CSA PODCAST

May 27, 2026.  Please note that this is an automated transcript of the above mentioned podcast; errors may exist. If you have any questions, please contact Castine.

Robin Hodgkins:  Hello, and welcome to this episode of Castine Conversations. My name is Robin Hodgkins, and I’m the president of Castine. By way of introduction, Castine is the leader in providing a full continuum of research and commission management solutions worldwide. In these episodes, we meet the business leaders involved in commission management and research as they are managed, paid for, and reported on by both investment managers and brokers around the globe.

My conversation today is with two luminaries in the CSA space, Aaron Walter of Janus Henderson and Steve Stone of Morgan Lewis. They’re experts in commission management and come at it from two different perspectives: from the investment manager perspective and also the legal perspective. Our conversation covers where CSA stand today on a global basis, and especially where things are moving (or not moving) in the United Kingdom.

I hope you enjoy the conversation 

Robin Hodgkins:  Aaron and Steve, thank you very much for joining me today for this latest Castine conversation about about CSAs. Delighted to be back together with you.  I’d like to point out that we did have a podcast individually with both of you, two years ago in 2024, talking about CSAs, so it’s kind of nice to get together and have a combination where we’re, we’re all together on the same podcast talking about CSAs in 2026.

And hopefully we’ll have a chance to dig into what’s changed and what hasn’t changed, and what is still the same. But first let’s, let’s help the listeners by introducing ourselves. I’m Robin Hodgkins. I’m the president of Castine. We’re very much in the CSA space and have been for 20 years with a bunch of products, which we’re not going to talk about that much today, but we’re definitely in that space.

Steve Stone: Robin, thank you so much for including me. I’m Steve Stone and I’m a partner at Morgan Lewis, where I’m a securities lawyer. I focus on issues affecting investment advisors and broker-dealers, and so that kind of brings me into this research continuum with a focus on unbundling and re-bundling.

Robin Hodgkins: Globally.

Steve Stone: Globally.

Aaron Walter: Good afternoon. I’m Aaron Walter. I’m managing director of research management and data. I’ve been at the firm for 32 years, and let’s just say part of my opportunity for this, for the last 10 years has been really focusing on commission, research commissions, third-party research, and now market data as well.

Robin Hodgkins: And I think we’ve known each other since before Janus Henderson … was Janus Henderson, correct?

Aaron Walter: We have. It’s been a few few days.

Robin Hodgkins: And many discussions about 28(e) soft dollars, MiFID II, RPAs, and the like. I was thinking we might start off talking about CSAs maybe on a safer geographic starting point, which is the USA.

And I’d love to get your thoughts on where things stand with CSAs in the States, if there’s particular changes that have happened in the last year or two, if it’s kind of status quo or if there are things that might be, you know, coming down the pike on this side of the Atlantic before we start talking about the UK and the EU.

So Steve, do you want to, you want to kick us off with that?

Steve Stone: Happy to. So CSAs,  commission sharing arrangements, they go by other names like client commission arrangements refer to a practice that actually emanated out of the UK and was incorporated into the SEC’s guidance under Section 28e, the Safe Harbor for research in their 2006 reinterpretation of the Safe Harbor.

And the Safe Harbor itself is relatively complicated, and it seems like every decade the SEC comes out with a new reinterpretation to modernize the principles with, frankly, the exception being the interlude from 2006 because there really hasn’t been a lot of movement other than in the context of unbundling to address the investment advisory status issue.

And that it is, of course, the issue where brokers, they’re not treated as investment advisors unless they provide advice that’s not incidental to their role as a broker, and they get something called special compensation, which in other words means anything that’s not a commission. So a P&L payment, as is now not uncommon in  Europe and the UK triggers advisor status potentially for a broker-dealer.

So there really hasn’t been a major reinterpretation of the Safe Harbor in the United States since 2006. There are a number of issues that have been identified by industry for potential cleanup to conform the 28(e) framework with what will be the end state outside of the US, and there’s been a dialogue with the SEC.

