Cross-Trading Policies and Procedures

SIFMA provides comments to the Employee Benefit Security Administration (EBSA) of the U.S. Department of Labor (DOL) on cross-trading policies and procedures interim final rule, 72 Fed. Reg, 6473, Feb. 12, 2007. SIFMA requests that the final regulation provide additional guidance on certain requirements of the interim rule, including the mitigation of conflicts; and that the Department address certain requirements of the statutory exemption.  SIFMA urges DOL to reconsider certain conditions in the interim rule, including the requirement of identify the compliance officer by name; and to adopt a pooled fund rule to implement consent requirements of the exemption.