Alternative Method for Carrying Broker-Dealers to Comply with Certain Nonbank Trustee Rules (Notice 2026-32)

This notice provides that, pursuant to § 1.408-2(e)(6)(ii) of the Income Tax Regulations, a broker-dealer that carries customer accounts and receives or holds funds or securities for those customers (a carrying broker-dealer) may, in lieu of demonstrating satisfaction of the adequacy of net worth requirement for nonbank trustees under § 1.408-2(e)(5)(ii), demonstrate satisfaction of Rule 15c3-1 (SEC Net Capital Rule) and Rule 15c3-3 (SEC Customer Protection Rule) (together, SEC Net Capital and Customer Protection Rules) of the Securities Exchange Act of 1934, as amended (Exchange Act).