It’s not really where things are going to go and whether this is a an important issue for the SEC chair, but we’ll, we’ll see. It really depends on the development in Europe and whether you have a, an emerging consensus and approach across the ocean, across the pond.

Robin Hodgkins: Aaron, as an important player in the asset management space, what are your thoughts about what’s happened in the US, or are we really focusing all of our attention across the pond to the UK and the EU  for what the next big thing will be?

Aaron Walter: It feels like things have been fairly status quo in the US. I think if anything, there seems like there’s a slow trend towards unbundling for those firms that are still trading in a kind of bundled fashion, if you will. But I think outside of that, it seems like it’s been fairly status quo and the attention’s generally been more on what’s happening in the UK and Europe.

Robin Hodgkins: From my perspective, we’re talking about the legal side and  manager side. We’re on the vendor side. We are seeing more CSA volume in the States. We’re not seeing regulatory change as you both said. We’re seeing more brokers coming online. They want to offer CSAs to their clients.

They see it as a way to increase order flow to provide better service for their clients, those sorts of things. But, I would agree, there’s been no regulatory or intra-US issues that have really caused a large jump in the activity.

Steve Stone: And I think part of that, Robin, is that everybody really has been focused on what’s happening first in the UK, and they completed their process last year as they added in the funds and what’s happening now, you know, including imminently in Europe.

and so there hasn’t been a major change on the CSA approach in the United States really since the SEC sunsetted the SIFMA letter, which required that both the buy side and the sell side adjust their framework for arrangements, including, in some contexts, moving the contracting process to London, where brokers could accept cash payments. But since then it’s been relatively quiet. There have been some US global managers that have tweaked their arrangements to  match what they were doing in Europe, but with the ultimate concept of rebundling when the occasion arises. And the fact that there’s been a disparate approach in terms of UK and the splintered way they approached that, plus EU has slowed that down.

And of course there’s client sentiment.

Robin Hodgkins: And I think there’s a lot that’s been discussed around client and asset owner sentiment around this. Before we get into the global view, certainly from the standpoint of a firm like Janus Henderson or, maybe our perception of what other global firms are looking for, maybe, Aaron, could you maybe set the stage for where we stand right now in the UK with not the adoption or the return to CSAs or rebundling or payment optionality, but what are the regulators saying is possible right now?

Aaron Walter: So the FCA  released a couple of different policies, 24/9 and 25/4, over the last couple of years that generally gives the ability to move to soft dollars. There are, there are limitations around corporate access as well as market data yet, but the regulators have given you the ability to move there.

The challenges are that there’s a lot more requirements than in the US regarding disclosures, budgeting. Those are, those are probably the two biggest policies, making sure you’ve got some formal policies in place that you can distribute as well. So the FCA generally believes they’ve done what they need to do to allow firms to move to joint payments.

Robin Hodgkins: And that would give the asset managers the ability to  move the payments that we refer to as P&L payments off of their P&L, to be paid for with client commissions. So there’s a significant reason, I would think, for asset managers and certainly their CFOs to look kindly on what the FCA is not only allowing, but also suggesting.

So Steve, looking at… And I know you’ve just back from the UK, and Aaron, you’re also just back from the UK. From your conversations over there, and this is maybe a trick question, how many hundreds of asset managers have fully adopted CSAs or payment optionality as the way to go for 2026 and are actually doing it today?

Aaron Walter: So from all the conversations I’ve had, there’s been minimal adoption. I think there’s a great desire for firms that want to move, but  The big elephant in the room is nobody wants to be one of the first ones to move. I think like in conversations there are some firms that have interestingly moved to RPAs.

They’ve made some one-off movements to RPAs to give themselves the ability to move to soft. But across the board, there’s, there’s no large movement at the, at this point in time to move to joint payments as everybody is waiting for somebody else to go first.

Robin Hodgkins: To kind of duplicate what happened with the domino effect back in 2017 as people went from RPAs to P&Ls.

That kind of looking for the mirror image of that. We’re hoping that would happen?

