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U.S. Securities and Exchange Commission


Division of
Trading and Markets


About the Division

Broker-Dealers

Banks and Other Depository Institutions

Credit Rating Agencies

Exchanges

Over-the-Counter Markets

ECNs/Alternative Trading Systems

National Market System

Municipal Markets

Clearing Agencies

Transfer Agents

Additional Topics

Frequently Requested Documents

 

Division of Trading and Markets
Exemptive Orders and
Exemptive, Interpretive, and No-Action Letters

Important Note:  This page contains Division of Trading and Markets no-action letters dated on or after January 1, 2002. Division of Trading and Markets no-action letters issued before that date may be obtained by submitting a request for a paper copy. Selected letters issued before January 1, 2002 may appear in other places on this website.

Procedures applicable to requests for no-action and interpretive letters are available in Securities Act Release No. 6269. You may call 202-551-5777 or send an email to tradingandmarkets@sec.gov with any questions about these procedures.




Subject Categories for No-Action Letters
List of No-Action Letters by Subject Category

Associated Persons of Broker-Dealers (including Registration, Bars, Statutory Disqualification, and Rule 19h-1)

"Bank" – Definition

Broker-Dealer Books and Records and Reporting Requirements

Broker-Dealer Customer Protection Rule - Rule 15c3-3

Broker-Dealer Net Capital Requirements – Rule 15c3-1

Broker-Dealer Registration (including Form BD Interpretations, Withdrawal from Broker-Dealer Registration and Successors)

Broker-Dealer Registration –
Clerical and Ministerial Activities

Broker-Dealer Registration – Exemptions from Registration

Broker-Dealer Registration – Finders

Broker-Dealer Registration – Foreign Broker-Dealers (including International Activities of U.S. Broker-Dealers and Rule 15a-6)

Broker-Dealer Registration –
Limited Broker-Dealer Functions

Broker-Dealer Registration – Networking
(Depository Institutions and Insurance Companies)

Broker-Dealer Registration – Other

Clearing Agencies

Confirmations – Rule 10b-10

Disclosure of Order Execution Information – Rule 605 (formerly Rule 11Ac1-5)

Disclosure of Order Routing Information – Rule 606 (formerly Rule 11Ac1-6)

Dissemination of Quotations – Rule 602 (formerly Rule 11Ac1-1)

ECNs ("Electronic Communications Networks")

Exchange Member Trading – Section 11(a)

Extension of Credit on New Issues – Section 11(d)

Foreign Market Communications with QIBs

Keep and Preserve Paper Copies – Rule 17a-1

Multiple Section Relief
(e.g. exchange traded funds and other basket products)

Municipal Auction Rate Securities

Municipal Securities Brokers and Dealers

Municipal Securities Disclosure – Rule 15c2-12

Penny Stock Rules

Regulation E

Regulation S-P

National Market System Rules, Miscellaneous – Section 11A

Other

Regulation SHO

Regulation T

Risk Assessment Rules – Rules 17h-1T and 17h-2T

Rule 10a-1, Short Sales

Rule 10b-18, Issuer Repurchases

Rule 12d2-2, Removal from Listing and Registration

Rule 14e-5, Purchases Outside a Tender Offer

Rule 15c2-11, Initiation of Quotations

Rule 17Ad-17, Lost Securityholders and Unresponsive Payees

Rule 101 of Regulation M,
Activities By Distribution Participants

Rule 102 of Regulation M,
Activities By Issuers and Selling Security Holders During a Distribution

Section 31 Fees

"Securities" – Other

Security Futures Products Brokers and Dealers

Shad-Johnson Letters

Transfer Agents

Vendor Display Rule Interpretive Guidance

Selected Class Letters

Alphabetical List of No-Action Letters

Chronological List of No-Action Letters
Interpretive Letters

Associated Persons of Broker-Dealers (including Registration, Bars, Statutory Disqualification, and Rule 19h-1)

Broker-Dealer Customer Protection Rule - Rule 15c3-3

Exchange Member Trading – Section 11(a)

Financial Accounting Standards No. 150

Multiple Section Relief (e.g. exchange traded funds and other basket products)

