I know a guy that started a hedge fund and blew it out. He lost 13 million dollars in about three months.....all that was left was 200k. Amazingly enough he's got a new fund. All he trades are S&P futures contracts. Doesn't he legally have to register as as CPO if all he trades are futures contracts. If he registers as a CPO then he has to disclose his previous track record. Is this correct?