SEC Cross-Trading Letter

Published on:
March 29, 2019
Submitted to:
SEC
Submitted by:
SIFMA AMG

Summary

SIFMA AMG sent a request for clarification of no-action relief under Rule 17a-7.

We request that the Staff confirm that this no-action relief also allows funds to engage in cross trades of other securities, in addition to municipal securities, using a price provided by an independent pricing service. We believe that this clarification is appropriate for the reasons and subject to the conditions set forth below.

Excerpt

Paul Cellupica

Deputy Director and Chief Counsel, Division of Investment Management

Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

Re: Clarification of no-action relief under Rule 17a-7

Dear Paul,

As discussed, here is an outline relating to our request for clarification of no-action relief under Rule 17a-7. We welcome the opportunity to discuss this with you further.

Part I. Requested relief

1. In no-action letters, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) has agreed that it would not recommend enforcement action to the Commission under Section 17(a) of the Investment Company Act of 1940, as amended (the “ICA”), if registered investment companies engage in cross trades (as defined below) under Rule 17a-7 under the ICA of municipal securities for which market quotations were not readily available using a price provided by an independent pricing service as the “current market price” of the securities, subject to certain conditions.

The no-action letters were issued to United Municipal Bond Fund (pub. avail. July 30, 1992) (the “1992 Letter”) and (pub. avail. Jan. 27, 1995) (the “1995 Letter”) and Federated Municipal Funds (pub. avail. Nov. 20, 2006) (the “2006 Letter” and, together with the 1992 Letter and the 1995 Letter, the “Letters”). We request that the Staff confirm that this no-action relief also allows funds to engage in cross trades of other securities, in addition to municipal securities, using a price provided by an independent pricing service. We believe that this clarification is appropriate for the reasons and subject to the conditions set forth below.

Continue Reading >

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.