Municipal Securities

Rule 10b-10, Confirmations

Rule 10b-18, Issuer Repurchases

Securities – Definition – Government Securities

Securities – Definition – Specialized Products

Exemptive Orders

Date Details
October 7, 2014 UBS AG
September 18, 2014 Banco Santander, S.A.
August 26, 2014 Order Granting a Limited Exemption from Rule 102(a) of Regulation M to Jones Lang LaSalle Income Property Trust Pursuant to Rule 102(e) of Regulation M
See also:  Incoming Letter
June 4, 2014 Deutsche Bank Aktiengesellschaft
May 14, 2014 Barclays PLC
May 7, 2014 National Bank of Greece
Mar. 25, 2014 Lloyds Banking Group plc
Mar. 6, 2014 Lloyds Banking Group plc
Nov. 7, 2013 Barclays PLC
Sep. 16, 2013 Lloyds Banking Group plc
Jul. 31, 2013 Barclays PLC
Jul. 17, 2013 IMH Financial Corporation
Dec. 18, 2012 Order Granting Limited Exemptions from Exchange Act Rule 10b-17 and Rules 101 and 102 of Regulation M to ALPS ETF Trust, ALPS/GS Momentum Builder Growth Markets Equities and U.S. Treasuries Index ETF, ALPS/GS Momentum Builder Multi-Asset Index ETF, and ALPS/GS Momentum Builder Asia ex-Japan Equities and U.S. Treasuries Index ETF Pursuant to Exchange Act Rule 10b-17(b)(2) and Rules 101(d) and 102(e) of Regulation M (Release No. 34-68459; File No. TP 13-02)
See also:  Incoming Letter
Dec. 14, 2012 Order Granting Limited Exemptions from Exchange Act Rules 101 and 102 of Regulation M to Shares of JPM XF Physical Copper Trust Pursuant to Exchange Act Rules 101(d) and 102(e) (Release No. 34-68439; File No. TP 11-10)
See also:  Incoming Letter
Sep. 7, 2012 Order Granting Limited Exemptions from Exchange Act Rule 10b-17 and Rules 101 and 102 of Regulation M to iShares, Inc. and iShares MSCI Frontier 100 Index Fund Pursuant to Exchange Act Rule 10b-17(b)(2) and Rule 101(d) and 102(e) of Regulation M (Release No. 34-67804; File No. TP 12-10) See also:  iShares, Inc. Request Letter
Aug. 8, 2012

Order Granting Business Development Corporation of America a Limited Exemption from Rule 102(a) of Regulation M pursuant to Rule 102(e) (Release No. 34-67620; File No. TP 12-12) See also:  Business Development Corporation of America Request Letter

