capital Rule) and Rule 15c3-3 (SEC Customer Protection Rule) of the Securities Exchange Act of 1934.

The notice applies as of May 21, 2026.

The notice also describes procedures regarding demonstration by a carrying broker-dealer of satisfaction of the SEC Net Capital and Customer Protection Rules and requests public comments on related topics.

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