Payment In Lieu of a Dividend (“payment in lieu” or “PIL”) is a term commonly used to describe a cash payment to an account in an amount equivalent to the ordinary dividend. Generally, the amount paid is per share owned. In addition, the dividend in most cases is paid quarterly (i.e., four times per year). The dividend payment is classified as follows: (1) ordinary dividend; and/or (2) payment in lieu of dividend. The former designation is for a payment received directly from the issuer or its paying agent. The latter designation is used when a cash payment is received from other than the issuer or the issuer’s agent.
Payment in lieu of an ordinary dividend may be received when the shares have been bought on margin, or when the account has a subsequent margin loan due to borrowing money to facilitate the payment for additional purchases of shares or as the result of a withdrawal from the margin account. Payment in lieu of a dividend may also be received when shares are owed to the brokerage firm and have not been received by the dividend record date.
To better understand the difference between an ordinary dividend and a payment in lieu, we will explain the steps taken by IB to comply with US regulations. Each business day, the Firm analyzes the positions in each customer account, every borrow, every loan, every pledge of shares for each security held by its customers to determine how many shares are held on margin and the associated margin loan balances. For each security that is fully paid, we are required to segregate those shares in a good control location (for example, a depository or a US bank. See KB1964). For shares that are held as collateral for a margin loan we are allowed to hypothecate and re-hypothecate shares valued up to 140 percent of the total debit balance in the customer account (See KB1967).
While the guidelines noted above for segregation of securities are clear, there are exceptions that are outside of the Firm's control. For instance, through no fault of its own, IB may have a deficit in segregated shares due to customer activity that changes the Firm’s overall segregation requirement for a security. This may be for a variety of reasons including a delay in receiving shares that have been loaned out to a counterparty after segregation requirements are recalculated and the Firm has issued a stock loan recall, sales of securities by one or more customers that reduce or eliminate margin loans, the deposit of cash by customers that similarly reduce or eliminate margin loans, or a failure of a counterparty to deliver shares for a trade settlement.
Upon issuing a recall of shares loaned, rules permit the borrower of the shares up to 3 business days to return them. The borrower of the shares is required to return them to us when we issue a recall, but if by business day 3 the shares have not been returned, IB may then issue a buy-in notice to begin the process of regaining possession of the shares. An additional 3 business days is generally needed for the purchased shares to settle and be delivered to the firm. Similarly if a counterparty fails to deliver by settlement date, shares to IB to settle a customer purchase, IB can issue a buy-in notice but the purchase of such shares are also subject to trade settlement in 3 days.
To summarize, if by the record date of a dividend certain shares have not been delivered to IB, the Firm will be paid an amount of cash that is equivalent to the dividend amount, but IB will not receive a qualified dividend payment directly from the issuer. In such cases, the Firm will receive PIL and will have no choice but to allocate such payment in lieu to customer accounts. The firm first allocates PIL to those accounts who hold the shares as collateral for a margin loan. If, after PIL is allocated to all shareholders whose accounts are not fully paid, any portion of PIL remains to be paid, it is allocated on a pro-rata basis to each remaining client account.
Account holders should be aware that a PIL may have different tax consequences than an ordinary dividend and should consult a tax advisor to understand such differences and whether they apply to their particular situation.
The Account Window provides the high-level information suitable for monitoring one's account on a real-time basis. This includes key balances such as total equity and cash, the portfolio composition and margin balances for determining compliance with requirements and available buying power. This window also includes information relating to the most recently assessed exposure fee and a projection of the next fee taking into consideration current positions.
To open the Account Window:
• From TWS classic workspace, click on the Account icon, or from the Account menu select Account Window (Exhibit 1)
Exhibit 1
• From TWS Mosaic workspace, click on Account from the menu, and then select Account Window (Exhibit 2)
Exhibit 2
After opening the window, scroll down to the Margin Requirements section and click on the + sign in the upper-right hand corner to expand the section. There, the "Last" and "Estimated Next" exposure fees will be detailed for each of the product classifications to which the fee applies (e.g., Equity, Oil). Note that the "Last" balance represents the fee as of the date last assessed (note that fees are computed based upon open positions held as of the close of business and assessed shortly thereafter). The "Estimated Next" balance represents the projected fee as of the current day's close taking into account position activity since the prior calculation (Exhibit 3).
Exhibit 3
To set the default view when the section is collapsed, click on the checkbox alongside any line item and those line items will remain displayed at all times.
Please see KB2275 for information regarding the use of IB's Risk Navigator for managing and projecting the Exposure Fee and KB2276 for verifying exposure fee through the Order Preview screen.
Important Notes
1. The Estimated Next Exposure Fee is a projection based upon readily available information. As the fee calculation is based upon information (e.g., prices and implied volatility factors) available only after the close, the actual fee may differ from that of the projection.
2. Exposure Fee Monitoring via the Account window is only available for accounts that have been charged an exposure fee in the last 30 days
IB provides a feature which allows account holders to check what impact, if any, an order will have upon the projected Exposure Fee. The feature is intended to be used prior to submitting the order to provide advance notice as to the fee and allow for changes to be made to the order prior to submission in order to minimize or eliminate the fee.
