Rule 10b-10 requires brokers to send, at or before the transaction, a written confirmation of each securities transaction with a client containing certain essential information about the transaction. In the case of a phased transaction, Rule 10b-10 requires the broker-dealer and the broker providing the services in soft dollars to send a written confirmation containing all the information required by Rule 78 The term „soft dollars“ covers payments made by investment funds and other asset managers to their service providers. The difference between soft and hard dollars is that instead of paying service providers in cash (i.e. hard dollars), the investment fund pays in kind (i.e. with soft dollars) by forwarding the transaction to the brokerage. Using information provided by dealer brokers and internal knowledge from previous audits, we selected 280 investment advisors and fund sets for review. Investment advisors are also required to disclose any conflicts of interest within a soft dollar that could prompt them to give advice that is not disinterested31 Accordingly, the Commission has ordered that consultants disclose to their clients all products and services they have received under soft dollar agreements, and states, „We have seen many cases where information provided by consultants about soft dollars is disclosed to their clients.“ insufficient or totally absent – especially with regard to non-research articles….