Reportable Security not entered into the SLATE system

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• Reportable Security not entered into the SLATE system

Reportable Security not entered into the SLATE system

Status: SEC APPROVED RULES 2.1.25 Last Updated: 02 Jan 2025

As modified by Partial Amendment No. 1, proposed Rule 6530(c)(3)52 would provide that, if a Covered Person makes a good faith determination that it has a reporting obligation under Rule 10c-1a,53 the Covered Person or Reporting Agent, as applicable, must report the Covered Securities Loan as provided in proposed Rule 6530.

If the Reportable Security is not entered into the SLATE system, proposed Rule 6530(c)(3) would also require the Covered Person or Reporting Agent, as applicable, to promptly notify and provide FINRA Operations, in the form and manner required by FINRA, the information specified in Rule 6530(a)(2)(A) and (B), along with such other information as FINRA deems necessary to enter the Reportable Security for reporting through SLATE.

FINRA stated that this requirement would enable FINRA to set the security up in its systems and facilitate reporting of the Covered Securities Loan to SLATE, as required by Rule 10c-1a and proposed Rule 6530.

Notes and Examples:

Status: TO BE REVIEWED Last Updated: 04 Jun 2025

Questions?

1. Does the security require full set up on the SLATE system prior to submitting reports?

   1. Answer: Yes

2. Is it feasible to report first then wait for the security to be set up or would this type of report be rejected by SLATE?

   1. Answer: No, the security must be set up first.

3. The SEC 10c-1a rule specifies that a reportable security is any for which information is reported or required to be reported to the consolidated audit trail as required by ‘Rule 613’ of the Exchange Act and the CAT NMS Plan (“CAT”), the FINRA Trade Reporting and Compliance Engine (“TRACE”) or the Municipal Securities Rulemaking Board’s (“MSRB”) Real-Time Reporting Systems (“RTRS”), or any that replaces one of these systems.   

   1. For CAT reportable securities, the CAT NMS Reference data list is published on the FINRA website and is updated multiple times a day. 

   2. Clarification is therefore requested from FINRA on the version that firms are expected to use to determine reportable securities daily.

   3. Regardless if the security is not on the list, it could still be a reportable security.

      1. The rules state this is on the covered person to set this up at FINRA.

   4. Why can FINRA not check the CAT, TRACE and MSRB lists?

      1. The RNSA does not manage what’s reportable or not.