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Series 63: Regulation of Investment Advisers
Series 63 practice questionhardNuance—Firms Acting Both as Advisers and BDs

William Blair, a dually registered broker-dealer and investment adviser, offers an advisory wrap-fee program but does not execute trades in the program. Under the USA, which statement is MOST accurate?

  1. AWilliam Blair is excluded from investment adviser status because it is also a broker-dealer.
  2. BWilliam Blair is acting as an investment adviser for wrap-fee clients and must be registered as such.✓ Correct answer
  3. CWilliam Blair is only subject to broker-dealer regulations for these clients.
  4. DWilliam Blair is not required to be registered as an investment adviser because it executes no trades.
Explanation

Why BWilliam Blair is acting as an investment adviser for wrap-fee clients and must be registered as such.

A firm acting in an advisory capacity and receiving compensation for advice is an investment adviser—even if also a broker-dealer (USA §401(c)). Execution of trades is not required for adviser status. Options A, C, and D all misstate the regulatory requirements.

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