I’m really confused by question 3 in Schweser’s EOC questions covering the Asset Manager Code.
"World Investment Advisers is a large sales force of registered investment representatives which has affiliations with many firms that produce investment-related products, such as mutual funds, life insurance, mortgages, and annuities. World Investment Advisers representatives market these products to the investing public and are able to pick and choose the best products for any particular client’s needs. One of the affiliated firms is a mutual fund company called Life Investors. The company has a special arrangement with World Investment in which World Investment has identified Life Investors as a “preferred product provider” in their internal marketing materials to their investment representatives. In return for this preferential treatment by World Investment, Life Investors has reimbursed World Investment for the cost of these marketing materials out of the trading commissions generated from the sale of Life Investors mutual funds by World Investment sales representatives. Which of the following statements regarding any violations of the Code is most correct? World Investment violated the Code relating to:"
a) Accepting gifts of minimal value because Life Investors is paying for the marketing materials that could influence World Investment’s representatives
b) having a reasonable and adequate basis for making investment decisions.
c) soft commissions by using client brokerage to pay for marketing materials.
The answer is C, and the explanation is essentially just that soft dollars shouldn’t be used to pay for marketing materials. However, I’m focused on the bold. I don’t understand this question at all. This is the Asset Manager Code, and World Investment is effectively a broker, so isn’t Life Investors, the Asset Manager, the one inappropriately using soft dollars?
I’d really appreciate it if anyone can help me correctly think about this problem. Thanks!