Gibraltar Investment Advisers opened for business last week. Because of the clients brought over from previous affiliations of their IARs, they have started with $94 million under management for various individual and corporate clients. They also signed a contract to manage an additional $10 million for a wealthy individual. Gibraltar will begin managing that individual's portfolio at the beginning of the next calendar quarter. Which of the following best describes Gibraltar's investment adviser registration requirements? A) Gibraltar would be eligible to register at the federal level.
B) Gibraltar need not register as an investment adviser because it will manage funds for an institutional investor.
C) Gibraltar's only option is to register at the state level because it currently manages less than $100 million in client funds.
D) Gibraltar must register with the state(s) and then, within 90 days of the receipt of the additional $10 million, must register with the SEC.