Client Alert

DOL Issues Interim Final Rule on Cross-Trading Policies and Procedures for ERISA Accounts

February 14, 2007

Josh Sternoff and Jacquelyn Volpe

The recently enacted Pension Protection Act established a helpful new prohibited transaction exemption for cross-trading of securities held by ERISA-covered accounts. Among other things, the exemption requires cross-trading investment managers to adopt written cross-trading policy and procedure statements. The U.S. Department of Labor has just issued interim guidance on satisfying this requirement.

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