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ARTICLE · 03 NOVEMBER 2026

SEC Proposes Expanding Securities Eligible For Cross Trading By Registered Funds

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The SEC has proposed significant amendments to Rule 17a-7 that would expand cross-trading opportunities for registered investment funds, particularly in fixed-income securities. These changes aim to reverse 2020 regulatory restrictions while modernizing pricing methodologies, reallocating compliance oversight responsibilities, and enhancing reporting requirements to balance operational efficiency with investor protection.

United StatesFinance and Banking

On October 9, 2026, the Securities and Exchange Commission (the “SEC”) proposed amendments to Rule 17a-7 under the Investment Company Act of 1940, as amended (the “Investment Company Act”), that would expand the types of securities eligible for cross trading between registered investment companies (“registered funds”) and certain affiliated persons. The proposed amendments are a welcome development for the industry, and effectively serve to reverse an unexpected regulatory development from 2020 that significantly narrowed the scope of securities eligible for Rule 17a-7 cross trading. In addition, the proposal would generally modernize the rule’s requirements (which could result in more efficient portfolio management and reduced transaction costs for registered funds and their shareholders) while maintaining appropriate safeguards against conflicts of interest and affiliated-party overreach. More specifically, the proposed amendments would, among other things, permit cross trading in

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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