On April 20, 2026, FINRA published Regulatory Notice 26-10 announcing the adoption of updated intraday margin standards under FINRA Rule 4210. The new requirements replace the longstanding “day trading margin requirements,” including the pattern day trader (PDT) framework.
The amendments eliminate both the day trade count thresholds used to designate customers as “pattern day traders” and the $25,000 minimum equity requirement applicable to PDT accounts. Instead, FINRA will require firms to monitor intraday margin exposure based on a customer’s actual market exposure and margin deficiency throughout the trading day.
The amendments become effective June 4, 2026, with an 18-month implementation phase-in period ending October 20, 2027. FINRA also plans to issue shortly a separate notice announcing the availability of interpretive guidance and other resources relating to the new intraday margin standards.
Background
FINRA stated that the existing day trading margin requirements, adopted nearly 25 years ago, had become “restrictive, onerous, and unnecessary in today’s markets.” In response to industry concerns and following a retrospective review, FINRA adopted a new “intraday margin rule” designed to provide customers with greater flexibility to participate in markets, while ensuring that customers maintain equity in their margin accounts commensurate with their actual exposure during the trading day.
Importantly, FINRA notes that the new rule does not replace existing maintenance margin requirements; it supplements them.
Key Amendments to Rule 4210
1. Elimination of the Pattern Day Trader Framework
The amendments remove:
- The four-day trade count test used to designate a customer as a pattern day trader.
- The $25,000 minimum equity requirement for PDT accounts.
- The legacy day trading margin calculations tied specifically to pattern day trading activity.
This represents a significant shift away from account classification based on trade frequency and toward real-time or end-of-day risk exposure analysis.
2. New Intraday Margin Deficit Requirement
New Rule 4210(d)(2) requires each member to determine the “intraday margin deficit” for each customer margin account (excluding good faith accounts and portfolio margin accounts) for any day in which there is an “intraday margin level” (IML)-reducing transaction.
An IML-reducing transaction reduces the amount a customer can withdraw while still meeting maintenance margin requirements. Examples include short sales or purchases of securities not used to cover a short position.
An intraday margin deficit represents the highest deficiency between the required maintenance margin and the account equity following such transactions.
FINRA designed the rule to permit firms to implement real-time monitoring and pre-trade blocking controls. However, real-time monitoring is not mandatory. Firms may instead perform a single daily calculation similar to current maintenance margin review practices.
3. Permitted Calculation Methodologies
The amendments provide operational flexibility in calculating intraday margin, including:
- Treating eligible sweep program deposits at Federal Deposit Insurance Corporation-insured banks as credit balances.
- Using updated market values rather than prior close or execution prices.
- Applying flexible treatment of “as of” transactions.
- Netting same-day deposits, withdrawals, and closing transactions.
- Treating multi-leg strategies and certain option exercises and liquidations simultaneously.
- Assuming the sequence of events that produces the highest intraday margin deficit when timing cannot be demonstrated.
These provisions are intended to allow firms to operationalize compliance without requiring unnecessary system redesign, where reasonable supervisory alternatives exist.
4. Satisfaction of Deficits and 90-Day Freeze Requirement
If an account incurs an intraday margin deficit, the member must ensure the deficit to be satisfied “as promptly as possible”.
An intraday margin deficit:
- Remains outstanding until satisfied, or
- Expires after the close of business on the 15th business day after occurrence
If a customer fails to satisfy a deficit by the close of business on the fifth business day and demonstrates a “practice” of untimely satisfaction, the firm must impose a 90-calendar-day restriction. This prevents the customer from creating or increasing a short position or debit balance other than by closing a short position.
FINRA provides limited exceptions where deficits:
- Do not exceed the lesser of 5% of account equity or $1,000, or
- Occur due to extraordinary circumstances reasonably determined by the member
5. Portfolio Margin Accounts
For portfolio margin accounts, firms must update their written risk analysis methodologies to include procedures for determining and monitoring intraday risk.
Additionally, portfolio margin accounts maintaining less than $5 million in equity must maintain an intraday margin substantially similar to those used at the close of business.
This preserves the existing $5 million threshold already embedded within the portfolio margin framework.
What This Means for Broker-Dealers
Although the elimination of the PDT rule may appear customer-friendly, the amendments create significant supervisory, operational, and systems obligations for broker-dealers.
Firms should begin assessing and updating their Written Supervisory Procedures to reflect:
- Intraday margin monitoring methodology
- Deficit calculation standards
- Escalation protocols for outstanding deficits
- Application of the 90-day freeze
- Exception handling and extraordinary circumstance determinations
- Portfolio margin intraday risk oversight, where applicable
Technology and Surveillance Controls
Firms should evaluate whether existing clearing firm and margin systems can:
- Calculate IML and intraday margin deficits
- Track outstanding deficits across multiple days
- Apply five-and fifteen-business-day timing requirements
- Support freeze restrictions
- Document supervisory review and exception management
Where clearing firms perform these functions, introducing firms should confirm oversight responsibilities and evidence retention expectations.
Customer Disclosures and Account Agreements
Broker-dealers should also review customer-facing disclosures, margin agreements, and internal training materials to remove legacy references to “pattern day trader” restrictions and replace them with disclosures consistent with the new intraday margin framework.
FINRA’s new intraday margin framework represents a fundamental shift in risk monitoring, supervision, and operational execution for broker‑dealers. ACA’s Broker‑Dealer Compliance team works with firms to assess margin and surveillance controls, update Written Supervisory Procedures, enhance exception management, and support implementation planning throughout regulatory change cycles.
Contact an ACA expert for assistance preparing for Rule 4210’s new intraday margin standards.