Does the CFTC Require Trading Screens and Technology Providers to Register as CTAs?

Highlights
An entity that is simply providing signal aggregation should not need to register as a commodity trading advisor (CTA) with the Commodity Futures Trading Commission (CFTC)
The recent CFTC order requiring a trade signal platform to register as a CTA seems to stem out of the facts and circumstances of the specific case
Further clarification is needed to identify components triggering CTA requirements; the precise facets for integrations between trade signal and trade data platforms and commodity trading providers remain unclear
The Commodity Futures Trading Commission (CFTC) recently entered into a consent order for permanent injunction against defendants Ryan Masten and BareIt Media LLC (d/b/a SignalPush) relating to a September 2020 CFTC enforcement action regarding the marketing, sale, soliciting, fraud, trade execution, and promises of “quick returns” offered on certain websites.
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