Compliance
NEW RELEASE! July 16, 2006 SEC Guidance Regarding Client Commission Practices Under Section 28(e) of the Securities Exchange Act of 1934
2001 SEC Interpretation: Commission Guidance on the Scope of Section 28(e) of the Exchange Act
Securities Industry Association (SIA) Best Practices,
AIMR Research Credit Standards
AIMR Research Credit Online Learning Module
GAO Testimony on Mutual Funds
NASD Soft Dollar Study 11/2004
Commission Guidance Regarding Client Commission Practices Under Section 28(e) of the Securities Exchange Act of 1934
"Today, it remains true that, if the conditions of the safe harbor of Section 28(e) are met, a money manager does not breach his fiduciary duties solely on the basis that he uses client commissions to pay a broker-dealer more than the lowest available commission rate for a bundle of products and services provided by the broker-dealer (ie: anything more than "pure execution".)"
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