On July 18, 2006, the SEC issued a final Interpretive Release on soft dollar arrangements that among other things, adopts the three-step analysis that was set forth in the proposed Interpretive Release, for investment advisers or managers to apply when determining whether a product or service falls within the scope of the Section 28(e) safe harbor. The SEC's three-step analysis includes (1) Identifying the service; (2) Confirming that the service provides lawful and appropriate assistance; and (3) making a good faith determination that commissions paid are reasonable in relation to the services provided.     2006 Final Interpretive Release on Soft Dollars