Cross-Trading at a Crossroads

  • Amy Doberman
  • 1.24.2025

In an article published in The Investment Lawyer, Partner Amy Doberman explains the history of cross-trading guidance and relief, the subsequent reluctance to adopt cross-trading and the eventual interpretive positions and statements that effectively ended cross-trading practices, among other topics.

Excerpt: “Cross-trading fixed income securities under appropriate circumstances would enable funds and their shareholders to save a substantial amount in transaction costs—by some estimates hundreds of millions of dollars annually. Indeed, by refusing to address this issue and provide clarity around permissible cross-trading, the SEC effectively shifts a substantial amount of revenue for securities dealers (and without any benefit to fund shareholders). This results in ineffective and inconsistent regulation, especially given the oblique permission to continue to cross-trade municipal bonds (given that UMB and Federated have not been withdrawn), which are often far less liquid and have less price transparency than many corporate bonds.”

Read the full article.