SEC Eases Collateral Rules for Security Borrowing
Published Date: 4/2/2026
Notice
Summary
The SEC just gave broker-dealers more freedom on what they can use as collateral when borrowing customer securities, like stocks. This change mainly affects broker-dealers and big investors, letting them use new types of collateral beyond just cash or government bonds. The new rules kick in soon and aim to keep things safe while making borrowing smoother and possibly saving money on borrowing costs.
Analyzed Economic Effects
7 provisions identified: 2 benefits, 5 costs, 0 mixed.
Broker-Dealers May Pledge Large-Index Stocks
As of March 30, 2026, broker-dealers that borrow fully-paid or excess-margin equity securities from certain institutional lenders may pledge a diversified basket of Russell 1000 and/or S&P 500 equity securities (including unleveraged ETFs composed of those indices) as collateral. This permission applies only when the borrowing is from a Qualified Institutional Securities Lender and must follow the conditions in Rule 15c3-3 and the Order.
Who Counts As Qualified Institutional Lender
The Order defines a "Qualified Institutional Securities Lender" as (1) a qualified institutional buyer under Rule 144A, (2) an entity that invests at least $100,000,000 of third-party securities on a discretionary basis, or (3) a principal lender represented by a bank agent with at least $100,000,000 of outstanding securities loans. Broker-dealers may rely reasonably on representations from prospective lenders or agents about meeting these tests.
Extra Over-Collateralization Required
When pledging Eligible Equity Collateral, broker-dealers must provide collateral that exceeds the Rule 15c3-3 minimum (100%) by 1% if the borrowed securities are denominated in euro, British pound, Swiss franc, Canadian dollar, or Japanese yen, or by 5% if denominated in another currency. An equity security's denomination is the currency of its primary exchange.
Order Adds Liquidity, Reduces Operational Risk
The Commission states that designating Eligible Equity Collateral will add liquidity to the securities lending markets and reduce operational risk by allowing broker-dealers to directly use Eligible Equity Collateral as collateral for securities loans. The Order is presented as consistent with investor protection and Rule 15c3-3 objectives.
Five-Business-Day Cure Window
If a lender or an equity security stops meeting the Order's eligibility requirements, the lender or security remains treated as eligible for five business days. By the end of the fifth business day, the broker-dealer must substitute other collateral that complies with paragraph (b)(3) of Rule 15c3-3 or return the borrowed securities to the lender.
Custody and Holding Location Requirement
Eligible Equity Collateral must be held at a bank (as defined in section 3(a)(6) of the Exchange Act) or at a broker-dealer. Broker-dealers may reasonably rely on representations from the lender or its agent about whether this custody condition is satisfied.
Concentration, Diversification, Daily Mark-to-Market
Broker-dealers and Qualified Institutional Securities Lenders must agree to maintain concentration and diversification standards for pledged Eligible Equity Collateral, and the value of loaned securities and collateral must be marked to market daily under paragraph (b)(3) of Rule 15c3-3. These measures are intended to address value fluctuations and limit lender losses.
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