On January 2, 2025, the US Securities and Exchange Commission (SEC) officially approved FINRA’s revised proposal under the FINRA Rule 6500 Series, establishing the framework for reporting under the 10c-1a regulation. The approved go-live date for compliance has been set for January 2, 2026.
While the SEC’s approval is a key step forward, the pending 5th Circuit Court case remains unresolved. The outcome of this case could potentially impact the timeline and scope of the regulation. If the court rules in favor of the challenger (National Association of Private Fund Managers), it may lead to delays or modifications to the implementation of 10c-1a.
Despite the legal uncertainty, the industry continues preparing for the approved January 2, 2026, go-live date. EquiLend is actively monitoring developments and will provide timely updates to ensure our clients are informed and ready to adapt to any changes.
“We are enhancing our reporting platform to meet the approved requirements and will ensure a seamless onboarding process as the compliance date approaches. We understand the evolving and uncertain regulatory landscape can present challenges,” EquiLend wrote in a statement.