SEC Rule 10c-1a: What Securities Loan Reporting Requires and When It Starts

Updated October 2026, after the SEC moved the compliance dates twice. First published June 2024.

No one has to report securities loans under SEC Rule 10c-1a yet, and FINRA's system for receiving them isn't open. Covered persons have to start reporting to FINRA on September 28, 2028, and FINRA has to start publishing the data on March 29, 2029. The SEC set those dates in an exemptive order on December 3, 2025 and restated them in a Federal Register notice on September 30, 2026. It's also considering changes to the rule itself.

When this post first ran in June 2024, it said reporting would start in 2026 and tied the rule to T+1. The rule has nothing to do with the settlement cycle. Here's what it requires, how the dates moved, and what's still open.

What the Rule Requires

The SEC adopted Rule 10c-1a on October 13, 2023, under Section 984 of the Dodd-Frank Act. It applies to three kinds of covered person:

• A person that agrees to a covered securities loan on behalf of a lender, such as a lending agent. A clearing agency acting only as a central counterparty or central securities depository is excluded.
• A lender that agrees to a loan without an intermediary.
• A broker-dealer borrowing fully paid or excess margin securities from customers under Rule 15c3-3(b)(3).

A covered securities loan is a loan of a reportable security, meaning one reported to CAT, TRACE, or the MSRB's RTRS. Two things are carved out: positions at a clearing agency that come from its central counterparty or depository services, and a broker-dealer's use of customers' margin securities. If the broker-dealer then lends those margin securities to someone else, that onward loan is covered.

The covered person reports by the end of the day the loan is effected, and again by the end of the day it's modified. The report has twelve public data elements: the issuer and its LEI, a security identifier, the date and time of the loan, the platform or venue, the amount loaned, the collateral type, the rebate rate (cash collateral) or lending fee (non-cash), the collateral percentage, the termination date, and the type of borrower. It also has confidential elements that FINRA keeps private: the parties and their identifiers, whether a broker-dealer lent from its own inventory to a customer, and whether the loan closes out a fail under Rule 204 of Regulation SHO.

You can hand the reporting to a reporting agent, which must be a broker, dealer, or registered clearing agency. That takes a written agreement and timely access to your data. The agent keeps what it receives and sends for three years, the first two in an easily accessible place.

FINRA, the only registered national securities association, then publishes each loan by the morning of the next business day, without the amount. The amount follows on the twentieth business day. FINRA also publishes daily aggregates by security and keeps the data public for five years.

How the Dates Moved

The first delay came at FINRA's request. In its April 29, 2025 letter, FINRA listed what had to happen before January 2, 2026 (build the system, run user acceptance testing, onboard reporters and their agents) and said it and market participants were concerned about the risks of that schedule. It also wanted time to check the quality of reported data before publishing it. The July 28, 2025 order granted both requests and moved reporting to September 28, 2026.

The second delay came from court. The National Association of Private Fund Managers, the Managed Funds Association, and the Alternative Investment Management Association had challenged the rule. On August 25, 2025, the Fifth Circuit sent Rule 10c-1a and the short-position rule (Rule 13f-2) back to the SEC to consider and quantify their combined economic impact. It didn't vacate either rule. The December 2025 order gives the SEC time to respond, which it said "may include proposing amendments to the Rules," and to avoid making firms pay to comply with parts that could change.

What the SEC May Change

The SEC's current regulatory agenda lists "Amendments to Rule 10c-1a" (RIN 3235-AN73) at the proposed rule stage. The entry says the Division of Trading and Markets is considering recommending amendments "that would reduce costs and burdens" for reporters and for FINRA, marks the item deregulatory, and gives October 2026 as the target for a proposal. As of October 26, 2026, no proposal has appeared in the Federal Register.

Industry groups have said what they want. SIFMA's May 18, 2026 letter asks for three changes: exclude short arranged financing with customers from the definition of a covered securities loan, publish loan-level data on the twentieth business day instead of the next morning, and require reporting only of loans that actually settle. None of that is law until the SEC proposes it and adopts it.

What to Do Before 2028

Some of the work doesn't depend on what the SEC changes. Decide which of the three covered-person categories you fall in, if any. If you lend through an agent, find out whether it plans to act as your reporting agent, and get that in a written agreement when the time comes. Map where each of the twelve data elements lives in your systems today, and which ones you'd need from a counterparty or platform.

Don't lock in the build yet. The SEC's own reason for the two-year delay is that parts of the rule could change, and the scope of a covered loan and the publication timing are where SIFMA has asked for changes. For FINRA's side of this, including its reporting windows and technical specifications, see our post on FINRA's SLATE system. For how T+1 did change lending operations, see securities lending under T+1.

This post is for informational purposes only and does not constitute legal advice. For guidance on specific regulatory obligations, consult your counsel or compliance advisor.