i guess soft dollars was more level 2, but i have seen questions on it in level 3. anyway, i seem to remember a question where the manager used the client’s commish to get access to great research on tax-free investing. it didn’t benefit the account whose commish was used. it benefitted other accounts. i think they said that was ok. doesn’t have to be one-to-one of the soft dollar benefitting the client. surprised me… although it wasn’t benefitting the manager. so that wasn’t an issue. at least they seemed to make that clear.
It’s OK as long as the client will eventually benefit from other research.