There is a requirement that breakers be accessible to the tenant; NEC citations aside, this is often a requirement modified by local ordinance, and may be addressed by other codes as well.
Depending on the exact configuration .... for example, whether the meters, etc., are accessible, or locked up in an electrical room .... a main breaker in the tenants' panel, as well as a main disconnect before the meters may make sense.
Having a main disconnect has other advantages, even if we are still well under the '6 throws' maximum. Again, depending on the exact jobsite, putting a main in now will save a lot of trouble later, if the place ever grows / is divided past the '6 throws' rule.
Here is one result of such growth:
![[Linked Image]](https://www.electrical-contractor.net/forum/RS/Webb_38A_service.JPG)