Generally, a person exercising trading authority over a customer's futures or
options account must register as a commodity trading advisor (CTA). The
Advisory states, however, that a person that manages the funds of
customers held by an authorized counterparty solely to trade forex is not
required to register as a CTA but may do so voluntarily. Obviously, if the
person also exercises trading authority over a customer's account for
exchange-traded futures or options contracts, the person must register as a
CTA.
A person exercising trading authority over a customer's account may not
receive or hold the customer's funds. Those funds must be held by an
authorized counterparty.
Nfa Forex Regulatory Guide