The feature is enabled by right-clicking on the order line at which point the Order Preview window will open. This window will contain a link titled "Check Exposure Fee Impact" (see red highlighted box in Exhibit I below).
Exhibit I
Clicking the link will expand the window and display the Exposure fee, if any, associated with the current positions, the change in the fee were the order to be executed, and the total resultant fee upon order execution (see red highlighted box in Exhibit II below). These balances are further broken down by the product classification to which the fee applies (e.g. Equity, Oil). Account holders may simply close the window without transmitting the order if the fee impact is determined to be excessive.
Exhibit II
Please see KB2275 for information regarding the use of IB's Risk Navigator for managing and projecting the Exposure Fee and KB2344 for monitoring fees through the Account Window
Important Notes
1. The Estimated Next Exposure Fee is a projection based upon readily available information. As the fee calculation is based upon information (e.g., prices and implied volatility factors) available only after the close, the actual fee may differ from that of the projection.
2. The Check Exposure Fee Impact is only available for accounts that have been charged an exposure fee in the last 30 days
IB provides a variety of tools and information intended to provide account holders with real-time details as to their state of margin compliance so as to avoid forced liquidations. These include the following:
IRA accounts, by definition, may not use borrowed funds to purchase securities and must pay for all long stock purchases in full, may not carry short stock positions and may not hold a debit cash balance (in any currency). IRA accounts are eligible to carry futures and option contracts. In addition, IB offers a specific form of IRA account referred to as a “Margin IRA” that allows the account holder to trade with unsettled funds, carry American style option spreads and maintain long balances in multiple currency denominations.
For additional information regarding trading permissions in an IRA account, refer to KB188.
If the aggregate cash balance in a given account is a debit, or negative, then funds are being borrowed and the loan is subject to interest charges. A loan may still exist, however, even if the aggregate cash balance is a credit, or positive, as a result of balance netting or timing differences. The most common examples of this are as follows:
Introduction
Where to Learn More
Tools provided to monitor and manage margin
How to determine if you are borrowing funds from IBKR
Why does IBKR calculate and report a margin requirement when I am not borrowing funds?
Buying power serves as a measurement of the dollar value of securities that one may purchase in a securities account without depositing additional funds. In the case of a cash account where, by definition, securities may not be purchased using funds borrowed from the broker and must be paid for in full, buying power is equal to the amount of settled cash on hand. Here, for example, an account holding $10,000 in cash may purchase up to $10,000 in stock.
In a margin account, buying power is increased through the use of leverage provided by the broker using cash as well as the value of stocks already held in the account as collateral. The amount of leverage depends upon whether the account is approved for Reg. T margin or Portfolio Margin. Here, a Reg. T account holding $10,000 in cash may purchase and hold overnight $20,000 in securities as Reg. T imposes an initial margin requirement of 50%, which translates to buying power of 2:1 (i.e., 1/.50). Similarly, a Reg. T account holding $10,000 in cash may purchase and hold on an intra-day basis $40,000 in securities given IB’s default intra-day maintenance margin requirement of 25%, which translates to buying power of 4:1 (i.e., 1/.25).
In the case of a Portfolio Margin account, greater leverage is available although, as the name suggests, the amount is highly dependent upon the make-up of the portfolio. Here, the requirement on individual stocks (initial = maintenance) generally ranges from 15% - 30%, translating to buying power of between 6.67 – 3.33:1. As the margin rate under this methodology can change daily as it considers risk factors such as the observed volatility of each stock and concentration, portfolios comprised of low-volatility stocks and which are diversified in nature tend to receive the most favorable margin treatment (e.g., higher buying power).
In addition to the cash examples above, buying power may be provided to securities held in the margin account, with the leverage dependent upon the loan value of the securities and the amount of funds, if any, borrowed to purchase them. Take, for example, an account which holds $10,000 in securities which are fully paid (i.e., no margin loan). Using the Reg. T initial margin requirement of 50%, these securities would have a loan value of $5,000 (= $10,000 * (1 - .50)) which, using that same initial requirement providing buying power of 2:1, could be applied to purchase and hold overnight an additional $10,000 of securities. Similarly, an account holding $10,000 in securities and a $1,000 margin loan (i.e., net liquidating equity of $9,000), has a remaining equity loan value of $4,000 which could be applied to purchase and hold overnight an additional $8,000 of securities. The same principals would hold true in a Portfolio Margin account, albeit with a potentially different level of buying power.
Finally, while the concept of buying power applies to the purchase of assets such as stocks, bonds, funds and forex, it does not translate in the same manner to derivatives. Most securities derivatives (e.g., short options and single stock futures) are not assets but rather contingent liabilities and long options, while an asset, are short-term in nature, considered a wasting asset and therefore generally have no loan value. The margin requirement on short options, therefore, is not based upon a percentage of the option premium value, but rather determined on the underlying stock as if the option were assigned (under Reg. T) or by estimating the cost to repurchase the option given adverse market changes (under Portfolio Margining).
