I had a conference call with an attorney for an FCM we work with last week about this, but I want to know the opinion of the real soldiers in the trenches. Please note: we don't do any futures or are planning to ever; spot forex only. We have a few forex retail IB sites, but during the last two years have been focusing on funding traders (not necessarily CTA's). Initially, we started funding these traders with the retail investors that came through our websites; but this year we have started looking for forex traders for a financial institution (allocator) who funds them - so the focus has moved away from the retail investor almost exclusively. Based on this info, I asked the attorney if I can get by [in the meantime] with getting the series 3 and registering my firm as a CTA. The FCM's I work with on the retail side want us to register by next year anyway to continue to pay us, so maybe I'll be able to kill two birds with one stone. He told me that as long as I stuck to forex and not futures, I would be OK for now. Since we are not really doing the management of the accounts (retail or institutional) â just referring the funding sources to the traders, I'm planning to do the DDocs without any performance info. What do you guys thing about this? When I do this, will still be able to work with non-registered traders like I do now? A lot of people refer to the inability to deal with non-members, but I think this is mainly if I deal with futures. I only plan on dealing with forex. Will this fly? I understand that this is not the perfect thing to do. I'm of the opinion of setting up shop offshore to avoid a lot of the hassles, but can't do so now due to family reasons; so the CTA intermediary step might have to do for the time being. I really appreciate what you think. Thank you.