Effected and Effective / Actual and Contractual Reporting

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• SEC Approved FINRA Rules: 2nd January 2025


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• Effected and Effective / Actual and Contractual Reporting

Effected and Effective / Actual and Contractual Reporting

Status: TO BE REVIEWED Last Updated: 04 Jun 2025

Notes and Examples:

•  Some member firms shared that the USA market is a same day market and therefore view the settlement date and effective date as the same day.

  • Although this is factual it cannot be denied that systems dont always work to this same rule, hence what if you have a new trade booked today for a future settlement although this may be instructed on the actual day for settlement the system for regulatory reporting will surely need to report the trade on the trade date in a contractual nature and not wait for the actual settlement date.

• As the settlement date (Pre-existing Loan Modification and Modification lifecycle events) and modification effective date (all lifecycles) have been removed it was debated if this is an issue or not which then led to a conversation around actual and contractual reporting of life cycle events and how this looks for USA securities which has been mentioned operate in a same day market. 

• Under the SEC’s Rule 10c-1a, the term "effected" refers to the completion or execution of a securities lending transaction.

  • Specifically, the rule mandates that when a covered person effects, accepts, or facilitates a covered securities loan in the U.S., it becomes a reportable security under Rule 10c-1a.  This means that the transaction must be reported to a registered national securities association (RNSA) by the end of the day on which the loan was effected.

  • Require clarity on when lifecycle events should be reported, see here for current understanding can this please be validated?

    • Thinking about how lifecycle events can be effective meaning they could be for future or past dates:

      1. Effective Today Activity Date:

         1. Where all lifecycle events are effected today and effective today then report the lifecycle event at the end of day today = Actual

      2. Effective Future Activity Dates:

         1. New Trade:

            • Where New Trade lifecycle events are effected today but for a future effective date, report the lifecycle event at the end of day today = Contractual

         2. Partial Return:

            • Where Partial Returns lifecycle events are effected today but for a future effective date, report the lifecycle event at the end of the successful settlement date = Actual

            • What would the Event Date Time field be stamped with?

         3. Rate (Fee, Rebate or Spread) Change:

            • Where lifecycle events are effected today but for a future effective date, report the lifecycle event at the end of day on the effective date = Actual

            • What would the Event Date Time field be stamped with?

         4. All other Non-Settlement Related lifecycle events:

            • Where all other non-settlement lifecycle events are effected today but for a future effective date, report the lifecycle event at the end of day on the effective date = Actual

      3. Effective Past (as of) Activity Dates:

         • Where all lifecycle events are effected today but for a past effective dates, report the lifecycle event at the end of day today = Actual

      4. For Terminations see:

         1. Termination Date & Term Date & Terminated Loan Indicator page