среда, 23 июня 2010 г.

Background


Because Regulation T initial
margin requirements and NASD/
NYSE standard maintenance
margin requirements3 are calculated
only at the end of each day, a
day trader who has no positions in
his or her account at the end of the
day would not incur a Regulation
T initial margin nor a standard
maintenance margin requirement,
assuming no losses in the account
from that day’s trading. Current
NASD/NYSE initial margin provisions,
however, generally require
a customer to deposit margin of at
least $2,000, unless in excess of
the cost of the security.
Although the day trader may end
the day with no position, the day
trader’s clearing firm is at risk during
the day if credit is extended.
To address this risk, the NASD
and NYSE require day traders to
demonstrate that they have the
ability to meet the initial margin
requirements for at least their
largest open position during the
day. Specifically, under current
margin requirements, a customer
who meets the definition of day
trader under the rule must deposit
in his or her account the margin
that would have been required
under Regulation T (i.e., the 50
percent initial margin requirement)
if the customer had not liquidated
the position during the trading day.
If the customer day trades, but is
not considered a “day trader,” the
customer is still required to post 25
percent of the position held during
the day.4 Currently, this payment is
due after the risk has been incurred.
Therefore, the funds are not available
during the trading day when
the clearing firm is at risk.
Currently, if a customer’s day trading
results in a day-trading margin
call, the customer has seven days
to meet the call by depositing cash
or securities in the account.
Because day traders typically end
the day flat and this day-trading
“margin” deposit is not securing a
margin loan, the customer is not
required to leave the margin
deposit in the account and may
withdraw the deposit the day after
the deposit is made. If the customer
fails to meet a day-trading
margin call, no specific action to
the customer account is required
to be taken by the firm. There are
no securities to liquidate, as there
would be for an existing position,
because day traders typically end
the day flat.

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