Hi all, I'm currently running an SEC-registered RIA firm based out of Delaware. Without going into too many details, my firm is exempted from CFTC/NFA registration as I don't have US clients. However, I'm thinking about pursuing this anyhow in order to tap into the US market, and as a precaution should the regulations change. Having said that, can someone provide info on the concrete steps, costs, filing/reporting requirements etc. etc. to register as CTA? Is it worthwhile, considering that my target clients are still primarily based out of the US? Thanks in advance. Cheers
Whoever advises on your SEC/Finra registration should also be able to advise on CTA. If you want to check on your own, the NFA seems to be reasonably helpful. Also, CME has a free booklet entitled "How to Become a CTA" that was published quite a while ago but might still be available. In general, you need to pass the Series 3 exam, submit a simple application with fees, and submit a fingerprint card. At some point you will probably need to write a disclosure document and get that past the NFA. You can sponsor yourself as a CTA. If you decide to set up a pool, you will need to register also as a CPO. Pool accounting is very expensive.
http://www.nfa.futures.org/NFA-registration/cta/index.HTML Total initial cost (for futures only) should be about $1200, (cost of fingerprints, if applicable, is local to you).
Thanks for the info. Do you need to register with both CFTC _and_ NFA, or will either do? If both, which one to register with first?
You should have no contact with CFTC unless you want to lobby for rule changes or they start an enforcement action against you. NFA does everything for registration.
Ok thanks for the info. Is assistance from a third-party necessary or is the process simple enough to do yourself in your opinion?
By the way, what are the on-going compliance issues and associated costs that need to be taken into consideration after NFA registration?
I was registered for only one year (1996-97), and I did the registration process and disclosure document on my own. I didn't need pool registration, and probably would have outsourced it if I did. I was warned that the NFA audits were burdensome, but I never got audited. I also never had any clients because I am the world's most inept salesman. Most of the fees are yearly. You also need ethics training which you can buy online and is not too expensive. I think that's all.
Ok thanks! Sorry for being curious, but why register if you only trade proprietarily? If returns are ok you don't need to sell, or...?
I wanted to be a money manager and make big bucks. I naively thought my trading record would sell my services, but that was not the case. I am able to pay the rent trading my own capital, but I'm not getting rich. But I no longer have any interest in managing money.