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Jul 30, 2005 2:46 am

Regarding seiminars that teach investment principals and are not selling product.

What NASD or SEC rule states that we cannot charge attendees for our time in addition to materials or room rental? I believe I read this somewhere while studying for one of the exams we all had to pass.

If this rule exists, what is the reasoning behind it?

If we teach a class, why can’t we like any other teacher get paid for our time? I cannot think of another topic/subject that is taught for free.

If this rule does not exist, great! Because this is a great way to smooth out the ups and downs in income. Plus, attendees are usually more serious when they pay for something.


Aug 1, 2005 1:37 pm

I have passed the 66 and am an Investment Advisors. I can charge fees to get advise. So, can an IA charge fees for teaching a course in personal finance? Is there some regulation that says we cannot receive compensation for our labor/time to teach a finance course?

Aug 1, 2005 1:38 pm

Sorry, terribly tired, will rephrase. As an IA can we charge fees to teach a course? Is there a regulation that says we cannot be compensated for our labor/time?

Aug 3, 2005 12:49 pm

I asked the question above because my firm said we can only charge for hard expenses (room rental, books) that can be reimbursed. We must show receipts. I thought once we became an IA we could give advise for a fee which would include courses. Is there a SEC or NASD rule that prohibits this practice?

Please advise.

Aug 3, 2005 2:27 pm

I don't think there is any particular rule that prohibits that.  It may just be a policy of your b/d.  Remember, you are an Investment Advisor Representative acting through your b/d's RIA.  So, what you can do is determined to a great degree by your b/d's RIA ADV & client advisory agreements.   My b/d (RJFS) has a pretty broad menu of things its IAR's can do which are specifically enumerated in our ADV.  I believe it does include the ability to charge fees for classes.

Instead of going through this research process, just ask your b/d why you can't charge for a class over & above "hard" costs.  If they say it's a regulatory restriction, have them point you to the specific rule.  If it's just because their RIA structure currently doesn't include such flexibility, ask them to change it.  If it's a policy of theirs, ask them why.