Cross Trades And Principal Transactions – Recent SEC Guidance Relevant For CLO Managers
Our Investment Management Alert from earlier this month described to private fund advisers the importance of the Security Exchange Commission’s (SEC’s) Division of Examinations recent Risk Alert on cross trades and principal transactions. That Risk Alert, issued on July 21, 2021, included guidance and warnings based on more than 20 examinations of investment advisers that engaged in cross trades or principal transactions involving fixed income instruments. As SEC-registered advisers, the SEC’s observations and guidance are equally […]