One Year to Go! US Securities Lending SLATE Reporting 2026

One year from now, on 28 September 2026, the US securities lending market faces its biggest shake-up in history. After years of largely paying lip service to the 2015 Financial Stability Board mandate for global regulatory authorities to collect and aggregate data on securities financing markets, the US securities lending market is taking action.

What is SLATE Reporting? 

SLATE introduces a single-sided reporting requirement for lenders of US securities eligible under CAT, TRACE or MSRB rules. Where the loan is effected, accepted or facilitated  – in whole or in part – in the USA, lenders must report details of those loans to FINRA’s Securities Lending and Transparency Engine (SLATE). This implies significant extraterritoriality where at least one party to the loan is in the USA, especially where the borrower is based in the USA but the lender is in a third country.

It is the “covered” person’s responsibility to determine whether a securities loan is reportable, based on CAT NMS, TRACE and/or MSRB listing of the underlying security. If the security has not yet been loaded into SLATE, then the covered person will be responsible for providing FINRA with necessary information in order to have it added.

(The covered person is a FINRA member direct security lender, a securities loan executing agent or the entity with the direct contractual relationship in the lending agreement.)

Delays

Earlier this year, following a request from FINRA, the Securities Exchange Commission (SEC) granted a delay, which pushed back the reporting launch date from 2 January 2026 to 28 September 2026. However, attempts to kybosh the regulation as a whole have been thwarted. The SEC accepted FINRA’s request to allow more time to build and test SLATE infrastructure and to ensure high quality, accurate and consistent reporting.

Recent revisions

The participant specification also changed significantly on 26 June 2025, with extensive revisions and the removal of certain fields. Reporting is required not only for new loans but also for a complex array of lifecycle events. The removal of the settlement date field and modification effective date fields may make reporting of these events more challenging and potentially introduces confusion about contractual vs. actual/effective reporting.  

Initial covered loan reports not previously reported to SLATE will be required to be reported same-day by 23:59:59 Eastern Time (ET) to the FINRA SLATE platform. This applies to loans effected on a business day between 0:00:00 and 19:00:00 ET. The same requirement covers loan allocations, modifications, full and partial terminations, corrections and cancellations.

This same day reporting from the point at which the loan is first contractually agreed and binding, not when it has settled, is likely to prove extremely challenging. Care will also be necessary to ensure that block loan trades are terminated when allocations are reported and that the value of the new allocation trades equals that of the original block.

Delegated reporting?

Firms may intend to delegate SLATE reporting in full. However under many trading scenarios they may find themselves unable to pass on the title of “covered person” – and therefore can only delegate the physical act of reporting, not the legal obligation to ensure that reporting is complete, accurate and timely.

Firms engaged in the US securities lending and borrowing markets globally should independently assess their scope or potential scope. Once scope is established, firms need to decide on their approach.  Options include:

  1. Reporting directly as covered person
  2. Using a reporting agent (such as an agent lender, likely to take legal responsibility as a covered person), or
  3. Utilising a service bureau (third party vendor) but still remaining covered person

Firms could also use a combination of these approaches.

Cost implications

Each of these options will come with different cost implications. Once captured by the regulation, whichever route you choose the cost of doing business is likely to incorporate FINRA platform costs, reporting fees and charges where late reporting occurs. Indeed, late reports will each incur a penalty charge on the same day.  Additional costs will relate to operational overheads including appropriate control frameworks to ensure compliance and data retention requirements.    

There is also potential to be captured by system generated and intra-day securities loans such as those executed on a firm’s behalf but ICSDs, such as auto-borrowing, fails curing and auto-collateralisation trades that are not expressly excluded from the SLATE obligation. These may pose issues to report just as they do under SFTR.

What should firms do to prepare? 

In readiness, securities lenders should be asking themselves:

  • Are there trading scenarios in which the firm comes into scope for a FINRA SLATE reporting obligation?
  • What approach/s does the firm intend to take in order to be compliant? (Build/Buy or Hybrid)
  • Has this business and its securities loan lifecycle events been mapped out?
  • Has a data discovery exercise been performed to identify sources of all of the data elements necessary?
  • How will self-reporting or use of a service bureau be monitored and controlled?

For a conversation with Jonathan about preparing for US SLATE Reporting, please get in touch.