Assertion: capital's form | /r/HasProperty | designed
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text: In an April 9, 2009, speech ("2009 Sirri Speech") Erik Sirri, then Director of the SEC's Division of Trading and Markets, expanded on this explanation by stating (1) the 2004 rule change did not affect the "basic" net capital rule that had a leverage limit (albeit one that excluded much broker-dealer debt), (2) an "alternative" net capital rule established in 1975 that did not contain a direct leverage limit applied to the broker-dealer subsidiaries of the five largest investment banks (and other large broker-dealers), and (3) neither form of the net capital rule was designed (nor operated) to constrain leverage at the investment bank holding company level, where leverage and, more important, risk was concentrated in business units other than broker-dealer subsidiaries.