FINRA's SLATE and the Rule 6500 Series: What FINRA Built and Where It Stands
Updated October 2026. First published October 2024, while the SEC was still reviewing FINRA's proposal.
The SEC didn't shelve FINRA's securities lending rules. It approved the FINRA Rule 6500 Series, which creates the Securities Lending and Transparency Engine (SLATE), on January 2, 2025. What moved is the start date. FINRA's SLATE page now gives September 28, 2028 as the launch. FINRA's rulebook lists March 29, 2029 as the effective date of Rule 6540, the public dissemination rule. Both dates follow the SEC's orders on Rule 10c-1a, the rule SLATE exists to carry out. Our post on Rule 10c-1a covers what that rule requires and why its dates moved; this one covers what FINRA built and what it hasn't published yet.
How the Approval Went
The original version of this post, written in the middle of the SEC's review, described a postponement and gave an October 5 deadline that doesn't match the record. The SEC's approval order gives the actual sequence:
- May 1, 2024: FINRA files the proposal (SR-FINRA-2024-007), which appears in the Federal Register for comment on May 7.
- June 10, 2024: the SEC extends its review to August 5.
- August 5, 2024: the SEC institutes proceedings to decide whether to approve or disapprove, to allow more analysis of the scope and implementation and more comment on both. This is the step the original post described as a postponement.
- October 28, 2024: the SEC sets January 2, 2025 as its deadline.
- November 14, 2024: FINRA files Partial Amendment No. 1.
- January 2, 2025: approval, as amended (Release 34-102093).
When a Loan Has to Be Reported
The amendment pushed the reporting deadline from early evening to the end of the day, which matters for any desk that books loans after the U.S. close.
| Loan effected | As first proposed | As approved |
|---|---|---|
| On a business day, by the evening cutoff | 12:00 a.m. to 7:45 p.m. ET; report before 8:00 p.m. ET the same day | 12:00 a.m. to 7:00 p.m. ET; report by 11:59:59 p.m. ET the same day |
| On a business day, after the cutoff | Report before 8:00 p.m. ET the next business day | Report by 11:59:59 p.m. ET the next business day |
| On a weekend, holiday, or day SLATE is closed | Report before 8:00 p.m. ET the next business day | Report by 11:59:59 p.m. ET the next business day |
Loan modifications follow the same windows. SLATE's system hours changed with them: FINRA first proposed 6:00 a.m. to 7:59:59 p.m. ET and amended the close to 11:59:59 p.m. ET.
What the Amendment Took Out and Put In
Partial Amendment No. 1 dropped several items. The expected settlement date is gone from the report. So are the six modifiers FINRA had planned to append to every report (exclusive arrangement, loan to affiliate, unsettled loan, terminated loan, rate or fee adjustment, and basket loan), along with a separate field for other fees. FINRA also removed a proposed requirement that a member using a reporting agent supervise that agent under Rule 3110.
The amendment also added items. A covered person now reports its own MPID, if known, on each new loan. For loans priced as a spread to a benchmark, a reporter may give the rate as of the loan date plus the spread and the benchmark's name, or just the rate.
The responsibility rules are plain. A covered person can use an agent to submit its reports, but unless that agent is a reporting agent under Rule 10c-1a, the duty to report on time, accurately, and completely stays with the covered person. A member's pattern of late reporting without exceptional circumstances can be treated as a violation of FINRA Rule 2010. If a security isn't set up in SLATE, the reporter has to tell FINRA Operations so it can be added.
What FINRA Will Publish
Under Rule 6540, FINRA will publish each loan's data, except the amount, by the morning of the next business day. The amount follows 20 business days after the loan is made or its amount changes. FINRA will also publish daily statistics for each security: aggregate loan activity and the distribution of rebate rates and lending fees. FINRA filed its reporting fees and data product fees as a separate rule change.
Where SLATE Stands in October 2026
The SLATE page lists the launch as September 28, 2028, with firm onboarding and a customer test environment both marked "TBD." The participant reporting specifications were last updated June 27, 2025, and FINRA says it "anticipates updated documentation in the future." There is nothing to test against yet.
The bigger open question is the SEC's. Its regulatory agenda lists amendments to Rule 10c-1a "that would reduce costs and burdens," with a proposal targeted for October 2026. Because the 6500 Series implements Rule 10c-1a, any change to the SEC rule would mean a FINRA rule filing too. Until then, the June 2025 specifications are the best guide to what SLATE will expect, and the 11:59:59 p.m. ET deadline tells you when your end-of-day lending extract has to run.
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.