A newsletter publisher bases advice on the specific securities positions of each subscriber. Under the USA, which best describes the publisher's regulatory status?

1. AThe publisher is an investment adviser and must register unless another exemption applies.✓ Correct answer
2. BThe publisher is excluded as a bona fide publication.
3. CThe publisher is exempt if the newsletter is distributed nationally.
4. DThe publisher qualifies for the LATE exclusion.

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