From: "jeffrey E." <[email protected]> To: "Lawrence H. Summers" Subject: Re: Date: Thu, 30 Jul 2015 11:17:50 +0000 did they review your contract. ? re me, no , In all my contracts i am cleat that i am not . . so it might be an issue of no more than your contract. but I would take care On Wed, Jul 29, 2015 at 10:05 PM, Lawrence H. Summers > wrote: I don't know Why can't I trust Wachtell Lipton. If I am an investment advisor what does it mean Are you an investment advisor Sent from my iPhone Please direct all scheduling inquiries to my office at: Follow me on twitter ®Ihsutruners www.larrysummers.com On Jul 29, 2015, at 7:30 PM, jeffrey E. <[email protected]> wrote: I have attached excerpts from West Publishing's Regulation of Investment Advisers. The idea that as long as you are not providing advice about "the purchase or sale of individual securities" you should be ok, is I believe too narrow a scope. See Sections 1:7, 1:8, and 1:9 of the attached excerpts. For example, in Section1:8 it states that: "... For example, a person may be deemed to be giving advice about securities even if the advise does not relate to specific securities, but rather relates to the benefits of investing in securities as compared with non- securities such as real estate or insurance. In addition, the SEC staff has taken the position that to be considered advice about securities, the advice need not be in the form of buy or sell recommendations for particular securities, but can be analyses or valuations of particular securities or of the securities markets generally. Likewise, a person who provides asset allocation or timing advice (i.e., advice about when a client should have a higher or lower percentage of his assets in certain securities or types of securities, such as equity mutual funds or money market funds) is viewed as giving advice about securities. Similarly, a person who advises clients as to the selection of an investment adviser, or who eva