SEC Proposes Extending Rule 10c-1a Comment Collection
Published Date: 7/27/2026
Notice
Summary
No summary available.
Analyzed Economic Effects
6 provisions identified: 1 benefits, 4 costs, 1 mixed.
Burden on direct reporting firms
Each providing covered person is estimated to incur 3,000 initial PRA burden hours (annualized to 1,000 hours per entity) to develop systems, and 1,350 ongoing PRA burden hours per year. The notice estimates a total initial annual industry burden of 259,000 hours and ongoing annual industry burden of 349,650 hours for providing covered persons.
Reporting agents face large compliance hours
The Commission estimates 128 reporting agents. Each reporting agent is estimated to incur 3,000 initial hours (annualized to 1,000 hours per entity) and 1,350 ongoing annual hours per entity, for total initial annual industry burden of 128,000 hours and ongoing annual industry burden of 172,800 hours. Additional burdens include 30 hours (annualized 10) per agent to enter agreements with non-providing covered persons and 52 hours per year per agent for record upkeep (total 6,656 hours industrywide).
More public securities‑lending data
Rule 10c-1a will make pricing and material terms of securities lending transactions available to market participants and investors to improve price discovery and reduce information gaps. The Commission states this could lower barriers to entry and reduce frictions in the cost of borrowing securities.
Lowered burdens for firms using reporting agents
A non-providing covered person that relies on a reporting agent is estimated to incur 1,500 initial hours (annualized to 500 hours per entity) and 65 ongoing annual hours per entity. The notice estimates a total initial annual industry burden of 121,000 hours and ongoing annual industry burden of 163,350 hours for non-providing covered persons, plus an estimated 30 hours (annualized 10) to negotiate written agreements, totaling 2,420 hours industrywide.
RNSA (FINRA) infrastructure and retention burdens
The Commission estimates an RNSA will incur an average one-time initial PRA burden (averaged figure reported as 10,924) leading to a total initial annualized industry burden of 3,641 hours, ongoing annual PRA burdens of 7,739.5 hours, and 52 hours annually to retain collected information. These burdens reflect developing infrastructure, assigning unique identifiers, public dissemination, and record retention.
Implementation timing: delayed reporting and publication
The Commission granted a temporary exemption: covered persons are not required to report Rule 10c-1a information to an RNSA until September 28, 2028, and an RNSA is not required to make certain information publicly available until March 29, 2029. During this period, covered persons and RNSAs may voluntarily incur burdens for system testing and implementation.
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