As a general matter, the SEC views directed brokerage arrangements as being outside the scope of Section 28(e): [T]ransactions for which the client has directed the money manager to a particular broker dealer in order to recapture a portion of the commis...
as a general matter, when a manager uses client commissions to pay for research, the manager does not violate his fiduciary duty under any federal or state law so long as the value of the research is reasonable in relation to the amount paid.6 4...