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Robin,
In my opinion, The CFTC is going to try to charge you with failing to
register as a CTA. I sincerely hope that you can clear this up with a letter
but doubt it.
Once anyone is registered, the CFTC has a legal right to demand subscriber
lists, financial records and anything else even remotely related.
Again, in my opinion this is OK if the CTA is managing money, has power of
attorney or gives individual advice.
If you have only used this or another list to talk about your program, then
you haven't given individual advice. However, if you have communicated with
an individual and given any advice or opinion to an individual, BINGO.
Good luck Robin,
Manning Stoller
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