
Between January 1, 2001 and October 2003, Respondents directed brokerage commissions on trades executed for the Scudder Funds to eighteen broker-dealers to reduce their revenue sharing costs. By directing brokerage commissions, a Fund asset, Respondents avoided, in certain instances, having to expend their own assets for revenue sharing. These marketing arrangements created potential conflicts of interest that DIMA and DAMI, as fiduciaries, should have -- but did not -- adequately disclose to the Fund Boards. DIMA and DAMI similarly failed to communicate to the Funds’ shareholders in the Funds’ prospectuses or Statements of Additional Information (“SAIs”) that SDI used the Funds’ assets to reduce revenue sharing costs.