An IAR with no office in State R manages 10 institutional clients and 3 retail clients in that state. Which is CORRECT regarding registration?

1. AIAR must register due to exceeding the de minimis client threshold.
2. BIAR must register because institutional clients count toward the de minimis exemption.
3. CIAR is exempt from registration since only 3 are retail clients, and institutional clients are excluded from de minimis count.✓ Correct answer
4. DIAR must register because any number of clients triggers registration.

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