Would the requested relief raise investor protection concerns?
The sweep accounts service that the Exchange Act ยง3(a)(4)(B)(v) authorizes banks to conduct without registration does not raise investor protection concerns, and the same service would not raise investor protection concerns if conducted by ECCU or any other federally-insured credit union. The Commission recognizes the no-load money market funds bought and sold in these sweep accounts carry little investment risk.1 The Commission further recognizes that the distribution fees no-load funds may pay the institution offering the sweep service and the associated potential for conflicts of interest between the institution and investor are minimal.2 These low-risk aspects of no-load money market funds protect investors regardless of the type institution offering the sweep service, be it bank, thrift, or credit union, or the type of investor, be it institution or individual. In addition, we believe the structure of credit unions and NCUA’s regulatory oversight and enforcement powers should alle