Data Elements Not Included / Reportable in Rule 10c-1a

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• SEC Approved FINRA Rules: 2nd January 2025


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• Data Elements Not Included / Reportable in Rule 10c-1a

Data Elements Not Included / Reportable in Rule 10c-1a

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

Identified data elements initially required to be reported under the proposed rule change, as originally proposed in the Notice, that were not included under Rule 10c-1a, including:

1. the expected settlement date of the Covered Securities Loan;

2. any other fees or charges (i.e., the dollar cost of any other fees or charges in addition to the rebate rate or securities lending fee separately required to be reported);

   1. In light of the removal of the text “any other fees or charges” as a data element that must be reported separately from the rebate rate (for a Covered Securities Loan collateralized by cash) or the securities lending fee (for a Covered Securities Loan not collateralized by cash), as applicable, Partial Amendment No. 1 also added the text “or any other fee or charges” to the Covered Securities Loan information specified in proposed Rule 6530(a)(2)(H) and the text “or rate, or any other fee or charges” to the Covered Securities Loan information specified in proposed Rule 6530(a)(2)(I).

3. whether the Covered Person is the lender, borrower, or intermediary;

4. if the Covered Securities Loan is an allocation of an omnibus loan effected pursuant to an agency lending agreement, the unique internal identifier for the associated omnibus loan assigned by the Covered Person responsible for reporting the Covered Securities Loan to SLATE;

5. the expected settlement date for modifications to the loan amount (if the expected settlement date is a date other than the date of the Loan Modification), or the effective date for all other Loan Modifications (if effective date is a date other than the date of the Loan Modification);

6. such modifiers and indicators as are required by FINRA under the Rule 6500 Series or the SLATE Participant specification;

   1. Exclusive Arrangement;

   2. Loan to Affiliate;

   3. Unsettled Loan;

   4. Terminated Loan;

   5. Rate or Fee Adjustment; and

   6. Basket Loan.

7. the unique internal identifier assigned to the Covered Securities Loan by the Covered Person responsible for reporting the loan to SLATE.

   1. With the exception of the data element concerning the unique identifier (clientUniqueLoanId example lifecycle being New Loan Event Sequence 4) assigned to the Covered Securities Loan by the Covered Person responsible for reporting the loan to SLATE, where a Covered Person’s daily submission includes two or more reports related to the same Covered Securities Loan, and FINRA has not yet assigned a unique identifier to the Initial Covered Securities Loan, all of the additional data elements listed above that commenters objected to as being beyond the scope of Rule 10c-1a were removed in Partial Amendment No. 1.

      1. However, to allow FINRA to link same-day T+0 reports that relate to the same Covered Securities Loan in fulfilling its data dissemination obligations under Rule 10c-1a(g), Partial Amendment No. 1 added proposed Rule 6530(a)(2)(U), which is a targeted provision providing that, where a Covered Person’s daily submission includes two or more reports related to the same Covered Securities Loan (e.g., an Initial Covered Securities Loan and a Loan Modification to terminate the Covered Securities Loan), and FINRA has not yet assigned a unique identifier to the Initial Covered Securities Loan, the Covered Person must report a unique identifier assigned to the Covered Securities Loan by the Covered Person responsible for reporting the loan to SLATE. FINRA stated that this requirement is limited to instances where a Covered Person’s daily submission includes two or more T+0 reports related to the same Covered Securities Loan—which is the circumstance that gives rise to the audit trail gap sought to be addressed by the requirement.

      2. Similarly, with respect to Loan Modifications, where a Covered Person’s daily submission includes two or more T+0 reports related to the same Covered Securities Loan, the Covered Person must report the identifier that was provided with respect to the associated same-day report for that Covered Securities Loan.

      3. FINRA stated that, without a way to link such reports, it would be unable to accurately incorporate modifications into the daily loan statistics where FINRA cannot identify the amount of securities impacted by the modification.

      4. FINRA stated that this requirement is necessary to allow FINRA to link same-day reports that relate to the same Covered Securities Loan, which allows FINRA to accurately record transactions reported pursuant to Rule 10c-1a and to incorporate modifications into the daily loan statistics.