Managed accounts, which typically include discretionary investment advice and therefore could not qualify for exemptive relief using a BIC, could
use fee levelization for commission - based products and BICs for programs featuring nondiscretionary advice, according to Wagner.
Not exact matches
In fact, firms may wish to explore
using a combination of the BIC Exemption and
fee levelization as a compliance strategy for their managed account programs.
For example, the BIC Exemption may be utilized for programs that feature non-discretionary advice, and
fee levelization may be
used for programs that feature discretionary advice.