Soft Dollars – Rule 28e

Tyler G. Kim, CMC

Assurance and Advisory Business Service
Toronto, Ontario

Tyler will compare and contrast US and Canadian regulatory guidance regarding soft dollars, in order to facilitate a discussion about the principles upon which specific rules are based. By examining these principles, risk managers, compliance officers, and internal auditors will be in a better position to ensure that their compliance policies and procedures and compliance monitoring programs effectively promote the kind of behavior that the regulations are meant to engender. Reference points will include National Instrument 23-102 in Canada, Section 28(e) of the Securities Exchange Act (including the July 2006 interpretive release from the SEC), and relevant aspects of other regulations (e.g. 31a-1(b)(9)).

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