[9810]
April 1, 1998
TO: BOARD OF GOVERNORS No. 18-98
INVESTMENT ADVISER ASSOCIATE MEMBERS No. 7-98
INVESTMENT ADVISER MEMBERS No. 9-98
PRIMARY CONTACTS - MEMBER COMPLEX No. 22-98
SEC RULES MEMBERS No. 24-98
RE: INSTITUTE PAPER ON BROKERAGE ALLOCATION PRACTICES
______________________________________________________________________________
Attached is a copy of an Institute paper entitled “Brokerage Allocation Practices.”
Soft dollar arrangements as well as other brokerage allocation practices have been, and likely will
continue to be, the subject of public and regulatory focus. The Institute prepared the enclosed paper to
provide guidance to advisers to both fund and non-fund clients to ensure that their brokerage allocation
practices are consistent with the best interests of their clients and with regulatory standards. As noted,
the paper is not intended as a substitute for appropriate professional advice with respect to the
applicability of laws and regulations in particular circumstances, nor is it intended to express any legal
opinion or conclusion concerning any specific action, policy or procedure.
The paper was developed by a special industry task force, with the assistance of outside counsel,
Kirkpatrick & Lockhart. In addition, drafts of the paper were reviewed by members of the SEC Rules
Committee and the Investment Advisers Committee.
In recent years, the Institute has prepared two other papers to provide practical guidance to
industry members on different topics. These papers, entitled “Investments in Derivatives by Registered
Investment Companies” (August 1994) and “Valuation and Liquidity Issues for Mutual Funds”
(February 1997), are available by contacting the InstituteGs library services at 202/326-5872.
Should you have any questions regarding the paper or on any related issues you may direct them
to me at (202) 326-5815 or Amy Lancellotta at (202) 326-5824.
Craig S. Tyle
General Counsel
Attachment
Note: Not all recipients of this memo will receive an attachment. If you wish to obtain a copy of the
attachment referred to in this memo, please call the Institute's Library Services Division at (202)326-
8304, and ask for this memo's attachment number: 9810.