An investment adviser has its home office in Wisconsin. Its only business is with trust companies, large employee benefit plans, and insurance companies. It has no place of business in Colorado but provides investment advice to two Denver banks, both chartered under Colorado banking laws. There is a new Administrator in Colorado, and it is his opinion that this IA should be required to register in his state. A careful reading of Section 201 of the Uniform Securities Act would indicate that A) the Administrator is correct and the firm must register B) as long as the IA does not have an office in Colorado, there are no conditions that would mandate registration there C) the firm does not have to register because it has no place of business in the state and its only clients are registered financial institutions D) this firm would be exempt from registration with the Colorado Administrator because it is doing business in more than one state