A solicitor refers clients to a third-party investment adviser and receives a flat referral fee for each client. The solicitor gives no investment advice. Under the USA, the solicitor is:

1. AAn investment adviser because they receive a fee.
2. BNot an investment adviser, as they do not provide investment advice.✓ Correct answer
3. CAn investment adviser only if the referral fee is ongoing.
4. DAn investment adviser if they are affiliated with a registered adviser.

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