Aaron Walter: Yes. The challenge with 2017 was you had a hard and fast deadline. So over one weekend back in 2017, the whole industry moved.  In today’s environment, there’s not a specific deadline so there’s not a timeframe that people have to work within to make this happen.

Steve Stone: Right. And although we haven’t seen a universal or anything close to it, adoption of commission-funded research RPAs or joint payment models across the UK and the EU, the direction of travel is becoming clearer. The combination of the UK and EU reforms and the sentiment behind it the dominant US commission-based research model involving soft dollars, broker-dealer constraints in the US on receiving hard dollar payments, and also changes in the research ecosystem, including with AI-driven changes in research and research consumption, and ultimately the need for assessing fairness in the allocation of research costs globally are all factors that are pushing managers  towards greater payment optionality.

And so I think there are two speed bumps. One, are they ready to turn the switch on? And two, how are they addressing the client perception issue? That is, I should say, the perception that clients will be resistant to this change. And frankly, I think from what I hear from talking to clients, That is, investment manager clients a timidity to engage with its institutional clients for fear that they will object or use the occasion to say, “Let’s talk about fees.”

Robin Hodgkins: And let’s dig into that a bit more because we’re hearing the same thing. We’re talking to a lot of people that they’re saying that the crowds are gathering at the gates and something’s going to happen, some big event’s going to happen, a big name’s going to go to the top of the fold  of the FT, saying they’re going to do this.

But what have you actually heard from the investors, the end asset owners when they’re, when they’re asked about this? Or have you gotten into conversations directly with them or indirectly hearing as to what they’re, they’re feeling about this potential return of research to their, you know, to their client commissions?

Steve Stone: From my standpoint, I haven’t really engaged with the asset owners in that dialogue. I guess in a sense I head up my pension investment committee with a decent size set of plans. So as an asset owner, I’m not sure I would be entirely dismissive of the notion of my managers softing.

Of course, they are doing it now under the US norm. I think the important thing is — I would say the important question is whether there’s greater anticipation of client resistance than  actual client resistance. Because if you take a look at those institutional or asset owners who commented through the, both the UK and the EU process, the deliberative process for optionality there weren’t loud and vocal cries across the board for resisting that, you know, those set of reforms

Robin Hodgkins: So Aaron, you have a different view of the world ’cause you are actually, you know, running research for a, for a large firm. What are you picking up on as far as this issue with using client commissions for research?

Aaron Walter: There’s definitely a concern out there from the industry. Nobody wants to have the conversation with their investors. I think they’re thinking of worst case scenarios here. The approach we’re taking is we’re, we’re  running actively managed products, so research is a key ingredient to our performance.

So we don’t think that there’s going to be a major outcry on this. for all regions outside of the UK and EU today, investors are paying for that. And then you look at the amount that we’re charging investors, the amount is relatively immaterial. You’re, you’re talking roughly two basis points. So yes, no, nobody wants to be paying more, but in the flip side of things, if this is going to help your alpha, I think that’s a much easier conversation to have.

Robin Hodgkins: So do you think it’s going to wind up requiring some sort of an AB test where someone can say, “Well, this is what the US is paying for research and  this is their performance, and this is what the UK is paying for research, and this is their performance”? It seems like that may have already happened

Aaron Walter: There’s not a lot of analysis out there right now with regarding what research fees are. And I think if you looked at the drilled down and looked at the kind of the impact to performance, I think it could be telling. So I think that would help the situation, but frankly, there’s just not a lot of data out there on research commissions and the impact on performance

Robin Hodgkins: Yeah, I don’t have specific numbers to quote, but the general takeaway has, for me, has, since method two, has always been that paying for research through P&L has reduced the use of research, the diversity of research, and by virtue of the lack of those inputs, has hurt  performance as compared to the states.

