The Securities and Exchange Commission has issued its guidance on client commission practices.  We are pleased to assist our clients with their commission management needs and answer any questions they may have regarding the SEC's new guidance.   Weeden understands the pressures placed on our buyside clients and makes available various methods for payment towards clients' external research commitments consistent with obtaining "Best Execution".
            * Commission Sharing Arrangements (CSA) - Ability for a money manager to pool commissions and instruct executing broker dealer (Weeden) to pay on their behalf vendors/broker dealers providing brokerage and research services in which the client intends such products and services to be eligible under the safe harbor of Section 28(e) of the Exchange Act. 
            * Traditional Soft Dollar Commission Business - We continue to provide a soft dollar commission business with negotiated and competitive hard/soft ratios. Each client receives detailed monthly statements, customized to its needs.
            * Westminster Group - Weeden does have a direct clear thru relationship with the Westminster Group, a third party research soft dollar provider. Westminster aggregates your soft dollar bills, provides administration and negotiates directly with you a hard/soft ratio. Westminster is not an executing broker but has created a network of execution brokers, which includes Weeden.
            * Directed Brokerage & Commission Recapture - Weeden maintains various broker dealer relationships for Directed Brokerage as well as Commission Recapture.
            * Step Outs - Weeden offers clients the ability to do Step Outs to brokers of choice.

For further information, contact your Weeden Sales Trader or Thomas Orr, 
Director of Research, (203) 861-7670.