Section 546 of the Bankruptcy Code expressly provides certain limitations on the avoiding powers of a trustee in a bankruptcy case.  In particular, section 546(e) prohibits a trustee from avoiding a transfer that is a settlement payment made to a financial institution, except for transfers that are made with actual intent to defraud the debtor.  Essentially, 546(e) is a “safe harbor” provision for transactions that would otherwise be regulated by securities laws—which generally strive to limit transactions that disrupt the market of buying and selling securities.