Carl Ayers
This 1996 no-action letter helps to define what net-of-fee performance data means. The SEC, in this correspondence, held that it include all transaction costs and ...
The SEC's Division of Investment Management granted Ayco Company "no-action" relief based on its request not to include in its advisory contracts a provision that ...
Because Schwab purchases and redeems MFMP investment company shares on behalf of its customers solely as broker Section 22ds restrictions do not apply to Schwab's ...
This marks one of the earliest SEC interpretive releases related to guidance around use of soft dollars and best execution. This hails from 1986.