Aaron Walter: Well, and I think another item to, for folks to consider is the research budget is one of the top expenses of any firm. So when you start having a downturn in the market and CFOs start looking for ways to cut expenses, research research spend is going to be one of those top focal points just if nothing else, by the nature of they’re one of the biggest right now

Robin Hodgkins: And I think a lot of people have not gone through that experience where they’re finding that all those different research inputs have been cut, and now they’re in a far worse position because it becomes somewhat of a downward spiral, I would think.

Aaron Walter: Completely agreed.

Steve Stone: Yes. In other words, from the standpoint of the client discussion, the  bookends are going to be performance and fairness. you know, clients don’t pay managers for research in the abstract, they pay for outcomes and performance, risk management, informed judgment. research is an input to those outcomes, and an important one.

And so the issue really shouldn’t be framed in terms of whether managers are opportunistically trying to push costs back to clients. It should be framed on whether managers have a, let’s say, a durable and fair way to fund research that they need to support client performance. And the point is especially important, and I think we talked about this, you know, in terms of the clients pay for performance two years ago on the podcast, but the point is especially important in volatile markets like today’s markets.

If research budgets are tied entirely to manager P&L, they may contract precisely when differentiated insight  is most important to driving alpha, and optionality gives managers more resilience through these market cycles. But it’s also important, particularly for global firms, to treat different clients in a fair and equitable way in terms of how they pay for research, as opposed to having certain subsets free ride on others.

And so in perhaps in an ironic way, you can look to the FCA standard that requires fairness in the allocation of research cost, regardless of how research costs are paid, as supporting a theme that favors rebundling on a, on a global basis

Robin Hodgkins: And I think performance is something that’s relatively easy to figure out, but on the fairness side, I’m hearing more and more of that these days, talking about the fair and equitable treatment of clients that are, that are domiciled in different places being  charged or not being charged for the research. And I’m not sure it’s really clear to the marketplace what that actually means.

So, for someone in the US, they’re an asset owner and they’re being charged for research, but that’s not happening in the UK. So why is that a problem?

Steve Stone: In a broad sense, investment advisors are required to treat clients fairly and equitably over time. We think of that concept as coming up particularly in the context of when you allocate investment or trading opportunities. And so if you get access to a significant allocation of SpaceX or the other, the next hot IPO you’re not supposed to pick and choose clients based upon whims and what you think serves your own interests.

You have to treat clients fairly and equitably in the allocation of those investment opportunities. The flip should also perhaps  apply in the context of which clients bear costs for research. And so, for example that concept is reflected in the US law, the Section 28(e) Safe Harbor, because the Safe Harbor says that you a manager justifies paying a higher commission for research and brokerage services, either in terms of the particular transactions or based upon their overall responsibilities for accounts over which they have investment discretion.

So it’s that latter chunk that is consistent with the equitable and fair treatment of clients that is also a bedrock principle in the FCA rules. But to be clear, fair and equitable, or fair and equitable, I would say over time, doesn’t mean identical treatment as in any given time. And I think another consideration that’s important is, you know, advisory fees are negotiable in the institutional marketplace, and  so some clients pay less or more, and that’s something that also can be factored in potentially to determine, you know, whether their incurring research costs are fair and equitable.

but this is an area where I think that, you know, firms will have to come up with their own framework and paradigms to to analyze it. It’s not something that the FCA seems intent, for example, to provide guidance on so I think firms are left to their own view in terms of the general concepts of fair treatment.

And treat- and disclosure and the opportunity to, you know, if you ha- want to have a discussion on fees, let’s have a d- discussion on fees, but why don’t you watch our performance first? That kind of a dialogue can make sense.

Aaron Walter: The one item that I continue to think about is when are we going to start seeing investors in regions outside of the UK and EU ask about why they are paying for research commissions and,  in the EU and UK that’s being paid by the company now that especially now that the FCA has given more optionality to be, to be able to do this

Robin Hodgkins: And those questions have not come up, but it would not be surprising if they do begin to surface, you think?

Aaron Walter: I think it’s a matter of time. I think at some point you’re going to start seeing different sets of investors ask that question, and especially to global global firms

Robin Hodgkins: And as far as the, as far as the pressure on the you know, on the asset manager to… Or on the, actually on the on the end investor and the asset manager together, where do you feel the movement’s going to start happening first?

