Series 63 practice questionmediumPublisher Exclusion – Timing and Content
A website publishes model portfolios every quarter to all subscribers, regardless of their personal holdings. Is the publisher considered an investment adviser under the USA?
- ANo, because the advice is impersonal and regular.✓ Correct answer
- BYes, because the publisher receives a fee.
- CYes, if subscribers use the advice to change their portfolios.
- DNo, if the publisher only recommends mutual funds.
Explanation
Why A — No, because the advice is impersonal and regular.
Impersonal, regular publications not tailored to specific clients are excluded from the IA definition under the USA (Section 401(c)). The fee and subscriber actions do not affect the exclusion.
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