Section 28(e) protection extends to all research products and services that contribute to the investment decision-making process, including both independent research produced by a firm other than the broker providing the research and research produced in-house.

Research services must consist of either advice, analyses or reports that relate to permissible subject matters defined in Section 28(e) and reflect substantive content, i.e., the expression of reasoning or knowledge. Interstate's support service department insures that contract and research payments are handled within the scope of SEC regulations.

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