I mean, looking back at 2017, the dominoes started with the big people. I was sitting at my desk in London, and over that weekend, it all just kind of came crashing down. We’re not seeing that now. But do you see it’ll be a small firm, a mid-sized, a large UK-based firm, or there’ll be some sort of pressure that will finally be brought from a global firm, maybe not Janus Henderson, but another firm that will, that will open the floodgates and get us past this point where the question of fairness and who’s being charged, who’s not being charged based upon, you know, jurisdiction is, becomes moot?

Aaron Walter: Well, I continue to look at my crystal ball, and let’s just say it gets it’s very fuzzy at the moment. I think there’s a couple different views. It feels like larger global firms are a step ahead of the UK and EU centric managers with regards to their readiness and ability to switch, but nobody wants to be the first mover.

On the flip side, with the smaller firms, it seems like there’s a lot at stake for these smaller firms to move But there’s also a lot of work that needs to be done. I think the global larger global firms are a little bit of at an advantage because of soft dollar practices that are in place in other regions at this point in time.

So the amount of work that’s required to get there’s a fair amount of work, and if you’re not actively engaged with this, it’s a challenge to get there. It’s, it’s definitely doable, but j- but it’s, it’s a process that you’ve have to go through. So I don’t think that’s a great answer to your question, Robin.

I think I don’t know if it’s going to be a large global firm that moves first or a number of smaller firms that that make the move  that that invert the market, if you will.

Steve Stone: I think the conventional wisdom was a couple big firms would be the first dominoes, but that’s, like many conventional wisdoms, are, you know, perhaps over simplistic because investment advisors, big and small, are idiosyncratic in terms of their positioning with their clients.

Some firms will roll into optionality and frankly probably not be observable in terms of impact because they’re too small or d- they don’t have the same following. you know, small, medium, and large firms will will move in. You could have some large firms who say, “No, we’re sticking to optionality.” and in part that turns up the pressure on small firms because they’re trying to squeeze out or increase the cost of the small firms by forcing them to match the economics or maintain the economics of unbundling.

So it’s not necessarily going to be a tidy process, but it’s pretty clear that  there will be a significant segment of the market that will move to optionality, and firms have been starting to plan for it, understanding the types of barriers, Aaron and Robin, that you’ve both been mentioning.

Aaron Walter: Yeah. I, and I would just add, it doesn’t feel like it’s an if question, it’s a, it’s more of a when question.

As, as I continue to talk to peers, the consensus is firms want to move. So it’s just a matter of how you do it and when you do it.

Robin Hodgkins: And I think, you know, all three of us have spent a lot of time in, you know, in London. You know, I’ve got an operation, you know, full-time operation there as well, so do you, Aaron.

Steve, you seem like you’re there all the time, so you might as well have a full-time operation there. Yep. But the movement that we’re seeing is really around the edges. You know, a lot of  brokers are getting ready for this. a lot of people are beginning to talk about the disclosures, notifying the FCA, notifying their clients, updating their prospectuses, whatever, those sorts of things.

But are we, or are you seeing on the asset manager side a lot of movement in that direction? Or is it still pre-disclosure, pre-notification?

Aaron Walter: I think we’re still way ahead of the pre-disclosure, pre-notification unfortunately. It it felt like at the end of the year that firms got over the hump of how to do the budgeting, and there seemed to be a lot of momentum towards this.

But as the year’s progressed, with there being minimal movement in the industry, there’s, there’s some firms that are just putting on pause their efforts, which I think is a mistake to do. because I think with the amount of work that you’ve have to  do, you want to get yourself operationally ready to go so that when the dominoes fall, if you believe you’re going to be an early mover, you can, you can have your options and make the move when you want to

Robin Hodgkins: You know, we always thought there was going to be a matter of, there’d be a log jam when people all of a sudden sign up and they want to, you know, come to us, they want to come to one of our competitors and do the software side.

