SEC Greenlights SLATE to Revolutionize Securities Lending Reporting

What are Rule 6500 Series and SLATE?

In the Notice and Partial Amendment No.1, FINRA stated that it proposed to adopt the new rule to establish reporting requirements for covered securities loans. SLATE will also provide for the dissemination of individual and aggregate covered securities loan information and loan rate statistics.

Rule 6500 Series sets out to improve transparency and efficiency in the securities lending market, as per Section 15(A)(b)(6) of the Securities and Exchange Act, Rule 10c-1a, and Section 984 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

SLATE Impact on Market Participants

According to FINRA, the proposed rule change will involve the collection of specified securities loan information from covered persons and reporting agents, both of which may include non-FINRA members.

Under SEA Rule 10c-1, “covered persons” include non-broker intermediaries, lenders without intermediaries, clearing agencies, and broker-dealers borrowing fully paid or excess margin securities.

The implementation date of the SLATE reporting requirements takes effect on 2 January 2026, while dissemination requirements come into force on 2 April 2026.

Preparing for SLATE’s Implementation

With the SEC’s approval of FINRA’s Rule 6500, the securities lending market is set for significant changes in transparency and reporting. Firms impacted by this regulation should begin preparing for the January 2026 reporting requirements now, and ensure regulatory compliance with the subsequent dissemination standards.

Here are some key steps to ensure compliance:

• Implement Systems and Software: Ensure you have robust systems in place to handle the collection, tagging, and submission of securities loan information. Automation tools can streamline the process and reduce errors.
• Review Data Management Practices: Evaluate how your organisation stores and manages loan data to ensure it aligns with the requirements of SLATE. Consolidating data into centralised systems may help.
• Invest in Compliance Expertise: Having a dedicated team or external consultants to monitor regulatory updates and implement necessary changes can mitigate risks.
• Plan for Dissemination Requirements: Prepare for the April 2026 dissemination deadline by ensuring you can share data in the required formats and with the specified frequency.

Proactive planning and leveraging the right technology will be critical for adapting to SLATE and maintaining compliance in the evolving regulatory environment.