I registration isn't required I don't think I will register right now. Not looking to manage individual accounts, but rather looking at a (hedge) fund structure.
Okay, got a reply from the CFTC: "Commission staff initially issued Interpretative Letter 76-21 indicating that a commodity trading advisor located outside the U.S. who provides advice as to the advisability of trading futures contracts on domestic exchanges is not required to register with the CFTC or become a member of the National Futures Association (NFA) when it confines its advisory services to areas outside the U.S., and none of the clients is a resident of the U.S. " and "Any person located outside the U.S. that satisfies the above criteria need not apply for this registration relief. Rather, it is available upon meeting the foregoing criteria. If a person is not registered, it may not claim to be a registered CTA when soliciting clients." So, no need to register with CFTC, join NFA and/or apply for registration relief.