In working as an investment adviser (ia), you see opportunity to benefit your clients holding nondiscretionary accounts by gaining access to initial public offerings. in order to have more choices as to the initial public offerings, you decide to hire a person, who is unaffiliated with your firm and not registered with the sec or in any state. this person charges a finder's fee of a quarter of the value of any investment secured through the use of the service. according to the investment advisor's act of 1940, the person charging the finder's fee cannot accept such payments because
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In working as an investment adviser (ia), you see opportunity to benefit your clients holding nondiscretionary accounts by gaining access to initial public offerings. in order to have more choices as to the initial public offerings, you decide to hire a person, who is unaffiliated with your firm and not registered with the sec or in any state. this person charges a finder's fee of a quarter of the value of any investment secured through the use of the service. according to the investment advisor's act of 1940, the person charging the finder's fee cannot accept such payments because
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