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Question #119

Has the SEC ever provided guidance, informal or formal, on whether the Separate Accounts exemption under Regulation M, Rule 105, would apply to two or more separately managed accounts (SMAs), which accounts are managed by the same adviser/manager?

Assume that the manager executed the relevant trades in all cases. For example, Wealth Manager Capital (WMC) manages SMAs for both Teachers Pension A (TPA) and Teachers Pension B (TPB). WMC executed short equities trades for TPA during the restricted period for stock X (without making any curative bonafide purchases), then participating in the offering on behalf of TPB. Also, assume that there are no info barriers and the same personnel of the WMC were used in general.



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