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On October 13, 2023, the SEC voted to adopt a new rule, SEC 10c-1a regulation, to increase the transparency of securities lending transactions in the U.S. On July 28th 2025, the U.S. Securities and Exchange Commission issued an order granting temporary exemptive relief for Rule 10c-1a. The new compliance dates are as follows:

New Reporting Date: Now September 28, 2026 (previously January 2, 2026)
New Dissemination Date: Now March 29, 2027 (previously April 2, 2026)

There are several key areas in the incoming regulation that will impact reporting requirements:

  • Submissions need to be made to FINRA
  • Lenders, Lending Agents or brokers (Only 1 side of the trade) are required to report
  • Submissions are required by the end of day
  • FINRA will publish anonymized data to the general public
  • Reportable products include those currently required under CAT, TRACE & MSRB RTRS regimes
  • A third party can be used to assist firms

S&P Global Market Intelligence Cappitech will continue to collaborate with Pirum Systems to deliver a reporting solution tailored to meet the unique requirements and workflows of the incoming SEC 10c-1a regulation.

The solution combines Cappitech’s rigorous data validation, event creation, and regulatory connectivity with Pirum’s UTI generation, exchange, and reconciliation abilities. to form an efficient and streamlined reporting solution.

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