[19] If restrictions and limitations imposed by the asset owner significantly hinder the organization from fully implementing the intended investment strategy, the assets may be considered non-discretionary.
There are degrees of discretion and not all restrictions and limitations will necessarily result in assets being considered non-discretionary.
This measures the total market value of the assets that are advised by a financial institution, which is often an investment consultant or other intermediary.
In general, the advisory firm does not have discretion to manage the assets.
Rather, in a non-discretionary manner, it provides advice and makes recommendations as to how those assets may be managed.