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ARTICLE · 10 OCTOBER 2008

DOL Issues Final Guidance on Cross-Trading Procedures

Fried Frank Harris Shriver & Jacobson
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On October 6, 2008, the US Department of Labor (the “DOL”) released its final regulation regarding the content of the policies and procedures that an investment manager must adopt if it seeks to effect cross trades under the statutory cross-trading exemption added by the Pension Protection Act of 2006 (the “PPA”).

United StatesEmployment and HR
Donald Carleen
Donald Carleen
Jessica Forbes
Jessica Forbes
Terrance O'Malley
Terrance O'Malley
Jeffrey Ross
Jeffrey Ross

On October 6, 2008, the US Department of Labor (the "DOL") released its final regulation regarding the content of the policies and procedures that an investment manager must adopt if it seeks to effect cross trades under the statutory cross-trading exemption added by the Pension Protection Act of 2006 (the "PPA"). The final regulation replaces, with few changes, an interim final regulation that the DOL issued on the same subject in early 2007. Although the final regulation becomes effective on February 4, 2009, investment managers that obtained client consent to engage in cross trades based on compliance with the interim final regulation will not be required to obtain a re-authorization as a result of the final regulation. Despite the issuance of the final regulation, a number of interpretive issues concerning the statutory exemption remain— including regarding its application to private investment funds.

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