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SEC Guidance on Soft Dollars Safe Harbor (PDF)
White & Case LLP
Aug. 22, 2006
5 pages. Excerpt: In a speech on July 31, SEC Commissioner Roel C. Campos urged investment managers to 'err on the side of caution' in determining whether a service is 'research' within the scope of the safe harbor. He emphasized the fact that 'the context in which we are analyzing services is a safe harbor from a fiduciary duty -- not an entitlement.'
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