and coins. Even those who receive finder's fees for referring potential clients to investment advisers are considered to be investment advisers themselves. Generally excluded from coverage under the act are those professionals whose investment advice to clients is incidental to the professional relationship. The IAA exempts "any lawyer, accountant, engineer, or teacher whose performance of such services is solely incidental to the practice of his profession." The key phrase is "solely incidental." An accountant, for instance, who acts as an investment adviser is in fact considered to be an investment adviser under the Act. If professionals are not to be considered investment advisers under the IAA, they must not present themselves to the public as investment advisers, any investment advice given must be reasonably related to their primary professional function, and fees for the "investment advice" must be based on the same criteria as fees for the primary professional function. The IAA, however, excludes from its definition of an investment adviser "any broker or dealer whose performance of such [advisory] services is solely incidental to the conduct of his business as a broker or dealer and who receives no special compensation thereof." Banks, publishers, and government security advisers are also excepted from the Act. Those who call themselves "financial planners" may, under certain circumstances, be considered investment advisers under the Act. The difference between a financial planner and an investment adviser, as it relates to the IAA, is also addressed in the aforementioned Release 1092. Registration Under the Act, investment advisers must register using Form ADV accompanied by a relatively modest fee. Form ADV asks for such information as educational background, experience, exact type of business engaged in, assets, information on clients, history of a legal and/or criminal nature, and type of investment advice to be offered. Registration under the Act does not constitute an endorsement of the investment adviser, and the person or firm may not advertise as such. Part 2A of Form ADV forms the basis of the "brochure" that registered advisers must provide to clients. Registered investment advisers are required to update their Form ADV at least annually. Advisers may receive compensation based on the performance of their advice only under prescribed circumstances, and they may not engage in excessive trading or profit from market activity resulting from their advice to clients. Investment advisers must also act in the best interest of their clients at all times