SEC Extends Securities Lending and Short Position Reporting Compliance Deadlines to 2028
December 5, 2025
On December 3, 2025, the Securities and Exchange Commission issued an order granting temporary exemptive relief that extends compliance deadlines for securities lending and short position reporting requirements under Rules 10c-1a and 13f-2.
Key Timeline Updates
The SEC has extended compliance dates as follows:
Rule 10c-1a (Securities Lending Reporting)
- Reporting date extended to September 28, 2028
- Public dissemination date extended to March 29, 2029
- Applies to covered persons entering into securities loan agreements
Rule 13f-2 and Form SHO (Short Position Reporting)
- Compliance date extended to January 2, 2028
- First filing required within 14 calendar days after January 2028
- Applies to institutional investment managers meeting specified thresholds
Regulatory Context
- This exemptive relief follows a Fifth Circuit Court of Appeals remand directing the SEC to reassess the cumulative economic impact of these rules. The extension provides the Commission with time to respond to the court’s opinion while allowing market participants additional preparation time.
- Additionally, the SEC stated that the temporary exemptive relief is “necessary in the public interest and consistent with the protection of investors” as they allow the Commission to “take any further appropriate actions, which may include proposing amendments to the Rules.”
What This Means for EquiLend’s 10c-1a Solution
EquiLend has been developing comprehensive Rule 10c-1a compliance capabilities designed to integrate seamlessly with our existing securities lending workflows. The extended timeline doesn’t change our approach. We are committed to building reporting solutions that meet the regulatory requirements while maintaining the flexibility to adapt as the rules evolve.
We are actively tracking the SEC’s review process and any potential amendments that may emerge. As the regulatory framework takes shape over the coming months, our product development will incorporate those changes to ensure clients have compliant, operationally efficient reporting tools that are ready well ahead of the September 2028 deadline.
The additional runway provides an opportunity to refine implementation strategies and testing protocols. For firms evaluating their compliance approach, early engagement with technology and reporting solutions can help avoid the operational pressures that typically emerge as deadlines approach.
For more information about EquiLend’s regulatory solutions, visit https://equilend.com/services/sec-rule-10c-1a/ and fill out the form to contact us.
View the full SEC order: [Release No. 34-104303]