Ethics 5: 10 percent de minimis amount. a10, particular, percentage, interpret

dmar

(3) the aggregate percentage of XYZ Brokerage derived from Client-Directed
Brokerage Arrangements and the amount of the particular Client’s
Directed Brokerage as a percentage of the aggregate, subject to a
10 percent de minimis amount.
How do you interpret the meaning of the 10%?

prav_Cfa7

If the particular client’s directed brokerage amount is less than 10% of the total client-directed brokerage amount of XYZ, you may opt not to disclose. If 10%, you must disclose to that client.
o.o

jbaldyga

So, if a client asks for additional information, but their brokerage share is
XYZ must disclose in writing to its Clients that additional information in
accordance with the CFA Institute Soft Dollar Standards concerning
XYZ’s Soft Dollar and Client-Directed Brokerage Arrangements is
available on request. Such additional information should include (1) a
firmwide description of the products and services that were received
from each broker pursuant to a Soft Dollar Arrangement, including the
identity of those Brokers; (2) for a specific Client account, the total
amount of Commissions generated for the Client through Soft Dollar
Arrangements, detailed by Broker and reporting the amount of
Brokerage directed by the Client to specific brokers; and (3) the
aggregate percentage of XYZ Brokerage derived from Client-Directed
Brokerage Arrangements and the amount of the particular Client’s
Directed Brokerage as a percentage of the aggregate, subject to a
10 percent de minimis amount.