The Division of Clearing and Intermediary Oversight confirmed that a person registered as an investment adviser with the Securities and Exchange Commission: (1) would come within the CTA definition in Section 1a(6) of the Act if it offered as part of its comprehensive portfolio management a “managed futures account” component; and (2) would be required to register as a CTA with the Commission unless an exemption from registration was available to it. Based upon the facts presented to it, the Division concluded that none of the exemptions from CTA registration in Regulation 4.14 would be available to the investment adviser. The Division further offered that, assuming that none of the adviser’s customers would be in the nature of the collective investment vehicles identified in Section 4m(3) of the Act, the adviser might be able to claim the exemption from CTA registration available under that section.