As a U.S. broker-dealer registered with the Securities & Exchange Commission (SEC) for the purpose of facilitating customer securities transactions, IB LLC is subject to various regulations relating to the extension of credit and margining of those transactions. In the case of foreign equity securities (i.e., non-U.S. issuer), Reg T. allows a U.S. broker to extend margin credit to those which either appear on the Federal Reserve Board's periodically published List of Foreign Margin Stocks, or are deemed to have a have a "ready market" under SEC Rule 15c3-1 or SEC no-action letter.
Prior to November 2012, "ready market" was deemed to include equity securities of a foreign issuer that are listed on what is now known as the FTSE World Index. This definition was based upon a 1993 SEC no-action letter and was premised upon the fact that, while there may not have been a ready market for such securities within the U.S., the securities could be readily resold in the applicable foreign market. In November of 2012, the SEC issued a follow-up no-action letter (www.sec.gov/divisions/marketreg/mr-noaction/2012/finra-112812.pdf) which expanded the population of foreign equity securities deemed to have a ready market to also include those not listed on the FTSE World Index provided that the following four conditions are met:
1. The security is listed on a foreign exchange located within a FTSE World Index recognized country, where the security has been trading on the exchange for at least 90 days;
2. Daily bid, ask and last quotations for the security as provided by the foreign listing exchange are made continuously available to the U.S. broker through an electronic quote system;
3. The median daily trading volume calculated over the preceding 20 business day period of the security on its listing exchange is either at least 100,000 shares or $500,000 (excluding shares purchased by the computing broker);
4. The aggregate unrestricted market capitalization in shares of the security exceed $500 million over each of the preceding 10 business days.
Note: if a security previously meeting the above conditions no longer does so, the broker is provided with a 5 business day window after which time the security will no longer be deemed readily marketable and must be treated as non-marginable.
Foreign equity securities which do not meet the above conditions, will be treated as non-marginable and will therefore have no loan value. Note that for purposes of this no-action letter foreign equity securities do not include options.
Symbol | Description |
CQC | CUESTA COAL LTD |
UNS | UNILIFE CORP-CDI |
GHC | GENERATION HEALTHCARE REIT D |
CDG | CLEVELAND MINING CO LTD |
THR | THOR MINING PLC-CDI |
CXX | CRADLE RESOURCES LTD |
MGN | MAGELLAN PETROLEUM CORP-CDI |
MXQ | MAX TRUST |
PXS | PHARMAXIS LTD |
EGG | ENERO GROUP LTD |
AFR | AFRICAN ENERGY RESOURCES-CDI |
TTI | TRAFFIC TECHNOLOGIES LTD |
GID | GI DYNAMICS INC-CDI |
MLX | METALS X LTD |
IRI | INTEGRATED RESEARCH LIMITED |
RCU | REAL ESTATE CAPITAL PARTNERS |
PAA | PHARMAUST LTD |
AVQ | AXIOM MINING LTD |
SUM | SUMATRA COPPER & GOLD-CDI |
SHC | SUNSHINE HEART INC-CDI |
MNZ | MNEMON LTD |
FRC | FORTE CONSOLIDATED LTD |
RVA | REVA MEDICAL INC - CDI |
SCD | SCANTECH LIMITED |
PGI | PANTERRA GOLD LTD |
AKP | AUDIO PIXELS HOLDINGS LTD |
KPR | KUPANG RESOURCES LTD |
WCB | WARRNAMBOOL CHEESE & BUTTER |
307 | UP ENERGY DEVELOPMENT GROUP |
8096 | RUIFENG PETROLEUM CHEMICAL |
3777 | CHINA FIBER OPTIC NETWORK SY |
396 | HING LEE HK HOLDINGS LTD |
8372 | RUIFENG PETROLEUM CHEMICAL |
8376 | GLOBAL ENERGY RESOURCES INT |
702 | SINO OIL AND GAS HOLDINGS LT |
8286 | SHANXI CHANGCHENG MICROLIG-H |
3300 | CHINA GLASS HOLDINGS LTD |
355 | CENTURY CITY INTL |
399 | UNITED GENE HIGH-TECH GROUP |
STRTECH | STERLITE TECHNOLOGIES LTD |
INGERRAND | INGERSOLL-RAND INDIA LTD |
KALPATPOW | KALPATARU POWER TRANSMISSION |
IBSEC | INDIABULLS SECURITIES LTD |
RELMEDIA | RELIANCE MEDIAWORKS LTD |
KENNAMET | KENNAMETAL INDIA LIMITED |
TBZ | TRIBHOVANDAS BHIMJI ZAVERI L |
MAHINDFOR | MAHINDRA FORGINGS LTD |
IVRCLINFR | IVRCL LTD |
GOLDLEG | GOLDEN LEGAND LEASING & FIN |
8068 | RYOYO ELECTRO CORP |
2749 | JP-HOLDINGS INC |
2169 | CDS CO LTD |
3278 | KENEDIX RESIDENTIAL INVESTME |
1934 | YURTEC CORP |
3433 | TOCALO CO LTD |
4109 | STELLA CHEMIFA CORP |
1720 | TOKYU CONSTRUCTION CO LTD |
4775 | SOGO MEDICAL CO LTD |
6801 | TOKO INC |