FINRA Repo Liquidity Filings


On Jan. 8, FINRA consulted on a supplemental liquidity schedule.


  • Proposed amendment to FINRA Rule 4521, and a supplemental liquidity schedule.
  • Event Notification
  • Require firms to notify FINRA in 48 hours of event that may signify a liquidity risk.
  • If firm becomes aware of lost access to secured funding via repo or stock loan, of
    above 20% of highest amount borrowed by contract over 35 rolling calendar days.
  • Any one of firm’s five largest repo or loan counterparties, raises collateral by 20%.
  • Five largest counterparties initiates termination outstanding repo prior to maturity,
    initiates the option not to renew, or reduces access to undrawn or unused finance.
  • Aware of reduction or termination of lines of credit from banks, of 20% in 35 days.
  • Firm triggers material adverse change clause, in a contract containing such clause.
  • SLS Reporting Form
  • New Supplemental Liquidity Schedule (SLS) filing by firms with their FOCUS Report.
  • On SLS, firms report on repo financing trades and other sources or uses of liquidity.
  • Information would includes financing term, collateral type and large counterparties.
  • Require SLS reporting from firms with largest customer and counterparty exposure.
  • Scope of Firms Covered
  • Filing is by each carrying or clearing FINRA firm with $25mn or more in total credit.
  • Credit per customer reserve formula computation, as set forth in SEA Rule 15c3-3.
  • Filing also for firms whose aggregate outstanding under repo, securities loans, and
    bank loans is equal to or greater than $1bn, as reported on the most recent FOCUS
  • Effectiveness
  • Follows FINRA Sep. 2015 guide on liquidity risk management practice, see #23022.
  • FINRA estimated 110 firms required to file SLS; comment period until Mar. 8, 2018.


Regulators FINRA
Entity Types B/D; Bank; Depo
Reference RN 18-02, PR, 1/8/2018; Rule 4521; SEA Rule 15c3-3; SEA Rule 17a-5
Functions Compliance; Financial; Legal; Operations; Reporting; Risk; Treasury
Countries United States of America
Products Loan; Repo/Reverse; Securities; Stock Lending
Regions Am
Rule Type Guidance
Rule Date 1/8/2018
Effective Date 1/8/2018
Rule Id 37333
Linked to Rule :23022
Report Issue 1/15/2018
Report Section US Investment

Last substantive update on 01/08/2018