Regulation of Advisers - Morgan, Lewis & Bockius

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Conflicts • Soft Dollars and CSAs - 28(e) “safe harbor” - Global arrangements - Portability of credits - Protection of accrued credits - Disclosures – “bundled” research and services vs. third party • Directed brokerage - Client directed - Commission recapture - Brokerage for referrals and sales (2013 SEC focus area – payments by advisers to entities that distribute mutual funds) • Trade errors © Morgan, Lewis & Bockius LLP 8
Sidebar on ERISA • Disclosure is not enough (generally) • Prohibited Transactions & PTCEs - Principal trades (PTE 75-1) - Agency trades (PTE 86-128) - Cross trades © Morgan, Lewis & Bockius LLP 9
Page 1 and 2: Regulation of Advisers (Part II): B
Page 3 and 4: Bedrock Concepts and Requirements
Page 5 and 6: Best Execution • Both quantitativ
Page 7: Conflicts • Principal and agency
Page 11 and 12: Public Equity • Thinly traded sec
Page 13 and 14: Retail Investor Platforms • Wrap
Page 15 and 16: Mechanics / Operations • Due dili
Page 17 and 18: This material is provided as a gene

Regulation of Advisers - Morgan, Lewis & Bockius

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