Quarterly report pursuant to Section 13 or 15(d)

Soft Dollar Arrangements

v3.23.2
Soft Dollar Arrangements
6 Months Ended
Jun. 30, 2023
Disclosure Soft Dollar Arrangements Additional Information Detail [Abstract]  
Soft Dollar Arrangements

18. SOFT DOLLAR ARRANGEMENTS

The Company obtains research and other services through “soft dollar” arrangements. The Company receives credits from broker-dealers whereby technology-based research, market quotation and/or market survey services are effectively paid for in whole or in part by “soft dollar” brokerage arrangements. Section 28(e) of the Securities Exchange Act of 1934, as amended, provides a “safe harbor” to an investment adviser against claims that it breached its fiduciary duty under state or federal law (including ERISA) solely because the adviser caused its clients’ accounts to pay more than the lowest available commission for executing a securities trade in return for brokerage and research services. To rely on the safe harbor offered by Section 28(e), (i) the Company must make a good-faith determination that the amount of commissions is reasonable in relation to the value of the brokerage and research services being received and (ii) the brokerage and research services must provide lawful and appropriate assistance to the Company in carrying out its investment decision-making responsibilities. If the use of soft dollars is limited or prohibited in the future by regulation, the Company may have to bear the costs of such research and other services. For the three months ended June 30, 2023 and 2022, the Company utilized “soft dollar” credits of $239 and $186, respectively. For the six months ended June 30, 2023 and 2022, the Company utilized “soft dollar” credits of $455 and $244, respectively.