2.3.3.2. Investment Advisers
Member firms registered as investment advisers may not pay a cash fee to a solicitor unless the member is registered as an investment adviser, the solicitor is a person in good standing with the SEC, and the cash fee is paid in conformance with a written agreement.
Cash fees may be paid for impersonal services only, meaning advisory services that do not in any way address specific objectives of specific individuals or accounts. A cash fee may also be paid to any officer or employee of the investment adviser or anyone who controls or is controlled by the investment adviser, as long as the solicitor’s relationship is disclosed to the client at the ti