Commission management you run in conversation with eight agents: every research dollar cited, split and signed before money moves
Every research dollar matched to an eligible use and a signed split, before money moves.
See one case, screen by screen ↓Commission Management is commission management software for asset managers that tracks commission sharing accounts (CSAs) and research payment accounts against the research invoices they pay. Eight agents read every invoice, test each line under the Section 28(e) safe harbor, apply only signed mixed-use studies, route each share to the right account and draft the payments. A commission analyst prepares, compliance approves with a reason code and finance releases.
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An asset manager pays for third-party research with part of its clients' commissions, held in commission sharing accounts at each executing broker and, for UK and EU clients, in research payment accounts. Every research invoice has to be priced against the provider's contract, tested for eligibility under Section 28(e), split when a product such as a terminal also serves administration, paid from the right account and approved — while the hard-dollar share goes through the firm's own accounts payable. Today that is spreadsheets, a dozen broker portals and email sign-offs.
The risk sits in what slips through: an invoice paid twice because it came by two channels, a price above the order form, travel and dinners paid with client money, a mixed-use study that lapsed, a vendor's bank details changed by email. SEC staff, drawing on over 1,500 adviser exams, list not properly administering mixed-use allocations and not disclosing soft dollar arrangements among the most common best execution deficiencies. And when an examiner asks for every mixed-use payment and its rationale, the evidence takes weeks to assemble.
Estimated split of the monthly statement tie-out and payment cycle at a large manager, by hand and with the solution.
Eight agents read, test, split, route and check every research invoice; the analyst prepares, compliance approves, finance releases.
Monday, October 19, 2026, at Quillfield Capital, a fictional manager of about $900 billion. Kestrel Data has billed $186,000 for 62 terminal seats for the fourth quarter. The commission analyst works in a conversation with eight agents beside every screen: they tell her where to start, she asks why or what if, every answer cites its passage, and three people sign before money moves. Here is what happens next, screen by screen, in the working solution.
Since Friday the agents have read 46 research invoices from 10 channels — the AP mailbox, vendor portals and broker portals — in English, German and Japanese. Thirty-eight, $1,204,594, are clean and agreed by both checking agents, ready to prepare in one step. Eight need a person, each with one next step: Prepare, Choose, Reject, Send query, Review. Beside them, what each agent did with its source, and the Balance agent's note on where to begin, with questions she can ask next.
“Start with Kestrel, then Ardent. … Kestrel's split follows signed study MU-2026-03; Ardent needs your choice because Calloway Markets is $34,760 short.” — Balance agent.
All 12 commission sharing accounts — Pellam & Co., Ostrander Markets, Calloway Markets and nine more — sit beside the UK and EU research payment accounts and Quillfield's own account, each with its balance, October accruals and what waits to be paid. Nadia picks Kestrel's invoice from the tray and drops it in: $130,200 lands in Pellam & Co., $412,880 available and $282,680 after this payment; $55,800 goes to Quillfield's own account. Calloway shows “Short $34,760”, Harwell Securities “Break $8,460”.
“Where it goes: the agents split it” — 70% · $130,200 Pellam & Co. · 30% · $55,800 firm pays.
The invoice opens beside the agents' six steps, all agreed. The Intake agent read KD-2026-10-4471 from the AP mailbox at 97% confidence: 62 seats (New York 38, London 16, Singapore 8) from October 1 to December 31 at $3,000, $186,000, with no earlier copy in 24 months. The Eligibility agent tested the line under Section 28(e)(3): research, but mixed use, rule E-07. Nadia asks, “Why does the firm pay 30% of the Kestrel invoice?” The Mixed-use agent answers in the thread, citing the study, the 2006 guidance and the population check.
“Section 28(e) covers only the research share; the 2006 guidance asks for a reasonable allocation by use, with the other share paid by the firm.” — Mixed-use agent.
The Mixed-use agent applies study MU-2026-03, signed by Alana Whitfield on May 14, 2026 and in force to May 14, 2027: a survey and login analysis of all 62 users measured research and investment-decision use at 70.4%, set at 70%. It checks the population still matches — 62 seats invoiced, 62 users surveyed — and splits $130,200 research and $55,800 administration. Every citation opens its passage; this one is the study's result.
“4.2 The research share is set at 70% for invoices dated May 14, 2026 to May 14, 2027.” — study MU-2026-03.
The Second-check agent, on a separate model family, re-tested the invoice on its own: the price matches order form KD-OF-2291, 62 × $3,000 = $186,000, no duplicate, and the account ending 6610 matches the vendor master. Nadia prepares it. Alana Whitfield, senior compliance officer for soft dollars, opens the same evidence, approves with reason code A2 “Mixed use per signed study” and signs. Nadia could not have approved it herself: no one approves what they prepared.
“Sign as Alana Whitfield, Senior Compliance Officer, Soft Dollars. My signature, the time and the evidence are kept with the record.”
