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Regulatory Requirements and Subsidiary Dividend Restrictions (Notes)
12 Months Ended
Sep. 30, 2018
Capital and Other Regulatory Requirements [Abstract]  
Regulatory Capital Requirements under Banking Regulations [Text Block]
Regulatory Requirements and Subsidiary Dividend Restrictions
The Company’s subsidiary INTL FCStone Financial is registered as a broker dealer and member of the Financial Industry Regulatory Authority (“FINRA”) subject to the SEC Uniform Net Capital Rule 15c3-1, which requires the maintenance of minimum net capital. INTL FCStone Financial is also a commodity futures commission merchant registered with the CFTC and subject to the net capital requirements of the CFTC Regulation 1.17. Under the more restrictive of these rules, INTL FCStone Financial is required to maintain “adjusted net capital”, equivalent to the greater of $1,000,000 or 8 percent of client and nonclient risk maintenance margin requirements on all positions, as defined in such rules, regulations, and requirements. Net capital and the related net capital requirement may fluctuate on a daily basis. INTL FCStone Financial also has restriction on dividends, which restricts the withdrawal of equity capital if the planned withdrawal would reduce net capital, subsequent to haircuts and charges, to an amount less than 120% of the greatest minimum requirement.
INTL FCStone Financial as a registered securities carrying broker dealer is also subject to Rule 15c3-3 of the Securities Exchange Act of 1934 (“Rule 15c3-3”), which requires the Company to maintain separate accounts for the benefit of securities clients and proprietary accounts of broker dealers (“PABs”). These client protection rules require the Company to maintain special reserve bank accounts (“SRBAs”) for the exclusive benefit of securities clients and PABs.
Pursuant to the requirements of the Commodity Exchange Act, funds deposited by clients of INTL FCStone Financial relating to their trading of futures and options on futures on a U.S. commodities exchange must be carried in separate accounts which are designated as segregated clients’ accounts. Pursuant to the requirements of the CFTC, funds deposited by clients of INTL FCStone Financial relating to their trading of futures and options on futures traded on, or subject to the rules of, a foreign board of trade must be carried in separate accounts in an amount sufficient to satisfy all of INTL FCStone Financial’s current obligations to clients trading foreign futures and foreign options on foreign commodity exchanges or boards of trade, which are designated as secured clients’ accounts. See below for additional information regarding INTL FCStone Financial’s calculation of segregated and secured client funds.
The Company’s subsidiary SA Stone Wealth Management Inc. (formerly Sterne Agee Financial Services, Inc.) is subject to the SEC Uniform Net Capital Rule 15c3-1 under the Securities Exchange Act of 1934.
The Company’s subsidiary INTL FCStone Ltd is regulated by the Financial Conduct Authority (“FCA”), the regulator of the financial services industry in the United Kingdom, as a Financial Services Firm under part IV of the Financial Services and Markets Act 2000. The regulations impose regulatory capital, as well as conduct of business, governance, and other requirements. The conduct of business rules include those that govern the treatment of client money and other assets which under certain circumstances for certain classes of client must be segregated from the firm’s own assets.
The Company’s subsidiary INTL FCStone Pty Ltd is regulated by the Australian Securities and Investment Commission and is subject to a net tangible asset capital requirement.
INTL FCStone DTVM Ltda. (“INTL FCStone DTVM”) is a registered broker-dealer and regulated by the Brazilian Central Bank and Securities and Exchange Commission of Brazil, and is subject to a capital adequacy requirement.
INTL Gainvest S.A. and INTL CIBSA S.A. are regulated by the Comision Nacional de Valores, and are subject to net capital and capital adequacy requirements.
All subsidiaries of the Company are in compliance with all of their regulatory requirements as of September 30, 2018, as follows:
(in millions)
 
 
 
 
As of September 30, 2018
Subsidiary
Regulatory Authority
 
Requirement Type
 
Actual
 
Minimum
Requirement
INTL FCStone Financial Inc.
SEC and CFTC
 
Net capital
 
$
167.7

 
$
101.4

INTL FCStone Financial Inc.
CFTC
 
Segregated funds
 
$
2,637.0

 
$
2,579.7

INTL FCStone Financial Inc.
CFTC
 
Secured funds
 
$
148.9

 
$
132.8

INTL FCStone Financial Inc.
SEC
 
Customer reserve
 
*

 
$
6.4

INTL FCStone Financial Inc.
SEC
 
PAB reserve
 
$
0.3

 
$

SA Stone Wealth Management Inc.
SEC
 
Net capital
 
$
4.6

 
$
0.4

INTL FCStone Ltd
FCA (United Kingdom)
 
Net capital
 
$
193.1

 
$
95.9

INTL FCStone Ltd
FCA (United Kingdom)
 
Segregated funds
 
$
187.3

 
$
182.1

INTL Netherlands BV
FCA (United Kingdom)
 
Net capital
 
$
193.0

 
$
95.9

INTL FCStone DTVM Ltda.
Brazilian Central Bank and Securities and Exchange Commission of Brazil
 
Capital adequacy
 
$
11.2

 
$
2.1

INTL Gainvest S.A.
National Securities Commission ("CNV")
 
Capital adequacy
 
$
4.2

 
$
0.1

INTL Gainvest S.A.
CNV
 
Net capital
 
$
1.2

 
$
0.1

INTL CIBSA S.A.
CNV
 
Capital adequacy
 
$
4.4

 
$
0.5

INTL CIBSA S.A.
CNV
 
Net capital
 
$
3.1

 
$
0.3


* As of September 30, 2018, the Company had no balance in the customer reserve SRBA. As a result of the reserve requirement determined through the weekly computation, the Company made a deposit to the customer reserve SRBA of $11.4 million on October 2, 2018, to meet the customer segregation requirements under Rule 15c3-3.
Certain other non-U.S. subsidiaries of the Company are also subject to capital adequacy requirements promulgated by authorities of the countries in which they operate. As of September 30, 2018, these subsidiaries were in compliance with their local capital adequacy requirements.