Demystifying 10c-1a: EquiLend Navigates the Path to Transparency Part 2

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We previously highlighted the challenges relating to effected vs. settlement, omnibus vs. allocation trades and rules for reporting evergreen trades under the SEC’s 10c-1a final rule. As we inch closer to the May 2 publication date of FINRA’s 10c-1a rule interpretation, we explore 3 additional ambiguities that, without clarification, could hinder a smooth compliance.