A few questions on some of the wording. Hopefully this can serve as a decent refresher for people. 1) “Manager may not allocate a client’s brokerage based on the amount of Client referrals the IM receives from a broker” Translation: If I’m a client, my investment manager cannot allocate my brokerage dollars (used to pay commissions) to Broker X just because broker X gives my investment manager a lot of client referrals. Thus, they should instead allocate brokerage to brokers who provide best execution (lowest cost, ability to fill trades) and quality of the research received 2) “Manager must not use brokerage from another client to pay for a product or service purchased under the client-directed brokerage arrangement” Translation: If I’m client A, my investment manager cannot use my brokerage to pay for client B’s products or services. Client B has a client-directed brokerage arrangement where client b’s trades are directed to a specific or list of approved brokers. Any further insight on this? 3) Disclosure to clients and potential clients: Disclose that research may benefit clients other than those whose trades generated the brokerage in the first place. It is ONLY to address the trades conducted on a PRINCIPAL basis and not on an agency basis. (true?) 4) What is the “unbundling” of Proprietary Research Arrangements mean? Is it like tracing back to how each piece of proprietary research is obtained? 5) Can only claim compliance with SDS with statements with regards to specific client accounts, right? I’ve seen in questions that firms put out a general “we comply with SDS” and its alright, is this possible? Many thanks in advance
slight bump
bump!!!