The Commodity Exchange Act defines a CTA as any person who:
For compensation or profit, engages in the business of advising others, either directly or through publications, writings, or electronic media, as to the value of or the advisability of trading in commodity interests;
For compensation or profit, and as part of a regular business, issues or promulgates analyses or reports concerning any of the activities referred to in the first prong;
Is registered with the CFTC as a CTA; or
The CFTC, by rule or regulation, may include if the CFTC determines that the rule or regulation will effectuate the purposes of the Commodity Exchange Act.