retail investment activity
- 19(a) advising on investments;
- 19(b) arranging (bringing about) deals in investments; 147
- 19(c) making arrangements with a view to transactions in investments147; or147
- (d) advising on conversion or transfer of pension benefits;147
19in relation to retail investments, except when carried on by a firm exclusively with or for professional client 61 or eligible counterparties 61 .