Saturday, June 27, 2009

Investment Adviser Rep Registration

Mary Ellen represents a federal covered investment adviser in State A, with her main office there. Once a month, as she passes through State B on her way to work, she meets with 4 financial planning clients at a diner to discuss investing strategies. Therefore
A. Mary Ellen need not register in State B due to the number of clients there
B. Mary Ellen must register in State B
C. Mary Ellen need not register in State B as she has no place of business there
D. Mary Ellen may register with either State A or State B

EXPLANATION: Mary Ellen does have a place of business in State B, so the number of clients is irrelevant.


  1. Great question to ask. I had to read it again and again because my first inclination was to go with C. However, getting deeper into the question it states 4 financial planning clients (which in my mind I was switching clients to colleagues). As you can see I fall into the bad habit of not reading the question CAREFULLY. Anyhow, great question to ask and help me with my struggle of trying to whiz past the question.

  2. yes, a "place of business" is not necessarily an "office." in fact, if she "holds herself out" as being avaiable to meet at a particular location, she has a "place of business" in that state.