Executive Summary
On Jan. 2, 2025, the US Securities and Exchange Commission
("SEC") approved the Financial Industry
Regulatory Authority, Inc.'s
("FINRA") proposed new Rule 6500 Series
(Securities Lending and Transparency Engine
("SLATE")).1 The SEC's
approval of the FINRA Rule 6500 Series ("SLATE
Rules")2 represents one of
the final steps in implementing ("Rule
10c-1a") of the Securities Exchange Act of 1934, as
amended (the "Exchange Act").3
FINRA's rulemaking was mandated by Rule 10c-1a.4 Importantly, Rule
10c-1a applies to any "covered person" or "reporting
agent" (collectively, "Reporting
Persons"), as such terms are defined therein, a group
that includes registered broker-dealers, registered investment
advisers, private funds, agent banks and registered clearing
agencies and foreign (non-US) persons.5 While only FINRA
members (a group that is limited to broker-dealers registered with
the SEC pursuant to Section 15 of the Exchange Act) are
