SEC Seeks Extension for Rule 17a-10 Data Collection
Published Date: 9/2/2025
Notice
Summary
The SEC is asking to keep collecting info for Rule 17a-10, which lets certain fund advisers trade with related funds under strict rules. This mainly affects investment subadvisers who must follow clear contract limits to avoid conflicts. No new costs or big changes—just a smooth extension to keep things running by September 2025.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 2 costs, 1 mixed.
Subadvisers must add contract clauses
If you are an investment subadviser or a fund that wants to rely on Rule 17a-10, your advisory contracts must include clauses that (1) prohibit subadvisers from consulting with each other about fund transactions and (2) limit each subadviser to advice for discrete portions of the fund. Including these contract terms is necessary to obtain the exemption in Rule 17a-10 that allows certain affiliated transactions.
Estimated annual compliance cost
The SEC staff estimates about 49 funds enter into new subadvisory agreements each year. The rule allocates 0.75 attorney hours per new fund for Rule 17a-10, totaling 37 burden hours annually and an associated annual cost of approximately $18,907.
No continuing burden for existing funds
The SEC staff assumes funds that adopted subadvisory contracts when Rule 17a-10 was adopted in 2003 already included the required contract terms, so those existing funds have no continuing burden from this rule. This means only newly formed subadvised funds or funds that enter into new subadvisory contracts are expected to incur the one-time amendment burden.
Submitted responses are not confidential
If you provide information to the SEC under this collection (Rule 17a-10), your responses will not be kept confidential. That means information submitted to obtain the benefit of relying on the rule can be viewed by the public or used by the agency.
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Key Dates
Department and Agencies
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