they can only be exempt if they DO NOT collect a commission (transaction-based or trader-based or similar) but rather make profits through PnL made through accounts with a registered broker-dealer with proper supervision. The oversight then falls on the B/D and not the firm. In Nonko and Lewis Firm Trading and Titan Equity Trading and all these other places, the exemption does not apply. They make commission on your trades as their revenue and your money is in your personal account.
You guys need to understand the difference. If you are paying commissions to the firms, they must be registered as a broker-dealer. If you are only paying a profit split and the commissions are pass-through, the firm does not need to register but the accounts do need to be at a registered broker-dealer for supervision.
You guys need to understand the difference. If you are paying commissions to the firms, they must be registered as a broker-dealer. If you are only paying a profit split and the commissions are pass-through, the firm does not need to register but the accounts do need to be at a registered broker-dealer for supervision.