Trust Examiner School - September 2023
Internal Use Only
Broker Relationships
• What are soft-dollar arrangements? • When are they appropriate?
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Internal Use Only
Broker Relationships
Use of own-bank or affiliated brokerage services: • Bank may provide discount brokerage service or brokered CD program • Complete & accurate disclosures • Prohibited transaction for employee benefit accounts • Use of affiliate’s service is a conflict of interest
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