# kaal:claim:2337268-005

**Claim.** Providing investment advice without compensation makes a person less likely to fall within the IAA definition of investment adviser, but the SEC construes compensation for advisory services broadly, which narrows the practical value of that limit.

**Type.** condition  **Support.** argued

**Holds when.**

- determining whether a person is in the business of rendering advice

**Source quote.**

> While providing investment advice without compensation makes the person less likely to provide investment advice as an investment adviser under the IAA's definition, the SEC is broadly construing the meaning of compensation for advisory services.

**From.** Wulf A. Kaal, *Investment Adviser Regulation* (2013), 1. Definitions, page 6

**Cite as.** Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268

**Verify.** sha256 of source PDF `7075ce35282a8ee75b81ae3dec0e19f68631beae7f3c3a00ab2827538dc9e302` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20-%202013%20-%20Investment%20Adviser%20Regulation.pdf

**Topics.** private-funds, securities-law

**Keywords.** investment-adviser-definition, compensation, sec-interpretation, regulatory-scope

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