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To resolve the disconnect in approaches, in its 2017 no-action letter to SIFMA, the SEC advised that it would not recommend enforcement action to broker-dealers accepting cash payments for research from investmentmanagers which are required by Mifid II to pay for research from its own money as opposed to client commissions or ‘soft dollars’.
The active investmentmanager specialises in emerging and frontier markets trading across fixed income, credit and specialist equities. Due to lower demand, bulgebrackets will sometimes not cater for the particulars of what frontier traders are looking to execute. “Say
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