Earlier this year, the CFTC ordered Summit Energy Services, Inc. (“Summit Energy”) to pay a $140,000 civil penalty to resolve allegations that it violated Section 4m(1) of the Commodity Exchange Act by failing to register as a CTA. The CFTC held that Summit Energy engaged in the business of advising 15 or more clients as to the trading of natural gas swaps and futures and generally held itself out to the public as a CTA. Additionally, Summit Energy included descriptions of its “risk management services” on its website and sale brochures, which the CFTC considered to be holding itself out…