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	<title>Comments on: Discussion with CFTC Regarding Forex Registration</title>
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	<description>Blogging on hedge fund laws, starting a hedge fund, news and events...</description>
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		<title>By: Marc Ilgen</title>
		<link>http://www.hedgefundlawblog.com/discussion-with-cftc-regarding-forex-registration.html/comment-page-1#comment-3027</link>
		<dc:creator>Marc Ilgen</dc:creator>
		<pubDate>Fri, 25 Sep 2009 03:04:47 +0000</pubDate>
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		<description>Thanks for the information. I too have been frustrated in trying to get some more specific information regarding new regulations for forex IBs. I have a question for you. A Forex IB can receive trade rebates for accounts that the IB introduces to the FCM. But is an IB the ONLY type of entity that can act as an &quot;introducer&quot;? More specifically, suppose an individual (and/or one person LLC) registers with the NFA as a CTA instead of an IB. (CTA requirements are MUCH less onerous than IB requirements). Is a CTA eligible to receive trade rebates from the FCM? Or is this up to the FCM itself? Suppose the LLC declares itself to be a CTA but does not register as such (claiming the &quot;under 15 customers&quot; exemption). In this case can the self-declared CTA still be eligible to receive trade rebates as an &quot;introducer&quot;? I understand this regs are still being decided, but maybe there is some guidance that can be gleaned from the futures market? Any ideas? Thanks.</description>
		<content:encoded><![CDATA[<p>Thanks for the information. I too have been frustrated in trying to get some more specific information regarding new regulations for forex IBs. I have a question for you. A Forex IB can receive trade rebates for accounts that the IB introduces to the FCM. But is an IB the ONLY type of entity that can act as an &#8220;introducer&#8221;? More specifically, suppose an individual (and/or one person LLC) registers with the NFA as a CTA instead of an IB. (CTA requirements are MUCH less onerous than IB requirements). Is a CTA eligible to receive trade rebates from the FCM? Or is this up to the FCM itself? Suppose the LLC declares itself to be a CTA but does not register as such (claiming the &#8220;under 15 customers&#8221; exemption). In this case can the self-declared CTA still be eligible to receive trade rebates as an &#8220;introducer&#8221;? I understand this regs are still being decided, but maybe there is some guidance that can be gleaned from the futures market? Any ideas? Thanks.</p>
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