The Securities and Exchange Commission and the European Commission announced guidance that will permit European Union-based firms to access US research after the effective date of the Markets in Financial Instruments Directive II on January 3, 2018. Under these requirements, a portfolio manager can obtain research from a third-country broker in one of two ways: through payment by the portfolio manager from its own resources or from payment from a separate research payment account ("RPA") controlled by a portfolio manager funded by a research charged with the manager’s clients. To accommodate the practice of many third-country broker dealers (such as those in the US) to bundle execution and research costs together, the EC agreed that this practice might continue provided the payment by MiFID II portfolio managers attributable to research can be identified. SEC staff provided guidance through no-action letters that brokers dealers, on a temporary basis, may receive research payments from money managers for research without registering as an investment adviser, and that money managers may continue to aggregate orders for mutual funds and other clients even where such clients may not end up paying an equal pro-rata share of all costs (because under MiFID II different amounts may be charged different clients for research). SEC staff also authorized the payment for research by money managers subject to MiFID II to executing broker dealers through an RPA. All relief was subject to conditions.