Some things can be hard to define. That said, the U.S. is very clear about the things that it doesn't consider to be investment advisors. Here they are:
an investment advisor representative
a lawyer, accountant, engineer, or teacher whose performance of investment advice is solely incidental to the practice of the person's profession
a broker-dealer or its agents whose performance of investment advice is solely incidental to the conduct of business as a broker-dealer and that does not receive...
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