Final Rules - Part 1 - Further details to be released later.
Key Points - Initial Reaction
CSAs survive and can fund RPAs.
Monetary Research Budgets Required.
Asset owners must be informed of their respective portion in advance. New
language appears to have potentially increased the granularity of research budget reporting.
(c) where an investment firm makes use of the research payment account, it shall provide the following information to clients: (i) before the provision of an investment service to clients, information about the budgeted amount for research and the amount of the estimated research charge for each of them. (ii) annual information on the total costs that each of them has incurred for third party research.