Though disclosure may make the sales comp reasonable under 408(b)(2) (that is, if you view sales as a service), it still does relieve the 406(b)(2) adversity problem. To make any sense of this, it looks like you still need to comply with PTE 84-24 in addition to the 408(b) 2 disclosures.
Continue Reading The Continuing Efficacy of Commission Disclosures Under PTE 84-24 After 408(b)(2)