RegAlert1994-05-13
Added · Updated
SEC Division of Investment Management staff letter: R. Bryan Stoker
The SEC staff clarifies that an author whose writings do not contain advisory information relating to specific securities or issuers, and are not part of a series intended to be updated or supplemented, is not considered an investment adviser under the Investment Advisers Act of 1940. The staff also notes that a financial planner may rely on the broker-dealer exception only if the advisory services are incidental to the broker-dealer business and performed within the scope of employment with a registered broker-dealer. The staff generally declines to express an opinion on the availability of the publisher's exclusion or other exclusions due to the fact-specific nature of the analysis required.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON. D.C. 20549
JIVISION OF
May 13, 1994
INVESTMENT MANAGEMENT
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R.
Lifestyle Publishinq
Bryan Stoker
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P.O. Box 355
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Dear Mr. Stoker: ) ;'~'J10 ---~, - """i, -2. II - - .. . A' ""1 Sykesville, MD 21784 ì:.,eck..Q!l --- _-- J ./ " ; !'
Your letter dated AP~¡:it_~i~1.:1i~g~~~~l!a'~~' Office for response. You state that you have authored and intend
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SEC published 7 documents in the last 30 days. We email you each new one the day it's published.