"Rule 204A-1 treats all securities as reportable securities, with five exceptions (i.e., direct obligations of the US Government, certain money market instruments and funds, certain mutual funds, and certain unit investment trusts) "designed to exclude securities that appear to present little opportunity for the type of improper trading that the access person reports are designed to uncover".However, transactions in exchange-traded funds are reportable securities according to an SEC response to National Compliance Services, Inc.'s 2005 request for no action guidance.