No; there are a number of ways; operate a financial institution, structure the deal to avoid CFC and PFHC, set-up in the USVI, etc..
None are cheap or do it yourself projects ...
The ISE is saying by account.
http://www.iseoptions.com/legal/pdf/proposed_rule_changes/SR-ISE-2005-31$Fee_Changes$20050629.pdf
See 3A
What prop firms are not complaining ...