SEC Issues Interpretive Release on Soft Dollars

By: Jessica Forbes, Terrance J. O'Malley

On July 18, 2006 the SEC published formal guidance through an interpretive release that addresses the scope of "brokerage and research services" and client commission arrangements under Section 28(e) of the Securities Exchange Act of 1934. The guidance contained in the interpretive release likely impacts all discretionary investment managers to some degree. The major points addressed in the SEC interpretive release are summarized in this memorandum. 

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