But there’s a lot of other things that have nothing to do with software that has, that have to happen beforehand, and those are kind of, I’m not sure canary in the coal mine, you know, is the right analogy, but those are kind of the early indicators in my mind as to where the market’s going. And you’re not seeing a lot of movement there.

Aaron Walter: to give you an example, we’ve got a we had a handful of RPAs that we converted over to CSAs at the beginning of the year. why we did this was, I think the direction is clear on where things are going, but then also we wanted to make sure  that that operationally we were good to go. We could handle the various requirements.

The biggest challenge we had was going back to 30 different brokers to get CSA agreements in place. A number of these brokers we already trade with in the US, so it didn’t feel like it would be a monumental effort, but it turned in to be, turned into one. I think part of it was we were an early or we were early to the table on this versus a lot of others in the industry But it took a proc…

It was a process. As I continued to talk to brokers out there, as well as some of the different commission aggregators, it just doesn’t feel like firms are, asset managers at least, are doing these things to get themselves operationally ready.

Robin Hodgkins: And, and from the legal  standpoint, Steve, as far as people getting their legal world aligned around this, are you seeing the same sort of procrastination?

Steve Stone: Yes, in short.

Robin Hodgkins: So it sounds like there’s a lot of interest in this. You know, the flesh is willing, but it’s not, it’s not happening at this point in time. Before we move over to the EU, I want to wrap up on the EU before we close for the day. What are your, what are your thoughts? I’ll ask Aaron first. If we believe that CSAs or payment optionality is a good thing, it’s good for all parties involved and it’s something that the regulators want to have happen what is your thoughts as to when we’ll start to see either  explicitly or by a slow reveal the movement, the stampede starting towards CSAs in the UK?

Aaron Walter: I don’t have a great answer on that. I was I was under the assumption that we’d start to see that already, but we haven’t. Will we see that as we trend into 2027? I’m optimistic, but the stars aren’t necessarily pointing that direction. But what I will also say is I still remember back to 2017 where things changed in a weekend.

So things can change very quickly, and when they do, I think there’s going to be a large shift within the industry as firms are going to want to move back to soft

Robin Hodgkins: And Steve, what are your thoughts about not the if, but the when.

Steve Stone: I was looking to see what was in  Aaron’s crystal ball. But I agree.

Realistically, the processes are complicated enough, including the client dialogue aspect, that I think that ’26 is not going to happen for many shops. ’27 is a possibility, but the budgeting work, the contractual work, the disclosure work, the client discussions complicate that timeline. So ’28 may seem a lot more realistic, but, you know, if there, if there are things in the market that precipitate this, you know tipping points, you could have things change radically.

So if you had a 50% correct- correction in the markets, which are pretty up there, pretty inflated that will change the zeal in which the C-suite says, “You have to make this done, get this done.” And that changes the talking points in front of the clients. I mean, one of the things I still continue to be interested in the fact is that really, you know, there hasn’t been an effort by the buy side firms to communicate broadly,  the reasons why going for payment optionality is important and ultimately in the best interest of clients who are thinking about what are the, what are the things that are going to be important to clients?

Obviously, performance and transparency. You know, if a manager is coming to me to say, “I want you to pay for research costs in order to drive performance,” then I’ll say, “Look, let’s talk about it. You’re right, performance is much more important to me, and I’d be penny-wise and pound-foolish if I was looking to save a penny and lost out many-fold that in terms of performance.”

But I want to have the transparency to confirm that that’s happening. And I want to understand what you’re, what you’re using my money to buy and how it pays off in terms of performance.”

Robin Hodgkins: We’ve tried to get people together to publish a joint article between different firms. But nobody wants to have the reputational risk, or the first mover publishing target on their back, as it were.

I think it’s a very interesting situation ’cause it seems everybody kind of either directly or indirectly wants to go in this direction, whether they kind of know it or not.

