Brokerage Commission Arrangements

With the understanding that money managers need detailed and unbiased third-party research, CCM unbundles execution and research from total fixed income trading costs and directs a portion of the commission to designated research vendors providing independent, unbiased third party research. In keeping with SEC guidelines for research providers under the Section 28(e) safe harbor, CCM is a non-positioning broker acting as an agent and riskless principal in fixed income securities, with all commissions fully transparent.

Approved by Congress in recognition of the fact that money managers trading only on the basis of cost would be deprived of the research needed to make informed decisions, the safe harbor effectively establishes that the money manager can still fulfill their fiduciary duty while offering a best execution capacity.

Client Commission Arrangements under Section 28(e) help money managers fulfill their fiduciary duty to acquire third party research needed to make prudent investment decisions.

CCM works with clients to assure that all aspects of Client Commission Arrangements are fully 28(e)-compliant.

Testimonials

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