Who qualifies as affiliates of an Investment Advisor (IA)?

Affiliates of an Investment Advisor (IA) encompass a broad range of individuals and roles that play significant parts in the operation or governance of the advisory firm. This includes officers, partners, and directors who typically have decision-making power or a managerial role within the organization. Their involvement is crucial as they often help shape the policies and strategies of the firm.

Nonclerical employees, although they may not be involved in higher-level decision-making, still contribute to the overall functioning and operation of the IA. Their roles could be involved in providing advice, research, or client support, which can also tie them to the core activities and responsibilities of the IA.

Additionally, individuals who own 5% or more of the outstanding securities typically have a financial interest in the firm, which can influence its direction and performance. This ownership signifies potential control or a significant stake in the operations of the advisory firm.

Considering these aspects, all of these categories formally qualify as affiliates of an Investment Advisor, reinforcing the idea that anyone with a substantial managerial role, employment dependency, or ownership stake is intertwined with the firm's activities and accountability. Therefore, the correct answer encapsulates the broad definition of affiliates under the regulations governing investment advisors.