Person who manage separate accounts for each client are required to register as a commodity trading advisor (CTA).

A CTA is defined as "any person who, for compensation or profit, engages in the business of advising others, either directly or through publications, writings or electronic media, as to the advisability" of buying or selling commodity futures or option contracts. Persons meeting this definition are required to register as a CTA unless they have:

provided advice to 15 or fewer persons during the past 12 months and do not generally hold themselves out to the public as a CTA; or

furnishes trading advice solely to a commodity pool (or pools) of which they are the registered CPO or are exempt from CPO registration; or

is in one of a number of businesses or professions listed in the Commodity Exchange Act or the CFTC regulations and the providing of advice is solely incidental to the conduct of that business or profession; or

is registered in another capacity and the advice is solely in connection with acting in that other capacity; or

is a registered investment adviser under the Federal Securities Laws who provides futures advice incidental to providing securities trading advice to the "otherwise regulated'' trading vehicles files a prescribed notice with the CFTC specified in CFTC Rule 4.5.

To make sure you do not run afoul of these very important statutes and rules, it usually makes sense to consult with an attorney experienced in commodities matters, who will analyze your situation and proposed method of operation to assure compliance with law. The consequences of not complying with the laws are very severe.