Ardent Macro Research's $96,000 subscription is paid by Calloway Markets under the H2 broker vote, but Calloway has $61,240 available. Nadia asks, “Which accounts cannot cover what is waiting?” The Balance agent answers: split with Ostrander Markets today — $61,240 from Calloway, $34,760 from Ostrander — or wait until accruals reach $100,140 on November 6, still before the November 15 due date. She chooses with one click.
“Two ways through … Your call.” The Balance agent never moves money between accounts.
Tessaly Research Partners' $58,000 invoice asks to be paid to a new account, Harbor Mutual Bank ending 9902, and was sent from tessaly-research.co. The vendor master holds Northern Lakes Bank ending 4471 and the domain tessalyresearch.com. The Second-check agent shows both views and holds the invoice until Tomás Ferreira, the finance controller, calls Tessaly on the number already on file.
“Possible fraud: held for a finance call-back to +1 416 555 0148.”
The Reconciliation agent tied the September statements from 12 brokers and 2 research payment accounts to 18,940 trades in the order management system. Harwell Securities credited nothing for a September 29 program trade of 423,000 shares, though its agreement credits 2.0¢ a share: $8,460, with the query drafted for Nadia to send. And Hollins County Teachers' Retirement System forbids soft dollars, yet three October trades credited $5,212 to the Aldmoor account; the agent proposes re-booking at execution-only rates and a refund that Nadia prepares and compliance approves.
“Schedule A §3.2 credits 2.0¢ a share. Please credit $8,460 and confirm on the October statement.” — drafted query.
The Payment agent drafted every instruction in each broker's format — Kestrel's $130,200 request to Pellam & Co. and a $55,800 accounts-payable voucher among 14 ready to release, $504,450 — with payee bank details taken only from the verified vendor master. Only finance releases. Northgate Global Research's $262,500 stays in “Second approval”: at $250,000 or more, Sam Deluca, Global Head of Trading, approves after compliance.
“Nothing is sent until finance releases; I never send a payment.” — Payment agent.
Each agent step and each decision is logged with who, what, when, why and the evidence: Alana's approval at 09:23 with A2, Nadia's preparation a minute before, the Mixed-use agent's split at 09:08. Files carry SHA-256 fingerprints and records are kept seven years. Asked for every mixed-use payment in 2026, the Evidence agent assembles the register — 186 payments, $4,812,600 — with the studies, both approvals and the broker confirmations.
“61,204 entries in 2026, every one with its evidence.” — Evidence agent.
The same Kestrel invoice and the same week, seen by five of the people who prepare, approve, release, budget and audit it — what their month looked like, and what it looks like now.
Eight agents read, test, split, route and check every research invoice; the analyst prepares, compliance approves, finance releases.
Collects research invoices from the AP mailbox, vendor portals and broker portals, splits bundles, reads the header and every line in the invoice's own language, fingerprints each file and finds duplicates across channels.
Tests each line against Section 28(e)(3), the SEC's 2006 guidance and the firm's eligibility rulebook — for UK and EU research payment accounts, also the MiFID II research definition — and cites the rule and the invoice line.
Applies only a signed, in-force mixed-use study, checks that its population still matches the invoice, and drafts a re-study from seat lists and usage logs when one lapses.
Routes each share to its account by the routing rules and the broker vote, checks the balance, pending payments and accrual forecast, and proposes a split or a date when an account is short.
Ties each broker's CSA statement to the ledger built from order management commissions, enforces client soft dollar restrictions and drafts broker queries.
Re-tests contract price, duplicates, arithmetic, FX and bank details on its own, on a separate model family, and reports agreement; a disagreement goes to compliance with both views side by side.
Drafts CSA and research payment account requests in each broker's format and accounts-payable vouchers for the hard-dollar share, and matches the brokers' confirmations.
Keeps the record, drafts the monthly commission report, the Form ADV Item 12 support and the UK and EU client disclosures, and builds the examiner pack.
Prepare, approve, release, second-approve. The agents propose; a named person decides.
Every working screen has the agents beside it. Ask why, ask what if, or tell them what to do — every answer cites its source, and some open the screen that answers it.
Why does the firm pay 30% of the Kestrel invoice?
Because Kestrel terminals are mixed use. Study MU-2026-03 measured 70.4% research and investment-decision use across all 62 users and set the research share at 70%. Section 28(e) covers only the research share; the 2006 guidance asks for a reasonable allocation by use, with the other share paid by the firm. So $130,200 comes from the Pellam & Co. account and $55,800 from Quillfield's own budget.
Which accounts cannot cover what is waiting?
Calloway Markets: $61,240 available, $96,000 waiting, $34,760 short. The only invoice it cannot cover is Ardent Macro Research ARD-26-7712. Two ways through: split with Ostrander Markets today, or wait until accruals reach $100,140 on November 6, still before the November 15 due date. Your call.
Show every mixed-use payment in 2026 with its study
186 mixed-use payments in 2026, $4,812,600 in all: $3,207,700 from client commission accounts and $1,604,900 paid by the firm. Each one carries its study, the invoice line, both approvals and the broker's confirmation. I have opened the examiner pack with the mixed-use register selected.
