- A firm handling transactions only for proprietary persons (such as the firm itself, affiliates, top officers, or directors) need not register as an FCM.
- A non-U.S. firm with only non-U.S. customers does not have to register if it submits all trades for clearing to an FCM.
All registered FCMs and IBs are required to be members of the National Futures Association (NFA), and may also be members of one or more designated contract markets (commodity exchanges). The NFA and the commodity exchanges are self-regulatory organizations that are required to enforce CFTC-approved minimum financial and reporting requirements for their members.
Futures Commission Merchant and Introducing Broker Requirements
FCMs and IBs must satisfy minimum standards for:
- Minimum net capital
- Customer funds (FCMs only; IBs do not hold customer funds)
- Disclosure and other requirements for customers
- Financial and other filings