15000 RT/million/year...that's not a large number... I am executing 12000 - 16000 RT/million/MONTH... Where are you clearing your business since you left RCG ?
Well, I don't think 15000 RT/million/year is the world's biggest number... but if you compare to the vast majority of CTA strategies, it's large. The average I've seen is roughly 4000-5000 RT/mil/mon. I'm currently using Vision as my FCM.
Heech, you need to find out if what your selling is Regestered or unregestered securities by Definition. Second...you need to read up on reg 144, private placement rules. I am senior VP of a small Private Equity Group in Texas. We raise funds for "Oil and Gas" high risk securities. It's not stock but actual rights to "OIL", ie: % of revenue pumped from commerical productive wells. I do have a Series 22 and 63 in all 50 states. However, there are loop holes that allow you to bypass being registered.. Yet, that comes with a price. The biggest price is credability. Due to the Stigma of the Financial World, many people refuse to trust anyone if there is no Remidy of Law. That is all the Series 22 and 63 provide to investors, a course of action via SEC, FINRA and LEGAL REMIDY. They mean nothing else. My advice, don't fuck around as a unliscensed yahoo thinking they can be the next GECKO by raising capital. Do it the proper way as the FEDS are about to re-write much of the securities law and will have a wider scope to crawl up your ass and take you out of the game if one, that's right, one investory complains. And if your thinking about hedgefund....goodluck getting clients...that industry imploded and is not likely to come back anytime soon...and could all but disapear if the short rules the OBAMA crew wants, are placed. Best wishes,
Heech, Make sure that you are talking to an attorney that is well versed with rules of BOTH the NFA and SEC. As was mentioned prior, it depends on the structure of your firm. For the most part, the NFA is ok with you paying marketing fees to licensed AP's through either your firm or an IB...and that should hold whether you are a CTA or CPO. Where it gets sticky is how your CPO is structured. If you are set-up like a typical hedge fund, with a LLP structure, you are under the rule of the SEC and are going to have to pay any marketing fees through a Broker Dealer. With regards to compensating IB's through commissions, it would be possible for your CPO to open accounts at several FCM's. But with respect to having different rates at each, are you really putting your investors best interests first? The easiest way to do this is to accept managed accounts and register as a CTA. Then any IB that opens a managed account for you can charge that account a clearing rate that they have negotiated with that investor (you can/should put caps on this so that it doesn't drastically affect your performance and keeps it reasonable for the investor). You can still do all your execution at one firm (in a block order), and then give-up trades to the different clearing accounts. My advice for you is to stay away from retail oriented IB's that are only interested in charging high commissions. Good Luck!
From what I understand, any owner of the management co. of a CTA/CPO has to be registered with the NFA...even if they are just an equity investor and have nothing to do with the trading side of the business.
It's good you got wise counsel and came to this conclusion. As the attorney probably told you, having "casual" finderss running loose is the third rail of the CPO/CTA business model. Absolutely don't want to step on it. In addition to many other issues, you're responsible for whatever claims they make on your behalf ("can't lose with this guy..."), and "casual" finders generally aren't cross-the-t's types with respect to disclaimers & etc.