Which of the following qualifies as an Investment Advisor Representative?

I. Victoria Seagle, Vice President of Sales at GoodHands Capital Management
II. Jason Black, who files for IRS extensions at an accounting firm, which is a sister company of GoodHands Capital Management
III. Stacey Linter, a sales executive who brings in new accounts to GoodHands
IV. Joshua Johnson, a financial reporter who covers stories about Good Hands for the Wall Street Journal
a) I, II & III
b) I & III
c) II, III & IV
d) All of the Above

The correct answer is b.
An Investment Advisor Representative (IAR) is defined as any partner, officer, or other individual affiliated with an Investment Advisor that meet the following criteria:
a) makes recommendations or gives advice pertaining to securities;
b) manages accounts or portfolios for clients;
c) determines the type of advice or recommendation will be given;
d) sells, negotiates or offers the sale of investment advisory services and/or;
e) supervises the employees who perform any of these functions.

Victoria is an officer and a supervisor and fits "e" in the criteria definition. Stacey is a sales person and fits "d" in the definition. Jason''s work is clerical and does not work for GoodHands, therefore, he does not meet the definition. Joshua from the Wall Street Journal fits none of the criteria either.


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