Robert works part-time for JJ Financial Planning, where he develops financial plans for clients. He asks clients a series of questions about their current finances and investment objectives, and uses their answers to create customized financial plans. These plans often include recommendations that they purchase insurance or variable annuities, opening IRAs or other types of retirement accounts. Robert charges a fee for the plans, but he does not earn commissions for selling clients variable annuities and insurance to implement their plans. Is Robert an investment adviser representative