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| Soft-Dollar Arrangements |
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Section 28(e) of the SEC Act of 1934 provides a safe harbor to investment managers who use the commission dollars of their advised accounts to obtain investment research and brokerage services ("soft dollar" research) by permitting such persons, under certain circumstances, to "pay up" for such services received from broker-dealers.
WJB provides its clients the opportunity to defer and bank a portion of each trade executed towards "soft dollar" commissions in order to meet research expenses in accordance with generally accepted accounting principles. WJB is permitted to then pay an associated vendor's invoice with the deferred "soft dollar" commissions provided that the vendor to whom the "soft dollar" commissions are being paid is an independent vendor. Typically, clients will have the company pay an invoice on either a monthly or quarterly basis. |
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