The enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act1 (Dodd-Frank Act or Act) has accelerated the process of erasing the distinction between a registered investment adviser and a "mere" broker whose advisory services have traditionally been considered only incidental to the brokerage relationship. The Act is audacious in its scope and embraces virtually all aspects of the financial services universe—from executive compensation to advertising and securities brokers to mortgage lenders. Indeed, it has been called the "most sweeping overhaul of the United States financial regulatory system, a transformation on a scale not seen since the reforms that followed the Great Depression."

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