Which of the following individuals 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