An investment adviser with no office in State Y manages accounts for 2 banks and 4 retail clients in State Y. Under the USA, is the adviser required to register in State Y?

1. AYes, because there are more than 5 clients
2. BNo, because institutional clients are excluded from the client count
3. CYes, because all clients count toward the de minimis exemption
4. DNo, because there are fewer than 5 non-institutional clients✓ Correct answer

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