The Commodity Futures Trading Commission issued an interpretive guidance indicating that receipt of separate compensation by a futures commission merchant, an introducing broker or a swap dealer in connection with commodity trading advice that was “solely incidental” to the FCM’s, IB’s or SD’s principal business would not require such entity to register as a commodity trading advisor. Although the CFTC’s interpretive guidance was issued in response to specific requirements of European Union-based investment managers to unbundle payments for investment research under the Markets in Financial Investment Directive II, the CFTC made clear that its guidance was not limited to payments received from EU-based managers.