ANSWERS FINAL PAPER 2026 FULL
QUESTIONS AND VERIFIED ANSWERS
GRADED A+
⩥ Exemption from Registration Under Federal Law. Answer: 1.
Intrastate Advisors - advisers whose clients, other than an investment
advisor who acts as an investment advisor to any private fund, are
residents of the state in which the adviser has its principal office and
place of business and who do not give advice dealing with securities
listed on any national exchange are exempt.
2. Advisors to insurance companies
3. Private Fund Advisors - (A) an exemption to advisors solely to private
funds with less than $150 million in assets under management in the US.
(B) Non US advisors with no place of business in the US and minimal
assets (under $25 milllion) attributable to US clients and investors. Has
in total or fewer than 15 clients (C) An investor solely to venture capital
funds
4.
⩥ Rule 3(c)(1) Answer: An investment adviser with discretion over more
than 100 accounts using pooled client funds might be considered to be
running an investment company and could require registration under
both the Investment Company Act of 1940 and the Advisor Act.
,⩥ Federal Covered Investment Advisor Answer: 1. Meet a minimum
threshold of $110 m AUM
2. Those under contract to manage an investment company registered
under the Investment Company Act of 1940
3. Those not registered with the SEC because they are covered in the
definition of the Investment Advisors Act of 1940
⩥ Dodd-Frank and Assets Under Management
3 Thresholds Answer: Large Investment Advisors - $100M Plus eligible,
$110 M AUM plus required
Small-Less than $25 M is state unless they would be required to register
in 15 or more state.
Mid size - 25-100
⩥ Exceptions Under Dodd Frank Answer: Register with the SEC for
pension consulatants if they control at least 200m in AUM
-Investment advisors expected to eb elgiible for SEC registration within
120 days
⩥ Exemption for the Registration for Investment Advisors under USA
Answer: If they have no place of business in the state and the only
clients are
1. Broker Dealers registered under the act
,2. Other Investment Advisors
2. Institutional investors
3. Existing clients not resident in the state
4. 5 or fewer clients resident in the state during the preceding 12 months
⩥ Private Fund Adviser Exemption Under State Law Answer: 1. If
qualified for exemption as 3 (c)(1). All investors must be qualified with
1 M in assets managed or 2M net worth not primary residence
2. No bad actors
⩥ 28(e) safe Harbor Answer: What would fall under as soft-dollar
compensation
1. Research reports analyzing the performance of a particular company
or stock
2. Financial newsletters and trade journals could be eligible research if
the relate with appropriate specificity
3. Seminars or conferences with appropriate content
4. Effecting and clearing securities trade
What would NOT Fall under
1. telephone lines
2. Office furniture
3. Travel expenses
, 4. rent
5. any software that does not relate directly to the analysis of stocks
6. payment for training courses for this exam
7. internet services
⩥ Client Referrals between IA and BD Answer: Must be disclosed and
make sure the services beign rendered for the RD cost reasonable
amount
⩥ Directed Brokerage Answer: When an IA suggests that a client sneds
trades through a speciifc BD, it must disclose and conflicts of interest
⩥ An adviser can sell securties to its customers from its own proprietary
accoutn Answer: with consent of client before completion of the trade
⩥ One respect in which the NASAA treats the handling of discretionary
authorization by an IA different than that of the SEC is that Answer:
NASAA allows use of oral discretion for the first 10 business days after
the date of the first transaction
⩥ Voting Client Securities Answer: Part 2A of form ADV must be ifno
on how advisor's vote pn client securities. If the IA has or will accept
authority to vote they have to give a brief descirption pn voting
procedures . If the advisor doesn't have authority this must be disclosed