Fiduciaries need detailed and unbiased third-party research to make prudent investment decisions.  On CCM’s client commission arrangements platform, we unbundle execution and research from total fixed income commission costs and direct a portion of the commission to designated research vendors.  In keeping with SEC guidelines for research providers under the Section 28(e) safe harbor, CCM is a non-positioning broker acting on an agency or riskless principal basis.  The safe harbor protects money managers from a breach of fiduciary duty solely on the basis that they paid more than the lowest available commission rate. Congress recognized that requiring money managers to trade only on the basis of cost would deprive them of the research they need to make informed decisions. Money managers act within the safe harbor if they determine in good faith that the amount of commission is reasonable in relation to the value of the brokerage and research services rendered.

Click here to view the 28(e) Navigator