Which of the following individuals would be most likely to need to register with the SEC under the Investment Advisers Act of 1940?

  1. Adam who retired last year from a big brokerage house, but he recently started providing services to 12 clients who live in his neighborhood that he met while out golfing.
  2. Belinda who writes weekly investment articles for a local newspaper.
  3. Carter who provides incidental services as an accountant.
  4. Diane who provides investment services only to three large insurance companies.