And the Snuggie goes to: a kind gentleman at FINRA who called me back TODAY and pointed to what I should have reviewed in the first place: response to comments and amendment 2 as they relate to the original rule filing.
In summary, even if your firm is a subscription-based mutual fund retailer--not a clearing firm and not a carrying firm--you still fit into the category of ''carrying/clearing members' if you have an account for the exclusive benefit of customers as described in paragraph (k)(2)(i) of SEA 15c3-3. That is, if you receive and deposit customer checks in an account you control, you're in this category for the sake of rule compliance. It's a customer protection thing, so they say.
So review Notice 09-71 again, and remember that all of these rules might apply to you, even if you think they don't (or shouldn't).
Going home now to put on my own Snuggie. Brrrr.
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