What if we lower the auto-prepare threshold to 0.85?
I replayed September's 212 invoices at 0.85: 9 more packages would have been prepared without a person checking a field, and on 2 of them the analyst had corrected a field (a service period and a seat count). I recommend keeping 0.90. Any change is a new version of the thresholds and needs the Chief Compliance Officer.
13 screens from the working solution, on its sample data. Pick one to see it large.
The thresholds every invoice and payment is checked against are settings. Each change is a new version, logged and approved by compliance, and the agents replay last month to show what a change would do first.
| Setting | Default | Choose from |
|---|---|---|
| Agents prepare a package on their own at | 0.90 confidence | Below this, a person reviews every field |
| Second approver (head of trading) from | $250,000 | Per payment, US dollar equivalent |
| Contract price tolerance | $0 over contract | Any increase holds the invoice |
| FX tolerance against the 4 p.m. fix | 0.5% | Rates from the 4 p.m. London fix, loaded daily; re-tested by the Second-check agent |
| Duplicate look-back | 24 months | Across every channel and provider |
| Low-balance warning | 20% of the next 30 days of payments | A change needs compliance approval and makes a new version |
| Mixed-use payments | Always approved one by one | Never in bulk |
| Bank-detail change | Call-back by finance + second person updates | Agents never change bank details |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (SEC Office of Compliance Inspections and Examinations, Risk Alert: Compliance Issues Related to Best Execution by Investment Advisers, July 11, 2018 — over 1,500 adviser exams; SEC Release 34-54165, July 18, 2006, Commission guidance on client commission practices under Section 28(e)). Quillfield Capital and the people, brokers, research providers, clients and funds named on this page are fictional: characters and sample data in the working solution.
Commission Management is commission management software for asset managers that tracks commission sharing accounts (CSAs) and research payment accounts against the research invoices they pay. Eight agents read every invoice, test each line under the Section 28(e) safe harbor, apply only signed mixed-use studies, route each share to the right account and draft the payments. A commission analyst prepares, compliance approves with a reason code and finance releases.
The Eligibility agent asks the three questions of the SEC's 2006 guidance on every line — is it research or brokerage under Section 28(e)(3), does it help in investment decisions or in executing trades, and is the price reasonable for its value — then applies the firm's rulebook and cites the rule. A conference invoice splits line by line: the registration for research sessions is eligible, the hotel, flights and dinner go to the firm. Anything under 0.90 confidence goes to a person.
Only by a signed, in-force study. The Mixed-use agent applies the study's percentage, checks that its population still matches the invoice, and blocks preparation when a study has expired. It then drafts a re-study from seat lists and usage logs — for an order management license, 21% brokerage use against the old 25% — for compliance to sign. Agents never set a percentage.
Yes. Every broker's CSA appears with the UK and EU research payment accounts and the firm's own account, each with its balance, accruals and what waits. Research for UK funds is paid from the UK account and for the Luxembourg funds from the EU account, never from a US CSA, and each research budget is watched against what was disclosed to clients. The rules shown for those accounts are FCA PS24/9 and PS25/4 in the UK and the MiFID II research unbundling rules (Delegated Directive 2017/593, Article 13) in the EU. Broker statements are tied to the order management system, and breaks are traced to the agreement.
Yes. The Intake agent fingerprints every file and looks back 24 months across every channel, so a second copy of an invoice already paid is rejected, not paid. Prices are checked against the order form with no tolerance over contract, and a query to the provider is drafted. A change to a vendor's bank details holds the payment until finance calls back on the number already on the vendor master.
The Evidence agent drafts the Form ADV Part 2A Item 12 support, the UK and EU client research disclosures and the monthly commission report from decided records only, each number linked to its records; an analyst prepares and compliance signs. For an examiner it exports one pack: the payment and mixed-use registers, signed studies, the maker-checker record with reason codes, statements and tie-outs, rulebook and agent versions, and the fingerprinted audit trail.
Yes. The agents read, test, split, route and draft; they never approve or send a payment, set a percentage, move money between accounts or change bank details. Three people sign every payment — analyst, compliance, finance — with the Global Head of Trading added at $250,000 or more, and no one can approve what they prepared.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your CSA agreements, provider contracts, eligibility rulebook, mixed-use studies and broker vote — and it goes live once every quality gate has passed. Setup connects the systems of record, has the agents read every agreement and contract, and ends with a dry run on last month's invoices, compared with what was decided and reported to compliance before go-live.
Committee pack in two hours, every outlier explained, every figure tied to its source.
1-min demoTransaction Cost AnalysisEvery trade's cost explained in plain words, by broker, algorithm and venue, by morning.
1-min demoBroker VoteEvery research dollar tied to its vote and evidence, approved in days, not weeks.
1-min demoWe'll run Commission Management on a sample of your own research invoices, CSA statements and mixed-use studies.