Definition of an Investment Adviser Representative

What this video covers

• The five functions that trigger investment adviser representative (IAR) status: making recommendations, managing accounts, determining advice, soliciting advisory services, and supervising any of the above
• Why soliciting alone makes someone an IAR even if they never manage a dollar or give a single stock pick
• Why supervising IARs also makes you an IAR, with no separate supervisor-only license under state law
• Why clerical and ministerial personnel (filing paperwork, updating records) are excluded from the IAR definition despite touching sensitive account files
• The critical difference between the state definition (zero numerical thresholds, any function qualifies) and the federal definition (more than 5 natural-person clients AND more than 10% of total clients)
• How to apply the two-part federal math test and why a supervised person with 4 or fewer natural-person clients is not a federal IAR
• Why qualified clients (net worth greater than $2.7 million or assets under management greater than $1.4 million) are invisible to the federal client-count math
• Why a home office counts as a place of business if an IAR regularly communicates with clients from that location