Insights & Education · 02 · The advisor

What is a CTA?

A commodity trading advisor is a federally defined, federally registered category, not a marketing label. Where an RIA advises on stocks and bonds under SEC oversight, a CTA advises on futures under CFTC oversight, with the National Futures Association as the industry’s self-regulatory examiner.

Saratoga Capital Advisors, LLCNFA ID 0578068Investor Education · September 2026
01

The terms you know

Where a CTA sits among the names you already know.

Most investors arrive with a vocabulary built around securities: advisers, wealth managers, funds. A CTA fits that map in one specific place, and the differences are structural, not cosmetic.

What it isHow the CTA relationship differs
CTA (commodity trading advisor)Advises on futures, or directs trading in client accounts under written authority; registered with the CFTC, member of NFA.The subject of this comparison. Saratoga is a registered CTA trading separately managed accounts.
RIA (registered investment adviser)Advises on securities (stocks, bonds, funds) under SEC or state oversight, usually across your whole portfolio.The closest cousin. A CTA is the same relationship shape for futures: advisory authority over an account you own, registered with the CFTC and examined by NFA.
Wealth manager / financial advisorA service label, not a registration category; typically an RIA representative or broker offering planning and broad portfolio management.A CTA may offer several defined trading programs; your account follows the specific program you select. It does not do financial planning and does not manage your broader portfolio.
Hedge fundA private pooled vehicle. Investors buy interests in the fund; the fund owns the brokerage account and sets the redemption terms.The opposite custody shape. In a CTA managed account you own the account in your own name and grant trading authority you can revoke.
Mutual fund / ETFA registered pooled product; you hold shares of a portfolio managed inside the wrapper.No wrapper. The program trades directly in your account; the positions, cash, and statements are yours at the FCM.
02

Roles & structures

Two regulated roles. Two investment structures.

A commodity trading advisor provides advice about futures and related derivatives. Some CTAs publish research; others receive written authority to direct trading in client accounts. A commodity pool operator does a different job: it operates a pooled vehicle and solicits capital for it.

Neither term names a product. The product is the structure the strategy arrives through: a separately managed account owned by one client, or a commodity pool in which participants’ capital is combined and traded as one account.

Regulated roles

CTAcommodity trading advisor: advises on futures, or directs trading in client accounts under written authority
CPOcommodity pool operator: operates a pooled vehicle and solicits capital for it

Investment structures

SMAseparately managed account: one client-owned account at the FCM, traded under delegated authority
Commodity poolcapital from multiple participants combined in one vehicle; each investor owns an interest in the vehicle

A CTA can manage an SMA, advise a commodity pool, or do both; a CPO can hire an external CTA to trade its pool. Saratoga is a registered CTA managing client-owned SMAs.

Fig. 01Regulated roles and investment structures are different thingsThe role is who is regulated · the structure is what you invest through

In Saratoga’s program, the client owns the account at the FCM and Saratoga makes the trading decisions under a limited power of attorney.

03

The oversight chain

What “registered CTA” actually means.

Firms that direct trading in client futures accounts are generally required to register as CTAs, though the Commodity Exchange Act and CFTC rules contain exclusions and exemptions. Saratoga is registered, and registration sits inside a two-layer oversight chain:

CFTCfederal regulator: registration, antifraud rules, enforcement
NFAself-regulatory examiner: on-site audits every 3–4 yrs, promo review
The CTA firmprincipals & APs fingerprinted, Series 3 tested, written supervision

Quarterly performance filings (NFA Form PR) · prescribed risk disclosure standards · all promotional material requires documented supervisory approval · books and records open to inspection.

Fig. 02The oversight chain: what “registered CTA” meansVerify any firm on NFA BASIC

Anyone can verify the firm (registration, every principal, any disciplinary action) in about thirty seconds on NFA BASIC.

NFA BASIC (nfa.futures.org/basic) is the futures industry’s public registry, comparable to FINRA BrokerCheck. Saratoga encourages prospective clients to review its registration there (NFA ID 0578068) before any conversation. Registration and NFA membership are legal requirements for the activity; they are not an endorsement of any firm or strategy by the CFTC or NFA.

04

The industry

A regulated industry, at scale.

1,164

Registered CTA members

NFA membership as of July 31, 2026.

Reg 4.7

Saratoga’s offering basis

Offered to Qualified Eligible Persons only; disclosure is furnished directly rather than filed for CFTC review.

Saratoga offers its program under CFTC Regulation 4.7, available only to Qualified Eligible Persons. The exemption changes the format of disclosure, not the substance of regulation: antifraud rules, recordkeeping and inspection, and NFA reporting (as applicable) all still apply.

05

Three different jobs

The client, the CTA, and the FCM.

A CTA-managed account involves three parties with three distinct jobs. Keeping them separate is the point of the structure: the firm that decides the trades is not the firm that holds the money.

The clientThe CTA (Saratoga)The FCM (StoneX)
Owns the accountYes: opened and titled in the client’s nameNo: holds written trading authority onlyNo: carries the account on its books
Handles the moneyFunds and withdraws directly with the FCMNo custody; no general withdrawal authorityHolds cash and positions under CFTC customer-fund rules
Makes the trading decisionsNo day-to-day action requiredYes: under the limited power of attorneyNo: executes, clears, and margins the trades
Reports the accountReviews both recordsSupplementary advisor reportingStatements and confirmations for the account

How the money and the authority actually move, and how a managed account compares with a commodity pool, is the subject of the next article, The Separately Managed Account.

06

Fees

Fees, in plain English.

Management fee
An annual percentage of the account’s trading size, billed monthly after each month ends. It pays for running the program.
Incentive fee
A share of net new trading profits: trading gains net of losses, costs, and management fees, measured above the account’s high-water mark, the highest level the account has previously reached. Specific schedules are set out in each advisor’s account documentation.
below the mark: no incentive accrues
account value high-water mark incentive accrues
Fig. 03The high-water markIncentive accrues only at the marked peaks

After a drawdown, no incentive fee accrues until the account recovers past its prior peak; the incentive fee is calculated only on net new profits above the high-water mark, as set out in the agreement.

Educational material only. Futures trading involves substantial risk of loss and is not suitable for all investors; you may lose more than your initial deposit. Nothing on this page is an offer to sell or a solicitation of an offer to buy any interest in any trading program, separately managed account, or other vehicle, and no performance of any Saratoga trading program is presented. Third-party figures are drawn from sources believed reliable as of September 2026 but are not guaranteed. Saratoga Capital Advisors, LLC is a CFTC-registered commodity trading advisor and NFA Member (NFA ID 0578068).