U.S. investment advisers are required to seek best execution for their clients’ securities trades, a duty that generally includes seeking to pay the lowest available commissions.  However, under Section 28(e) of the Securities and Exchange Act of 1934, advisers are permitted under certain circumstances to pay higher commissions if, in exchange, they receive credits – “soft dollars” – that can be used to pay for certain eligible brokerage or research services.  See “Katten Forum Identifies Best Practices for Hedge Fund Managers Regarding Best Execution, Soft Dollars, Principal Trades, Agency Cross Trades, Cross Trades and Trade Errors,” Hedge Fund Law Report, Vol. 7, No. 10 (Mar. 13, 2014).  The U.K. has a similar regime, and the U.K. Financial Conduct Authority recently clarified the application of that regime to the use of dealing commissions by hedge fund managers to purchase substantive research or corporate access.  See also “Best Practices for Due Diligence by Hedge Fund Managers on Research Providers,” Hedge Fund Law Report, Vol. 6, No. 11 (Mar. 14, 2013).