A Practice Note discussing the conditions under which a money manager can rely on the safe harbor of Section 28(e) of the Exchange Act to use client funds to purchase brokerage and research services for their managed accounts. Under Section 28(e), a money manager is protected from liability for a breach of fiduciary duty solely on the basis of having paid more than the lowest commission rate for brokerage and research services provided by a broker-dealer when the manager determines in good faith that the amount of the commission is reasonable in relation to the value of the services.