Yes. Brokerage firms must be registered with both the CFTC and the SEC in order to offer and trade these products.
If your firm is a registered FCM or IB that is also fully registered with the SEC as a broker-dealer, it has no further registration obligations.
If your firm is not currently registered as a broker-dealer, it must notice register by filing a Broker-Dealer Notice Registration Form (Form BD-N) with NFA. You can download this four-page form directly from NFA's Web site (www.nfa.futures.org). There is no filing fee and the firm's notice-registration is effective upon filing as long as the form is complete and the eligibility requirements are met.
If your firm notice-registers as a broker-dealer, it will be exempt from some requirements of the securities laws that duplicate futures requirements. These include financial requirements, prohibitions on certain exchange members doing both proprietary and customer trading, and risk assessment rules. Also, your firm is not required to become a member of FINRA since the firm's securities business must be limited to offering and trading security futures products.