So many of these auditors will have been issuing opinions for broker-dealers and FCMs that may have been sparsely or not at all inspected by the SEC, CFTC, FINRA or an SRO.
We began to prepare the necessary paperwork for a bulk transfer of our customer accounts to another FCM, talking with other FCMs we work with to see who could facilitate the transfer the easiest.
This gives EU banks offering forex trading to U.S. customers time to register in the U.S. But I think FI refers to banks and not CFTC-registered FCMs, which probably include the FDMs (forex-dealer merchants, the prior designation) too.