An individual who is a registered representative with a broker-dealer prepares financial plans for customers under the supervision of the broker-dealer and does not charge for the plans. The individual takes commissions on transactions that result from the implementation of the recommendations included in the plans. Under SEC Release IA-1092:.
A. both the individual and the broker-dealer must register with the SEC as an investment adviser representative and an investment adviser, respectively
B. neither the individual nor the broker-dealer need register with the SEC as an investment adviser representative and an investment adviser, respectively
C. the individual must register with the SEC as an investment adviser representative; the broker-dealer is not required to register with the SEC as an investment adviser
D. the individual need not register with the SEC as an investment adviser representative; the broker-dealer is required to register with the SEC as an investment adviser
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