Yes but you're missing the point that an unscrupulous advisor would much prefer to be in charge of his own oversight than have a dealer breathing down his neck.
It's actually funny the argument you are making because you are just making assumptions that the dealer removes all responsibility from the advisor. In my experience it is the opposite. Their oversight keeps advisors aware of the regulatory requirements. And you are also assuming that being in charge of their own compliance will just make every advisor more knowledgable of the regulations and follow them. Again, my experience is the opposite.
Either way a dishonest advisor is likely to find ways to skirt the rules. I just think it is easier when they don't have a dealer. My assumption is the dealer is doing their job, which may not always be the case.
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