Eligibility · 17 CFR § 4.7

Qualified Eligible Persons.

The firm's programs are offered exclusively to Qualified Eligible Persons as defined in CFTC Regulation 4.7. This page explains, in plain language, why eligibility is limited, who qualifies, and how qualification is verified.

Saratoga Capital Advisors, LLCNFA ID 0578068QEP Eligibility · 2026
01

Why eligibility is limited

A sophisticated-investor exemption.

Saratoga Capital Advisors offers its program under CFTC Regulation 4.7, an exemption that allows a registered commodity trading advisor to advise certain sophisticated investors without delivering a CFTC-reviewed disclosure document. In exchange, the program may be offered only to Qualified Eligible Persons — investors the regulation presumes able to evaluate the risks of a futures trading program on their own.

This is why no performance information appears on this website.

Program materials, including performance information, are furnished only after a prospective client’s QEP status has been verified.

02

Who qualifies · by status

Qualifying without a portfolio test.

Certain investors qualify by status alone, with no additional portfolio requirement. The principal categories:

Regulated institutions
Futures commission merchants, registered broker-dealers, and certain banks, insurance companies, and investment companies acting for their own account.
Registered professionals
Commodity pool operators, commodity trading advisors, and investment advisers that meet the regulation's registration, tenure, and assets criteria.
Qualified purchasers
Persons who are “qualified purchasers” under Section 2(a)(51) of the Investment Company Act — generally individuals with $5 million or more, and institutions with $25 million or more, in investments.
Knowledgeable employees
Certain principals and employees of the advisor who participate in its investment activities.
Non-United States persons
Persons located outside the United States, as defined in the regulation.
QEP-owned entities
Trusts and entities in which all owners or participants are themselves Qualified Eligible Persons.
03

Who qualifies · by portfolio

Accredited investors with a qualifying portfolio.

Most individual investors qualify through a second path: investors who meet the definition of accredited investor under Regulation D of the Securities Act — among other enumerated categories — and who also satisfy the regulation’s Portfolio Requirement by meeting any one of the following:

$4,000,000

Securities portfolio

Ownership of securities and other investments with an aggregate market value of at least $4,000,000.

$400,000

Margin on deposit

At least $400,000 in exchange-specified initial margin and option premiums, together with required minimum security deposits, on deposit for commodity interest transactions during the preceding six months.

½ + ½

Pro-rata combination

A proportional combination of the two — for example, half of the securities threshold together with half of the margin threshold.

Any one of the three satisfies the Portfolio Requirement.

04

Verification

How qualification works.

  1. Request materials

    A prospective client contacts the firm through the materials request form or by email.

  2. QEP questionnaire

    The firm provides a short questionnaire in which the prospective client identifies the basis of their qualification.

  3. Materials furnished

    Once QEP status is established, program materials — including performance information and the advisory agreement — are furnished directly.

This page is a plain-language summary provided for convenience. The text of CFTC Regulation 4.7 controls in all cases, and nothing on this page is legal advice. Prospective clients should consult their own advisers regarding qualification.

Believe you qualify as a QEP?

Request the program materials and the firm will respond with the qualification questionnaire and next steps.

Request materials