An adviser in State Y has only insurance companies as clients. The firm has no office in State Z, but advises an insurance company located there. Is the adviser required to register in State Z?

1. ANo, because the adviser only deals with institutional clients and has no office in State Z.✓ Correct answer
2. BYes, because the adviser solicits clients in State Z.
3. CNo, because insurance companies are always exempt from state laws.
4. DYes, unless the insurance company is a captive insurer.

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