A recent case before the SEC has only confirmed this advice. The SEC barred a person from the securities industry, and required disgorgement in the amount of $400,000 because the person failed to register as a broker-dealer while selling private fund interests. The cited person communicated with investors, discussed the investment, handled funds, and received a commission when it sold notes issued by a third party fund, who then proceeded to go out of business. See https://www.sec.gov/litigation/admin/2017/34-80083.pdf.

In short, the SEC is not shying away from requiring broker-dealer registration, and people should think twice before proceeding with any securities activity.