(3) the aggregate percentage of XYZ Brokerage derived from Client-Directed Brokerage Arrangements and the amount of the particular Client’s Directed Brokerage as a percentage of the aggregate, subject to a 10 percent de minimis amount. How do you interpret the meaning of the 10%?
If the particular client’s directed brokerage amount is less than 10% of the total client-directed brokerage amount of XYZ, you may opt not to disclose. If >10%, you must disclose to that client. o.o
So, if a client asks for additional information, but their brokerage share is < 10%, you don’t have to provide them with the additional information? XYZ must disclose in writing to its Clients that additional information in accordance with the CFA Institute Soft Dollar Standards concerning XYZ’s Soft Dollar and Client-Directed Brokerage Arrangements is available on request. Such additional information should include (1) a firmwide description of the products and services that were received from each broker pursuant to a Soft Dollar Arrangement, including the identity of those Brokers; (2) for a specific Client account, the total amount of Commissions generated for the Client through Soft Dollar Arrangements, detailed by Broker and reporting the amount of Brokerage directed by the Client to specific brokers; and (3) the aggregate percentage of XYZ Brokerage derived from Client-Directed Brokerage Arrangements and the amount of the particular Client’s Directed Brokerage as a percentage of the aggregate, subject to a 10 percent de minimis amount.
yes i would say so.