RegAlert2006-08-11
Added · Updated
SEC Division of Trading and Markets no-action letter: Wachovia Securities
Wachovia Securities LLC and Wachovia Securities Financial Network LLC request an exemption from Rule 10b-10(a) to deliver periodic quarterly statements containing all required trade information in lieu of trade-by-trade confirmations for clients in the Private Investment Management, Fundamental Choice, and Quantitative Choice Programs. Eligible clients must provide explicit written or electronic consent to waive immediate confirmations, while the firms must continue to generate and retain trade-by-trade records internally and provide access to transaction data via website or phone by the next business day. The firms are prohibited from requiring this election, charging additional fees for the change, or acting as principal in these transactions, and must continue sending standard confirmations to any client who does not opt out.
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John V. Ayanian
Partner
202.739.5946 jayanian@morganlewis.com
August 11, 2006
Ms. Catherine McGuire
Chief Counsel
Division of Market Regulation
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Request for Exemption from Rule 10b-10(a) for Wachovia Securities Dear Ms. McGuire:
On behalf of Wachovia Securities, LLC ("WSLLC") and Wachovia Securities Financial Network, LLC (“WSFN”) (together, “Wachovia Securities”), we request an exemption, pursuant to Rule 10b-10(f) of the Securities Exchange Act of 1934, as amended ("Exchange Act"), from the trade-by-trade confirmation delivery requirements of Rule 10b-10(a) for securities transactions in the accounts of the respective clients of each of WSLLC and WSFN in the Private Investment Management (“PIM”), Fundamental Choice (“FC”) and Quantitative Choice (“QC”) Programs (collectively, “Program Clients”). WSLLC and WSFN request this relief to permit them to send requesting Program Clients, in lieu of trade-by-trade confirmations, a periodic statement not less often than quarterly that contains all of the information required by Rule 10b-10(a). WSLLC and WSFN are affiliated broker-dealers registered with the Securities and Exchange Commission ("Commission") under Section 15(b) of the Exchange Act. WSLLC is a member of all principal national securities exchanges and the NASD, Inc. (“NASD”), and WSFN is a member of the NASD. WSLLC and WSFN are also affiliated investment advisers, each registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). As registered investment advisers, each of WSLLC and WSFN are fiduciaries for their respective Program Clients. The PIM, FC and QC Programs WSLLC and WSFN make available to their respective clients the PIM, FC and QC Programs (hereinafter "Programs").1 The Programs are investment advisory programs, wherein WSLLC 1 WSFN has entered into an agreement with WSLLC, pursuant to which WSLLC will act as service provider to WSFN with respect to the Programs. WSFN, however, will act as the sole investment adviser and executing broker for securities transactions in the accounts of its own Program Clients.
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