If my firm is not based in the United States, what requirements does it have?

The following table shows when an individual/entity is required to be registered as an FCM, RFED, IB, CPO, or CTA based on the locations of the entity, its customers, and the exchanges on which contracts will be traded.  Exemptions may, of course, apply. 

Entity Location	Customer Location	Exchange Location	Registration Required
United States	United States	United States	Yes
United States	United States	Foreign Country	Yes
United States	Foreign Country	United States	Yes
United States	Foreign Country	Foreign Country	No
Foreign Country	United States	United States	Yes
Foreign Country	United States	Foreign Country	*
Foreign Country	Foreign Country	United States	No**
Foreign Country	Foreign Country	Foreign Country	No

*The firm must register unless it has received an exemption under CFTC Regulation 30.5 or 30.10. 

** For a foreign broker acting as an FCM, registration is not required only if it submits any commodity interest transactions executed on or subject to the rules of a designated contract market for clearing on an omnibus basis through a registered FCM.

Foreign entities applying for registration must meet the same filing requirements as domestic applicants. In addition, each foreign entity that files an electronic Form 7-R agrees to make its books and records available in the United States for inspection by NFA and the CFTC.

All foreign applicants must file their application materials in English.  FCM and IB applicants required to file financial reports must prepare them in English using U.S. dollars and according to U.S. accounting standards.