Abstract
In this time of heightened regulatory attention to potential conflicts of interest and the transparency of transaction costs in buying and selling portfolio securities, soft dollar practices have come under intense scrutiny. Regulators are asking whether the use of soft dollars should be eliminated, while some in the investment management industry have begun to restrict their own practices or even voluntarily discontinue them. What should you be doing now? Should you be evaluating your soft dollar arrangements? Do you have effective soft dollar policies and procedures in place to maintain compliance with applicable regulatory requirements? Who are the primary beneficiaries of your soft dollar arrangements? This article outlines the background and regulatory considerations applicable to soft dollar arrangements, and discusses the issues money management firms should consider in reviewing their soft dollar practices.
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