Registration of Associated Persons

An investment adviser representative (IAR) is generally defined by most states as a person who is paid to:

• • Make recommendations regarding securities
• • Manage customer accounts
• • Determine which securities recommendations or advice to offer
• • Solicit or sell advisory services
• • Supervise investment company representatives

This definition applies to officers and directors of an investment adviser and any other associated person. It does not apply to clerical or administrative positions.

Brokers and dealers, by contrast, engage in the business of buying and selling securities, either on a customer’s b