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Conflicts in a Rapidly Changing Fiduciary Landscape: Dually Registered or 'Hybrid Advisor' Challenges (PDF)
Pershing LLC
Mar. 29, 2016 12 pages. "For non-discretionary advice relationships, the DOL proposal would condition the availability to receive 12b-1 fees and other forms of revenue sharing upon satisfaction of the terms of a new 'best interest contract' or 'BIC' exemption. The conditions of the BIC exemption are numerous, highly technical and require the delivery of a 'best interest' promise to clients which exposes the firm and its representatives to litigation risk. In the case of discretionary advice relationships ... the receipt of 12b-1 fees, revenue sharing payments marketing fees, administrative fees, sub-TA fees and sub-accounting fees by hybrid firms with discretionary management authority over client IRA assets would be explicitly disallowed." MORE >> |
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