FLAUM, Circuit Judge. Commodity trading advisors are required to register with the Commodity Futures Trading Commission (“CFTC” or “the Commission”) pursuant to 7 U.S.C. § 6m(l) — a provision of the Commodity Exchange Act. This requirement probably would not have drawn objection if it was limited to purveyors of personalized, client-specific trading advice. The language of the reg…
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