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