Cross Trading in Focus: Decoding the Regulatory Framework

February 01, 2019
| The Investment Lawyer

“Cross trades,” or trades between accounts with the same investment manager, continue to be an area of focus of both the Securities and Exchange Commission (SEC) and the Department of Labor (DOL). This article discusses the regulatory framework applicable to cross trades under the Investment Company Act of 1940, as amended (Investment Company Act), the Investment Advisers Act of 1940, as amended (Investment Advisers Act), and the Employee Retirement Income Security Act of 1974 (ERISA) and provides related compliance recommendations to investment managers.