Fee rebates

A peer asks us to anonymously post this query.

Can you please help him? Thanks, Carl

"A Rep from another firm mentioned that fee rebates would be permissible for an adviser to move assets from an SMA account into a mutual fund provided the following criterion are met:

* All investors to the mutual fund pay the same expense ratio.

* The rebates are distributed from the Adviser - not from the fund.

* The Adviser acts as fiduciary and does this to benefit the investor

* The rebates are disclosed the ADV.

Please share your thoughts and concerns about the appropriateness of this arrangement. Thank you."

Carl Ayers
Publisher, Regulatory Compliance Watch
Two Washingtonian Center
9737 Washingtonian Blvd., Suite 502
Gaithersburg, MD 20878
Link to me via LinkedIN
Fax: 301-287-2121
Our Video Channel: http://www.regcompliancewatch.com/Home/Info/Videos
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