Firms which provided investment advice to pooled investment vehicles trading in spot forex (the off-exchange foreign currency markets) are deemed to be “forex commodity pool operators” or “forex CPOs”. Like regular CPOs which must be registered with the Commodities Futures Trading Commission (CFTC), forex CPOs will also need to be registered with the CFTC through the National Futures Association (NFA). Note that if a forex CPO also provides advice to separately managed accounts, the firm would also be a “forex commodity trading advisor” or “forex CTA” and be subject to registration like a traditional CTA.
