ISLA & KPMG: SEC Rule 10c-1a | Paving the Path for Transparent Securities Lending Markets

ISLA Americas is pleased to announce the release of our latest publication, SEC Rule 10c-1a | Paving the path for transparent securities lending markets, in collaboration with KPMG.

This publication is designed to provide our members with a high-level overview of the SEC’s Rule 10c-1a, highlighting its historical origin, purpose, and a summary of the Rule itself.

In this paper, we delve into the reporting requirements, analyze key similarities and differences between the Rule and the Securities Financing Transactions Regulation (SFTR), examine the Rule’s impact to market participants, and provide high-level implementation guidelines, along with a section dedicated to frequented asked questions (FAQs) and suggested next steps for your implementation roadmap.

We believe this publication will serve as a valuable resource for all ISLA America’s members and wider industry stakeholders, equipping you with the knowledge and tools needed to navigate the evolving regulatory landscape with confidence.

Key topics covered in this publication:

  • Historical origin and purpose: A look back at the historical context that led to the development and eventual enactment of SEC Rule 10c, tracing back the industry developments, such as the GFC, that paved the way for the introduction of the Rule and set the stage for its key objectives: bolstering market transparency and regulatory oversight, as well as decreasing systemic risk globally.
  • Summary of Rule 10c-1a: A concise yet comprehensive summary of the Rule to ensure a clear understanding of its provisions. This section is the cornerstone of our publication, designed to familiarize readers with the key aspects of the Rule.
  • Comparison to SFTR: A detailed comparison between Rule 10c-1a and the EU and UK’s SFTR, highlighting the similarities and differences between these two regulatory frameworks.
  • Impact to market participants: A deep dive into key operating complexities, financial implications and costs, as well as several unintended consequences, providing insight into how the Rule may affect operations and compliance strategies.
  • High-level implementation considerations: An overview of critical implementation considerations, designed to offer a starting point for your firm’s transformation journey.
  • Key next steps for your firm’s consideration: Our macro-level suggestions designed to initiate a baseline dialogue amongst the key stakeholders at your firm.

For any questions and further discussion on how Rule 10c-1 may affect your operations, or to find out more about ISLA Americas membership, please contact fran.garritt@islaamericas.org.

October 31 2024

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