Soft Dollars

"The elimination of fixed commission rates thus raised questions for investment managers and the capital markets: for example, would managers be required by their fiduciary ...

Six years of 'no-action' relief around soft dollars research quietly end

"I am disappointed that the SEC staff has decided not to extend the MiFID II Relief for a modest additional period to accommodate these potential ...

Document your reviews. And each quarter, look at the budget-to-actual soft dollars’ expenditures. Be sure to disclose your soft dollars usage.

A peer shares the advisory firm's soft dollars checklist

Create a one-page summary outlining the terms of a soft dollars’ arrangement, including confirmation that the deal fits within the 28(e) safe harbor and have ...

A peer shares this checklist to help you

A peer shares this policy and procedure

The topic of soft dollars has lost some of its luster among examiners but enforcement actions continue to emerge from the agency. Expenses, however, remain ...

An Excel file courtesy of Karen Huey of Professional Compliance Assistance in Woodstock, Ga. The worksheets within this Excel file are designed to help you ...