Soft Dollars Arrangement

2010 Webinar - Soft Dollar Arrangements: Commission Sharing vs. Traditional Soft Dollar Arrangements & Other Current Issues

Soft Dollar Arrangements: Commission Sharing vs. Traditional Soft Dollar Arrangements & Other Current Issues
June 3, 1:00 pm – 2:15pm EDT

Presenter: Steven W. Stone, Morgan, Lewis & Bockius LLP
Moderator: Monique S. Botkin, Senior Counsel, IAA


The SEC’s 2006 soft dollar interpretive guidance has resulted in a shift in the structure of Section 28(e) arrangements from traditional soft dollar arrangements toward commission sharing agreements. However, many details of the SEC’s guidance remain subject to interpretation. This webinar will address requirements and best practices for advisers in satisfying the safe harbor requirements in structuring commission sharing agreements, including satisfying the “effecting” and “provided by” elements of the safe harbor. The session will also address other current soft dollar issues facing advisers, including client “no soft dollars” bars, use of aggregators, protecting and transferring soft dollar balances, client rebates, sharing research with affiliates, cross border trading, and disclosure considerations.

STEVEN W. STONE is the leader of Morgan Lewis’s Investment Management Practice Group. His practice focuses on broker-dealer and investment manager regulation and enforcement defense and regulation of the securities markets, and he represents major investment banks, broker-dealers and investment managers in a wide range of matters. Mr. Stone frequently advises trading desks of both broker-dealers and investment managers on a range of issues. He counsels clients on a wide variety of regulatory and transactional matters, including development of new products and services; federal and state registration and compliance issues; SEC, NASD and state investigations; and enforcement actions; mergers and acquisitions and joint ventures involving broker-dealers and investment advisers; interpretive and “no-action” letter requests; insider trading issues; and related matters.


To purchase a recording of this webinar, please complete a payment form and return it to IAA Director of Meetings and Events Lisa Gillette at or at (202) 293-4222.