Many Believe FINRA Exceeded its Mandate On June 10, 2024, the SEC extended the period by which it must take action on FINRA’s proposed SLATE Rules from June 21, 2024 to August 5, 2024.

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Loan Recalls & the T+1 Countdown: Can Securities Lenders Adapt?
Time is Running out for Lenders to Prepare for T+1 and N-PX Loan Recall Wrinkles The securities industry is transitioning to a T+1 settlement cycle, where trades settle one business day after the transaction date. While this shift promises benefits like reduced market risk and lower costs, it poses significant challenges for securities lenders.
Predictive AI in Securities Finance: Step One
On April 2nd, 2026, an effusion of data from a daily trove of U.S. regulatory filings will create resources to drive many new use cases for artificial intelligence in capital markets. A clear opportunity exists in securities finance, where practitioners have repeatedly stated that major IT investments will be needed to comply with the many new regulatory mandates. “Black box” AI platforms may seem a ready solution but can also create nightmares for client reviews and lawsuits.
In our opinion, public data can clarify the rational limits of influence for predictive artificial intelligence. The best courtroom-ready models will display an audit trail based on the replication of critical decision parameters and vectors from past markets. Vendor data in securities finance may be more timely and deeper than the public releases but, for judicial purposes, the public data will provide foundational evidence for the “bounded rationality” of decision-makers, as defined by the late Herbert Simon, Nobel Laureate and the father of Artificial Intelligence.
Beyond Benchmarking: The Race to Predictive Analytics in Securities Finance
When, on October 13, 2023, the Securities and Exchange Commission released its long-awaited final 10c-1 rule on reporting and public disclosure of securities loans (explained here), the most important passage, at least to the commercial data vendors who support the securities finance community, stated that, “the final rule could render existing securities lending data services less valuable, potentially leading to less revenue for the firms currently compiling and distributing these data for a fee.”[1] But is that true? Are bonuses and careers really at risk?? As shown in the table below, there is hope for vendors because the public data release will either omit or delay several data elements that are crucial to many important vendor applications today.
New Money Fund Reforms: Safer and More Resilient Cash Collateral Pools?
More liquidity, transparency, and safety for institutional investors? The Securities and Exchange Commission (SEC) recently adopted final rules on money market (2a-7) fund reforms. These reforms are designed to make money market funds more resilient and liquid, potentially making them safer and more attractive vehicles for mutual funds to use as collateral pools for their […]
SEC Adopts Long Awaited Securities Lending Disclosure Rule
Persuasive Public Comment Helps Mold the Final Rule The Securities and Exchange Commission (SEC) has adopted a new rule, rule 10c-1, to increase transparency in the securities lending market. The rule requires certain persons to report information about securities loans to a registered national securities association (RNSA). The RNSA will then make certain information publicly […]
Untold Stories of Market Manipulation: Archegos Capital
How Securities Lenders Unraveled the $100 billion Pump and Dump Scheme By Ed Blount and Dan Hammond “In a matter of days, the companies at the center of Archegos’s trading scheme lost more than $100 billion in market capitalization, Archegos owed billions of dollars more than it had on hand, and Archegos collapsed.”U.S. Federal Bureau […]
Archegos Litigation Heats Up
Rogue Trader’s Collapse Still Ripples Through the Financial Industry In March 2021, Archegos Capital Management, a family office run by Bill Hwang, collapsed in a spectacular fashion, leaving its counterparties with over $10 billion in losses. The collapse of Archegos was one of the largest hedge fund failures in history, and it has since been […]
Modernizing Beneficial Ownership Reporting
The Industry Waits for Final Action from the SEC In early 2022, the Securities and Exchange Commission (SEC) proposed several significant changes to Regulations 13D and 13G, which require certain persons to disclose their beneficial ownership of equity securities. These changes seek to improve the transparency and timeliness of beneficial ownership reporting and to make […]
The SEC Unveils its Agenda for 2023
A Busy Mix of New Business and Old In its recently updated regulatory flexibility agenda, the Securities and Exchange Commission has announced its regulatory priorities for 2023. A mix of old and new business, the Commission’s 2023 plans include finalizing 29 existing proposals and placing 23 new proposals up for consideration. In a January 4, […]