ERNST & YOUNG LLP
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)).