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Becoming an Approved Broker-Dealer

To become an approved broker-dealer, firms must complete the following steps: 

  1. Read the Department's Investment Policy Statement.
  2. Submit documentation attesting to the Broker-Dealer requirements to cst_investment_team@state.co.us.
  3. Email treasurer.young@state.co.us to schedule a meeting with Department Investment Team to present qualifications.  
  4. If approved to move forward, a representative from the firm must read the Broker-Dealer Notice and submit the Broker-Dealer Acknowledgment form.

Broker-Dealer Requirements 

Approved broker-dealers must: 

  1. Be designated as a primary government securities dealer by the Federal Reserve Bank of New York and /or FHLB, a regional dealer, a direct issuer of eligible investments (such as BAs or CP) or a dealer representing many institutional buyers and sellers on an electronic platform providing competitive bids and offers;
  2. Have a minimum net capital of one hundred million dollars, or deemed competitive based on value added from expertise in research (information from and access to analysts, strategists, and economists) and/or trading (new issue underwriting, best bids and offers, and sales coverage), to be reviewed annually at a minimum;
  3. Be self-clearing or have a third-party agreement with an entity having the required net capital and clearing;
  4. Have been in operation for at least three years;
  5. Not have a qualification of the auditor’s opinion or a contingent liability that could materially affect the firm’s capital; and
  6. Deemed competitive based on the value added to the Investment Team, including expertise in research (e.g., information from and access to analysts, strategists, and economists) and/or trading (e.g., new issue underwriting, best bids and offers, and sales coverage); and
  7. Be in compliance with the Uniform Net Capital rule of the U.S. Securities & Exchange Commission (the “SEC”). Current financial statements must be available to the State Treasury on demand.  

No independent contractor arrangements will be considered, except when authorized in writing.

Broker-Dealer Notice

By virtue of conducting investment transactions with the Colorado Department of the Treasury, approved broker-dealers acknowledge that they have reviewed the Investment Policy Statement displayed on the Colorado Department of the Treasury website and sent a signed statement to the State Treasurer acknowledging an understanding of this Investment Policy Statement. Approved broker-dealers agree to have implemented reasonable procedures and internal controls to preclude imprudent and fraudulent investment activities arising out of investment transactions conducted between the Colorado Department of the Treasury and the approved broker-dealers. It is expected that all approved broker-dealers use professional due diligence in informing the Colorado Department of the Treasury of foreseeable risks associated with financial transactions.

Broker-Dealer Acknowledgment Form

By my authorization below, I acknowledge that my firm has received, read, and agrees to comply with all requirements and limitations in the State of Colorado Department of the Treasury’s Investment Policy Statement, dated February 26, 2025.

An asterisk (*) indicates a required field.