Registration Question

James Stillman is an investment adviser representative with Rock, Feller, and Standard (RFS), a covered adviser with its principal office in State O. Stillman works out of an office in State P and has 4 retail clients there. In addition, Stillman has 25 retail clients in State D, 6 retail clients in State M, and 1 retail client in State O. Stillman would be required to register as an investment adviser representative in

A) States D and M.
B) States P, D, and M.
C) State P.
D) States P and O

I am a bit confused here. I chose P,D, and M since in P and M, he has more than 5 retail clients whereas in P, he has an office but the answer was state P only. What did I miss? Please advise. Thanks

I think it’s because James works for a (federal) “covered adviser.” Since the Investment Advisor is registered with the SEC, James only need to be registered in the state where his office is located.

This is from Series 66, 5.3.4