MFA - Managed Funds Association

05/28/2026 | Press release | Archived content

MFA submits letter to the SEC with request to the separate accounts exception in Rule 105 of Reg M

MFA submitted a letter to the Securities and Exchange Commission (SEC) recommending clarity on the operation of the Separate Accounts Exception.

MFA recommends the following:

  • The Commission provide clarification regarding the "Separate Accounts Exception" in Rule 105 to more clearly delineate the scope of permissible activities by senior managers and other individuals who have access to information of multiple separate accounts as part of their oversight responsibilities, with the goal of aligning the Commission's current interpretation of Rule 105 with the interpretation in the 2007 Adopting Release..
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