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SEC Confirmation that Fixed-Income Commissions Can Satisfy the Section 28(e) “Soft Dollars” Safe Harbor

By Bryan Daly & Marc E. Elovitz on October 29, 2013
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Registered investment advisers in the process of planning an annual compliance review will generally include a review of their best execution processes and their use of so-called “soft dollars.” Managers that trade in fixed-income securities may find it useful to review a no-action letter issued earlier this year by the Division of Trading and Markets of the U.S. Securities and Exchange Commission. This letter, granted to Carolina Capital Markets Inc.,[1] confirmed that institutional asset managers, in reliance on the safe harbor of Section 28(e) of the Securities Exchange Act of 1934, may purchase eligible third-party brokerage and research services with commissions generated by qualifying transactions in fixed-income securities.

Click here to read more about the background on the Section 28(e) safe harbor, the eligibility of fixed-income commissions under the Section 28(e) safe harbor and the 2013 Carolina Capital No-Action Letter.

Photo of Bryan Daly Bryan Daly

Bryan Daly is a partner in the Governmental and White Collar Defense Practice Groups and works out of the firm’s Los Angeles office. Bryan is a former Assistant U.S. Attorney for the Central District of California, Criminal Division, Public Corruption and Government Fraud…

Bryan Daly is a partner in the Governmental and White Collar Defense Practice Groups and works out of the firm’s Los Angeles office. Bryan is a former Assistant U.S. Attorney for the Central District of California, Criminal Division, Public Corruption and Government Fraud Section.

Read more about Bryan DalyEmail
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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Regulatory & Compliance Update
  • Organization:
    Schulte Roth & Zabel LLP

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