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Posts Tagged ‘ Section 28(e) ’

27 September
Posted in Uncategorized

Hedge Fund Soft Dollar Disclosure Practices

 Disclosure Under Greater Scrutiny Both registered investment advisers and unregistered managers are generally required to make complete and accurate disclosures with respect to their investment programs.  The obvious purpose of this requirement is to provide potential investors and clients with accurate information so the investors can make informed decision about the [...]

20 November
Posted in Legal Resources

Hedge Fund Soft Dollars – Permitted Soft Dollar Practices

This memorandum contains information regarding eligible and ineligible uses of soft dollars within the safe harbor found under Section 28(e) of the Securities Exchange Act of 1934.  This memo is structured in three parts: (i) discusses, generally, the eligibility of research services; (ii) discusses, generally, the eligibility of brokerage activities; [...]

14 October
Posted in Laws

Section 28(e) of the Securities Exchange Act of 1934

Section 28(e) – Exchange, broker, and dealer commissions; brokerage and research services (1) No person using the mails, or any means or instrumentality of interstate commerce, in the exercise of investment discretion with respect to an account shall be deemed to have acted unlawfully or to have breached a fiduciary [...]

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