Alan:
According to Paul Schwartz, Licensing chief in PA, under the 1972 act, section 102 (J) there are certain exclusions to RIA.
What was relayed to me is that I may not advertise, hold letterhead, define myself as an advisor...etc. And I may trade for less than 5 "clients."
Now, IB does not care about this exclusion, and I suppose I can' t blame them, but it does exist. IB currently requires anybody trading for another persons' account to be a RIA.
I gave up my licenses in 1997 to trade for my personal account and have no intention of getting involved with the RIA requirements. I simply have a few old clients that want my help and I'd be happy to do the work.
I have a few ideas and as soon as I get a legal beagle to check them out, I'll post the findings here if thee is still an interest.