FSA Use of Dealing Commissions, COB 7.18

SIFMA provides comments to the Financial Services Authority (FSA) on proposed amended to the use of dealing commissions, COB 7.18.  The proposed amendment would categorize connectivity services and associated services as non-permitted services, i.e. – those that may not be obtained by investment managers through use of dealing commissions.  SIFMA strongly disagrees with the content of the proposal, as well as the proposals conclusions that connectivity services and associated software fail the temporal test or are inconsistent with duties owed to client.