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ARTICLE · 05 JANUARY 2010

SEC Extends Temporary Rule For Principal Trades With Clients

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On December 23, 2009, the Securities and Exchange Commission ("SEC") extended, on a temporary basis, Rule 206(3)-3T under the Investment Advisers Act of 1940, as amended (the "Advisers Act"), for principal trades with clients of investment advisers who are also registered broker-dealers.

United StatesStrategy

Article by John A. Brunjes , Cheri L. Hoff , Robert S. Frenchman , Julian Rainero and Genna N. Garver

On December 23, 2009, the Securities and Exchange Commission ("SEC") extended, on a temporary basis, Rule 206(3)-3T under the Investment Advisers Act of 1940, as amended (the "Advisers Act"), for principal trades with clients of investment advisers who are also registered broker-dealers. Originally adopted in 2007, Rule 206(3)-3T was set to expire on December 31, 2009. The SEC has adopted Rule 206(3)-3T in the same form as adopted in 2007, except that the rule will now expire on December 31, 2010, absent further action by the SEC.

Rule 206(3)-3T provides an alternative means for investment advisers who also are registered broker-dealers to meet the requirements of Section 206(3) of the Advisers Act when engaging in principal transactions with clients. Pursuant to Section 206(3), it is unlawful for any investment adviser "acting as a principal for his own

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