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Be safe!

I think that tips the scales in favor of allowing this. She's basically not an advisor.

Thank you, QDROphile, Bird, and Belgarath, for your helpful thinking. While I dislike many lawyers’ use of pro bono to describe the category, many professionals consider a moral responsibility to volunteer one’s service, without fee, to those who would not be a paying client but need the service. Some investment advisors similarly volunteer uncompensated services. I had thought about whether an opportunity for referrals, or even good will, might be indirect compensation that invokes ERISA § 3(21)(A)(ii). First, the circumstances of the charity, its employees, those who serve on its governing board, and its donors are such that it’s unlikely any of them ever would become any advisor’s paying client. Further, the advisor is unregistered, and so cannot accept a paying client. (Because she is retired, she will remain unregistered.) This also makes recognition or good will something that won’t result in compensation. Thank you for helping me think this through. You have given me a Christmas present I value much more highly than others.