Yes. However, broker-dealers who are not currently FCMs or IBs can notice-register as FCMs or IBs if they are registered with the SEC as full-fledged broker dealers and members of FINRA. These firms notice-register with the CFTC on Notice Form 7-R, which is only two pages long. You can download the form on our Web site and file it with NFA. There is no fee, and registration is effective upon filing.