To fall within the Section 28(e) safe harbor of the Securities Exchange Act of 1934, which TWO activities are an investment adviser required to do if it pays higher commissions in order to receive soft dollar products?
1) Make a good faith determination that commissions paid are reasonable for products received.
2) Make disclosure in Form ADV Part 2 regarding its soft dollar practices.
3) Document mixed use allocations in writing.
4) Ensure that research is used to benefit all client accounts.