Conclusion The Investment Manager can establish that the product or service is Research that can be purchased with Client Brokerage only after the Investment Manager has taken two steps. First, the Investment Manager must have defined the product or service (Level I analysis). Second, the Investment Manager must have determined that the primary use of the product or service will directly assist the Investment Manager in the Investment Decision-Making Process rather than in the management of the investment firm (Level II analysis). The final step is for the Investment Manager to determine what portion of the Research will be used by the Investment Manager in the Investment Decision-Making Process and pay only for that portion with Client Brokerage (Level III analysis). |