Jun. 19, 2012 Order Granting a Limited Exemption from Exchange Act Rule 10b-17 to Certain Actively Managed Exchange-Traded Funds Pursuant to Exchange Act Rule 10b-17(b)(2) (Release No. 34-67215; File No. TP 11-07) See also:  PIMCO ETF Trust Request Letter
Jun. 7, 2012 Order Granting FS Investment Corporation II a Limited Exemption from Rule 102(a) of Regulation M pursuant to Rule 102(e)
(Release No. 34-67163; File No.:   TP 12-11) See also:  FS Investment Corporation II Request Letter
Apr. 16, 2012 WisdomTree Emerging Markets Corporate Bond Fund
Mar. 1, 2012 PIMCO Total Return Exchange-Traded Fund
Dec. 16, 2011 Claymore Exchange-Traded Fund Trust
Dec. 16, 2011 AdvisorShares Trust
Nov. 3, 2011 iShares Trust Equity-Index Exchange Traded Fund
Aug. 29, 2011 WisdomTree Global Real Return Fund
Aug. 16, 2011 WisdomTree Asia Local Debt Fund
Aug. 16, 2011 WisdomTree Managed Futures Strategy Fund
Jun. 7, 2011 Bank of Ireland
May 24, 2011 Claymore Exchange-Traded Fund Trust
Apr. 8, 2011 Bank of Montreal
Feb. 7, 2011 NYSE LLC and NYSE Amex LLC
Feb. 7, 2011 Sumitomo Mitsui Financial Group, Inc.
Dec. 16, 2010 AdvisorShares Trust Actively Managed ETF
Oct. 28, 2010 Banco Bilbao Vizcaya Argentaria, S.A.
Oct. 12, 2010 BATS Y-Exchange
Sep. 22, 2010 PIMCO ETF Trust - Actively Managed ETF
Sep. 16, 2010 Deutsche Bank Aktiengesellschaft
Sep. 2, 2010 WisdomTree Trust Dreyfus Commodity Currency Fund an Actively Managed ETF
Aug. 19, 2010 The Toronto-Dominion Bank
Aug. 17, 2010 iShares Trust Equity-Index Exchange Traded Funds
Aug. 6, 2010 WisdomTree Trust Emerging Markets Local Debt Fund an Actively Managed ETF
Jul. 2, 2010 AdvisorShares Mars Hill Global Relative Value Actively Managed ETF
Jun. 18, 2010 AdvisorShares Trust Actively-Managed ETF, WCM/BNY Mellon Focused Growth ADR
May 27, 2010 WisdomTree Trust Real Return Actively Managed ETF
May 26, 2010 EDGA Exchange
May 26, 2010 EDGX Exchange
May 4, 2010 U.S. One Trust Actively-Managed ETF of ETFs
Apr. 22, 2010 Bank of Ireland
Apr. 1, 2010 Highbury Financial Inc.
Feb. 25, 2010 BATS Exchange, Inc.
Feb. 5, 2010 Vimpelcom Ltd.
Jan. 27, 2010 Grail Advisors ETF Trust Actively Managed Fixed Income ETF
Dec. 31, 2009 BNY Mellon
Dec. 23, 2009 Cash Offer of Franco-Nevada Corporation for Common Shares of International Royalty Corporation
Dec. 23, 2009 WisdomTree Trust Index-Based ETF of ETFs
Nov. 19, 2009 ING
Nov. 12, 2009 iShares Diversified Alternatives Trust Actively-Managed Commodity-Based Investment Vehicle
Nov. 10, 2009 PIMCO ETF Trust Actively Managed Fixed Income ETF
Nov. 2, 2009 Lloyds Banking Group plc
Oct. 29, 2009 Chicago Board Options Exchange, Inc.
Sep. 20, 2009 AdvisorShares Trust Actively-Managed ETF of ETFs and Exchange Traded Products
Aug. 28, 2009 Chicago Board Options Exchange
Aug. 28, 2009 NASDAQ OMX BX, Inc.
Aug. 21, 2009 Federal Reserve Board New York
Aug. 20, 2009 PIMCO ETF Trust
Jun. 1, 2009 PIMCO ETF Trust
May 6, 2009 Grail Advisors ETF Trust
Apr. 20, 2009 FS Investment Corporation
Apr. 20, 2009 Lloyds Banking Group plc
Mar. 25, 2009 Index IQ ETF Trust
Mar. 5, 2009 Shinhan Financial Group Co., Ltd.
Feb. 18, 2009 The Royal Bank of Scotland Group plc and ABN AMRO Holding N.V.
Feb. 17, 2009 Federal Reserve Bank of New York
Dec. 22, 2008 Banco Santander, S.A.
Sep. 22, 2008 Auction Rate Securities — Global Exemptive Relief
Jun. 24, 2008 Republic of Uruguay
May 16, 2008 UBS AG
Nov. 16, 2007 Exemption Under Rule 608(e) of Regulation NMS under the Securities Exchange Act of 1934 from Certain Provisions of the "Plan for the Purpose of Creating and Operating an Intermarket Option Linkage" Relating to the Representation of Principal Acting as Agent Orders on the American Stock Exchange
Jul. 30, 2007 Boston Stock Exchange, Inc.'s Request for Exemption Under Rule 608(e) of Regulation NMS Under the Securities Exchange Act of 1934 from Certain Provisions of the Plan for the Purpose of Creating and Operating an Intermarket Option Linkage Relating to the Execution of Option Transactions During Crossed Markets
Feb. 1, 2007 NYSE Request for Exemptions from Certain Provisions of the Intermarket Trading System ("ITS") Plan
Jan. 30, 2007 Extension of the Exemption from the Order Protection Provisions of the Intermarket Trading System ("ITS') Plan with Respect to Single-Priced Closing Transactions
Jan. 30, 2007 Extension of the Exemptions for Initial Version of the American Stock Exchange's AEMI Hybrid Market Trading Platform
Jan. 30, 2007 Extension of the Exemptions from Certain Provisions of the Intermarket Trading System Plan
Jan. 30, 2007 Extension of the Exemption from the Order Protection Provisions of the Intermarket Trading System ("ITS") Plan with Respect to Single-Priced Closing Transactions
Jan. 30, 2007 Extension of the Exemption under Rule 608(e) of Regulation NMS Under the Securities Exchange Act of 1934 from Certain Provisions of the Intermarket Trading System Plan
Nov. 14, 2006 Philadelphia Stock Exchange, Inc.'s Request for Exemptions under Rule 608(e) of Regulation NMS Under the Securities Exchange Act of 1934 from Certain Provisions of the Intermarket Trading System Plan
Nov. 3, 2006 Request for Exemptions for Initial Version of the American Stock Exchange's AEMI Hybrid Market Trading Platform
Jul. 27, 2006 Chicago Board Options Exchange Incorporated's Request for Exemption from Trade-Through Provisions of the Plan for the Purpose of Creating and Operating an Intermarket Option Linkage Relating to the Automatic Execution of Option Transactions During Crossed Markets
Apr. 6, 2006 Request for Exemption from Rule 601(a)(Z)(iv) and 601(b)(l) under the Securities Exchange Act of 1934 for the NYSE Arca Inc.'s Portfolio Crossing Service
Nov. 18, 2005 Exemption Under Rule 608(e) of Regulation NMS under the Securities Exchange Act of 1934 from Certain Provisions of the "Plan for the Purpose of Creating and Operating an Intermarket Option Linkage" Relating to the Representation of Principal Acting as Agent Orders on the Chicago Board Options Exchange
Feb. 13, 2003 Order Extending Temporary Exemption of Banks, Savings Associations, and Savings Banks from the Definition of "Dealer" under Section 3(a)(5) of the Securities Exchange Act of 1934
Mar. 18, 2002 Order Under Section 36 of the Securities Exchange Act of 1934 Granting Exemptions From Certain Provisions of the Act and Rules Thereunder
Dec. 20, 2001 Extending Broker-Dealer Exemption from Sending Financial Information to Customers
Oct. 10, 2001 Government Securities Reconciliations
Sep. 28, 2001 Exemptive Relief to Respond to Market Developments, Pursuant to Section 36(a)(1) of the Securities Exchange Act of 1934
Sep. 28, 2001 Re: Government Securities Reconciliations
Sep. 24, 2001 Re: Government Securities Reconciliations
Jan. 12, 2000 Regulation M — Sovereign Bond Exemption

 

http://www.sec.gov/divisions/marketreg/mr-noaction.shtml


Modified: 11/14/2014