In working as an investment adviser (ia), you see an opportunity to benefit your clients holding nondiscretionary accounts by gaining access to initial public offerings. in order to have more choices as to the initial public offerings, you decide to hire a person, who is unaffiliated with your firm and not registered with the sec or in any state. this person charges a finder's fee of a quarter of the value of any investment secured through the use of the service.
according to the investment advisor's act of 1940, the person charging the finder's fee cannot accept such payments because:

a) there has been no interest expressed in the investments by the nondiscretionary account holders.
b) the ia has gone outside of their normal broker-dealer research groups who could have performed the same services for less cost.
c) in soliciting information from the offering companies, the unaffiliated person would be then acting on behalf of the ia as a solicitor.
d) the unaffiliated person would be acting as a broker-dealer because they would be receiving commissions based on their finding the securities