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In a message dated 4/23/99 7:52:43 AM Central Daylight Time,
James_Money@xxxxxxxxxxxx writes:
> About 3 years ago I was asking the same questions. The securities attorney
> I was working with essentially said my "loopholes" were the following, such
> that I did not have to be NASD licensed, nor registered as an investment
> advisor:
>
> 1) Fewer than 15 clients.
> 2) Not receiving a fee for the purchase/sale of securities. My fee is
> based upon the net gains/losses rather than the commission for the
> purchase/sale of their stock.
>
> Hope it helps,
> Jim
I believe that the CFTC has a different view. Please check with them, also.
Charlie
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