Following the advice of its portfolio managers, The Rising Tide Hedge Fund executes most of its securities transactions through Momentum Securities, a registered full-service broker-dealer. In order to compensate for the commissions charged, Momentum Securities allows employees of Rising Tide to use furniture and facility at a discounted rate. Under the soft-dollar provisions of Section 28(e):. a) this would not fall under the safe harbor. b) this would fall under the safe harbor. c) this would not fall under the safe harbor provisions unless the employees were those who directed the transactions to Momentum. d) as long as the discounted rate reflected the volume of business done by Rising Tide, this would be permitted.
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