Pay For Your Bloomberg with Bond Trades
December 1, 2009
Money Managers, this month Bloomberg created a commission field on its bond trade ticket. The purpose is to enable the use of commissions to obtain research under Section 28(e) of the Exchange Act. Fixed income trades can be used to obtain research; however, the broker/dealer must be non-positioning, acting as "Agent Only."
Learn How:
· You can use brokerage commissions from an eligible broker dealer acting as an "agent only" to acquire fixed income 3rd party research
· You can use brokerage markups/markdowns with eligible "certain riskless principal" transactions to acquire fixed income 3rd party research
· You can use sales concessions on new issues to pay for fixed income 3rd party research
· You can receive better execution from an inter-dealer broker than the sales department of a bank dealer
· The Global Settlement of 2003 dramatically shifted research from proprietary to independent 3rd party platforms
· The SEC states that research is the FOUNDATION of the money management industry
· Payment for research services with portfolio brokerage is the appropriate manner to obtain research
· The proposed Form ADV does not distinguish between proprietary and 3rd party research with regard to soft dollar disclosure
· The proposed Form ADV includes both commissions and markups/markdowns as transactions that can be used to obtain research
Presenters:
Tom Shugrue, President
CCM
Patrick Freeland, Chief Compliance Officer
CCM
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