Definition of an IAR
Chapters in this video
- 0:00 The two-part test: association plus one function
- 1:02 Why Ivan and his cat are not IARs
- 2:34 The five statutory functions that trigger IAR status
- 3:20 Saul the solicitor: advice-free but still an IAR
- 4:44 Clerical and ministerial exclusions at the firm
- 5:24 Patty the partner: title does not equal function
- 6:16 Natural person requirement and no lone wolves
- 7:17 State-registered IA vs federal covered adviser registration footprint
- 7:54 Rapid-fire exam recap
What this video covers
- The two-part test for IAR status: association with an investment adviser (IA) firm plus performance of at least one of five specific functions
- The five statutory functions that trigger IAR classification: making recommendations, managing accounts, determining advice, soliciting advisory business, and supervising
- Why solicitors who never give advice can still be IARs, and how state discretion affects the general principle
- Why partners, officers, and directors are not automatically IARs if they perform purely clerical, ministerial, or administrative duties
- The exclusion of non-natural persons: why firms cannot be IARs and why free-standing IAR registration does not exist
- Where IARs must register: the distinction between state-registered IAs (clients or place of business) and federal covered advisers (place of business only)
- How to spot exam traps that bait you with impressive titles or omit the association requirement
Read the full lesson, free
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