Cowpoke Partners is the investment adviser to the Western Vistas family of funds, the firm's sole advisory client. The Western Vistas family currently has $18 million under management. Which of the following statements concerning Cowpoke's registration is TRUE?
a) Cowpoke is considered a federal covered adviser and must register with the SEC
b) Cowpoke must register with both the SEC and each state in which it does business until its assets under management exceed $100 million
c) Cowpoke is required to register only with the states in which Western Vistas has clients
d) Cowpoke is exempt under the de minimis exemption at both the federal and state levels since it only services a single mutual fund complex
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