Deposit requirements are the amount of money you must contribute to carry out an investment strategy in a margin account. If you borrow money from your broker-dealer, you’re subject to Regulation T and FINRA margin requirements.
Regulation T is a rule under the Securities Exchange Act of 1934 that requires a specified deposit when you borrow money to buy securities. The Federal Reserve controls this rule. In most cases, Regulation T requires an initial deposit of 50% of the transaction value.
FINRA requires at least $2,000 of margin equity (ownership) to use margin loans. In practice, the required deposit is the greater of the Regulation T requirement and the FINRA minimum. An example makes this easier to see.
An investor opens a new margin account and subsequently executes a purchase of 100 shares of ABC stock at $30. What is their deposit requirement?
Can you figure it out?
Answer = $2,000
The investor purchases $3,000 of stock (100 shares x $30). They must deposit the greater of 50% or $2,000.
Because $2,000 is greater, the investor must deposit $2,000.
What if the purchase is less than $2,000? For example, suppose an investor buys stock worth $1,200. Requiring a $2,000 deposit wouldn’t make sense because the most they could lose on that purchase is $1,200 (if the stock became worthless). In that case, the investor deposits 100% of the purchase price. In other words, the account is treated like a cash account for that transaction.
Margin initial deposit rules for long accounts are summarized as follows:
| Purchase amount | Deposit amount |
|---|---|
| $2,000 or less | Entire amount |
| $2,000 - $4,000 | $2,000 |
| $4,000 or more | 50% (Regulation T) |
Investors who already own fully-paid securities (securities bought without borrowed funds) may be able to meet deposit requirements without posting cash. Fully-paid securities can be transferred into the margin account and used as collateral.
In particular, you can post 2x the cash deposit requirement in fully-paid marginable* securities. For example, suppose an investor wants to purchase $10,000 of stock in a new margin account.
This satisfies the Regulation T requirement without depositing cash.
*A marginable security can be purchased on margin or utilized as collateral in a margin account. A list of marginable securities is provided later in this chapter.
Deposit rules are different for short positions. When an investor sells short, losses can exceed the initial value of the position.
For example, suppose an investor shorts 100 shares at $15.
Because short positions have higher risk, margin rules require a minimum deposit equal to the greater of 50% or $2,000. Most importantly, even a small short position below $2,000 still requires at least a $2,000 deposit.
For example:
An investor opens a new margin account and executes a short sale of 10 shares of ABC stock at $40. What is their deposit requirement?
Although the position is only worth $400 (10 shares x $40), the investor must deposit $2,000. Unlike long purchases, short sales always require at least a $2,000 deposit. If this same trade were a long purchase of 10 shares at $40, the required deposit would be $400.
Many securities are marginable, meaning they can be purchased with borrowed funds or used as collateral. Marginable securities include:
*The Federal Reserve provides a list of OTC (unlisted) stocks they deem marginable. As a reminder, unlisted stocks are typically volatile and risky. The Fed generally only approves the “best of the worst,” typically the least volatile securities in this group. Here’s an old example of their marginable OTC stock list.
**Primary market offerings include both initial public offerings (IPOs) and mutual funds. These securities can never be purchased on margin with borrowed funds, but they can act as collateral towards a purchase of another security. For example, assume an investor opens an account and buys mutual fund shares with their own money. After 30 days of holding the position, it is worth $10,000. They could purchase $10,000 of a marginable stock (a completely different security) and not deposit any extra funds.
These securities are not marginable:
In addition, only non-retirement margin accounts* can utilize margin. The following account types cannot utilize margin:
*In recent years, some broker-dealers have introduced “limited margin retirement accounts”. While most non-margin accounts require investors to wait before using unsettled proceeds (e.g., selling stock and using the proceeds immediately), limited margin accounts permit investors to bypass settlement requirements. Other forms of margin, like borrowing funds to purchase new securities, cannot be used. This concept is generally untested, and you should assume retirement accounts cannot use margin.
Regulation T also sets a deadline for settlement in both margin and cash accounts. Securities can have different regular-way settlement times, but Regulation T settlement is always two business days after regular-way settlement. This is the last day:
If the required cash or securities aren’t delivered by Regulation T settlement, the broker-dealer holding the account must act. The firm can either request an extension from the appropriate self-regulatory organization (usually FINRA) or close out the position and freeze the account.
If the firm obtains an extension from an SRO, the customer gets extra time to meet the obligation. For example, if a customer owes $10,000 for a recent purchase, they’ll have a few additional days to make the $10,000 deposit. Extension requests are infrequent and may be denied.
More commonly, the firm liquidates positions and freezes the account. Using the same example, if the customer still owes $10,000 by Regulation T settlement (two business days after regular-way settlement), the firm can liquidate $10,000 of securities in the account. The firm uses the proceeds to pay for the transaction and then freezes the account.
A frozen account can still be used, but only when funds are immediately available. Before placing a purchase, the customer must already have enough cash in the account to pay for it. Frozen accounts remain frozen for 90 days.
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