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(a) provides advice, or issues reports or analyses, regarding securities or as to the advisability of investing in, purchasing, or selling securities ("investment advice"); (b) provides such services for compensation; and (c) is in the business of providing such services.
(a) holds itself out as an investment adviser or as one who provides investment advice; (b) receives any separate or additional compensation that represents a clearly definable charge for providing advice about securities, regardless of whether the compensation is separate from or included within any overall compensation, or receives transaction-based compensation if the client implements the advice; or (c) on anything other than rare, isolated and non-periodic instances, provides specific investment advice, including a recommendation or analysis about specific securities or specific categories of securities.
(a) holds itself out as an investment adviser or as one who provides investment advice; (b) receives any separate or additional compensation that represents a clearly definable charge for providing advice about securities, regardless of whether the compensation is separate from or included within any overall compensation, or receives transaction-based compensation if the client implements the advice; or (c) on anything other than rare, isolated and non-periodic instances, provides specific investment advice, including a recommendation or analysis about specific securities or specific categories of securities.
(a) charged its financial advisory clients for investment advice separately from its financial advisory fee; (b) received any compensation that represented a "clearly definable" charge for providing advice about securities, regardless of whether that compensation is separate from or included in any overall compensation; or (c) received transaction-based compensation if the client implemented the advice.
(a) the advice about the money market funds is solely incidental to the financial advisory services that the financial advisor provides to its financial advisory client; (b) the financial advisor receives no separate, additional or transaction-based compensation for the advice about the money market funds; (c) the financial advisor does not hold itself out as an investment adviser; and (d) the financial advisor does not have discretionary authority over the assets of its financial advisory client that are invested in the money market funds.
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