We started off talking about the US and potential regulatory changes in the US around CSAs; I think we said that’s unlikely. Do you think there’s any likelihood for regulatory changes on the FCA to soften this or to make it easier? Or as Aaron said earlier on, to set a date to make this happen?

Steve Stone: I think that there are continuing discussions between industry and the FCA to clean up some of the things that don’t connect the FCA regime to what is emerging in Europe, and certainly what exists in the United States such as corporate access, such  as market data. We’ll see how that plays out.

Robin Hodgkins: But you don’t expect a change in the notification rules coming out of the FCA specifically?

Steve Stone: No.

Robin Hodgkins: Well, we’ve talked about the US, we’ve talked at length about the UK. In the last couple minutes do you have any observations about what is going to be coming out of the EU in the next couple weeks? And I guess my larger question is, do you think that the EU will be playing in the CSA/ re- unbundling space sooner than the UK?

Aaron Walter: I think we’re all waiting for the final policies to be put into effect But I don’t think there’s any expectations that there should really be anything significantly different from what the FCA  did.

I think if anything, it just seems like there is more of a question as to when are these policies going to be put out there and how much focal, how much of a focal point is this with the regulators in the different countries. I don’t think there’s any concerns necessarily, but it just hasn’t been a, been a priority.

I think the bigger response is there is that there’s really not going to be a whole lot different, at least we’re not anticipating.

Steve Stone: I agree. I mean, this is not a circumstance where I would expect that EU member states would necessarily gold plate their implementation of this. There are other circumstances where EU member states will not typically cut away, but will elaborate and add additional restrictions. And I don’t think given the tenor and the rationale behind these changes  that that’s likely in this circumstance. Can’t rule it out, but probably not.

Robin Hodgkins: Any last thoughts about CSAs before we wrap up? Or is it more “let’s see what happens in early June in the EU and we’ll see what develops in 2026 throughout the UK?” Any other thoughts, observations or topics we should be wrapping up with?

Aaron Walter: I would just say I think if you’re at a firm that believes you want to be moving to joint payments at some point or another, continue to work on this. Don’t hit the pause button. Get yourself operationally ready to do this because I think there’s a big difference between saying you want to work on it, you want to move, versus actually doing it and putting yourself in a position where you can act quickly when you when you need to or want to.

Robin Hodgkins: And, and doing the paperwork is work, but it does put you in a very strong position of your own optionality. So you have choices that you’re just not going to have if you wait until all the Joneses do this, and then you’re playing, back to our point before, six to nine-months of catch-up.

Aaron Walter: And, you know, generally speaking, there’s no implicit cost to this. Your, your cost is your time internally that you’re, you’re, you’re dedicating to this. So there’s not any kind of external cost generally you’re, you’re, you’re, you’re looking at to in terms of for setups of these

Robin Hodgkins: And Steve, would you, would you agree with that? Maybe there’s costs on the legal side that they should be paying you to move this forward?

Steve Stone: Look, the critical thing, and Aaron said it, is firms really, if they haven’t invested in putting this in place, they really need to create an implementation playbook.

So at the very start they can do the planning to evaluate what are the gaps they have to address in the milestones, and start thinking about what is the timeline and who are going to be the responsible parties for carrying this out.

Robin Hodgkins: I think that’s a great place to leave it. Those are great words from both of you as far as getting things lined up and ready to go.

It’s going to help on all fronts, give you a lot of flexibility that a lot of firms don’t have now and will be missing out on if they don’t, if they don’t continue with their plans.

I want to thank you both for your time today. I look forward to seeing you in New York in the not too distant future at the Substantive Research Unbundling Uncovered Conference, and then hopefully again in London in November where we can see what’s actually happened for the remainder of 2026.

Aaron, Steve, thank you both very much for your time today.

I’d like to thank Steve and Aaron for joining in this conversation today. For more information on Morgan Lewis, please visit morganlewis.com. For more information on Janus Henderson, please visit janushenderson.com.

And for more information on Castine’s full continuum of research and commission management solutions, please visit CastineLLC.com. Thank you very much.