NFA ISSP Amendments

Reminder: April 1 effective date for amendments to NFA’s Interpretive Notice regarding Information Systems Security Programs—instructions for notifying NFA of applicable cybersecurity incidents In January 2019, NFA issued a Notice to Members announcing amendments to its Interpretive Notice entitled NFA Compliance Rules 2-9, 2-36 and 2-49: Information Systems Security Programs (Interpretive Notice). The amendments provide clarification on common questions related to training obligations and ISSP approval posed by Members to NFA, and impose a narrowly drawn notification requirement to ensure that Members notify NFA of certain cybersecurity incidents related to a Member’s commodity interest activities. The amendments will become effective on April 1, 2019. Cybersecurity incidents…...

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Disruptive Trading Practices

Disruptive trading practices are prohibited and specifically addressed within CME rules and regulations.  CME Group’s Market Regulation team has created the following educational course on Distruptive Practices Prohibited.  If you have a few minutes it’s worth a look. Market Regulation: Disruptive Practices Prohibited – Spoofing...

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NIBA Educational Series – Cybersecurity Briefing

The NIBA is pleased to announce the kick off of its educational series.  This idea is to cultivate ideas, discussion and networking in an intimate setting throughout the year.  This event is hosted and sponsored by Bovill. There’s a gap between Compliance and IT responsibility for security in most organizations. For example, what should an Information System Security Policy cover and how best should it be implemented? We’re delighted to invite you to our briefing and networking event on Wednesday, March 6, 2019, where we will be giving you some tips to help close this gap and discuss challenges with…

NFA adopts Interpretive Notice entitled NFA Compliance Rule 2-9: CPO Internal Controls System

NFA recently adopted an Interpretive Notice entitled NFA Compliance Rule 2-9: CPO Internal Controls System (Interpretive Notice). The Interpretive Notice requires commodity pool operator (CPO) Members, which have the ability to control customer funds, to implement an internal controls framework designed to: Protect customer funds; and Provide reasonable assurance that the books and records of a CPO’s commodity pools are accurate and reliable and that the CPO is in compliance with all CFTC and NFA requirements. The Interpretive Notice will become effective on April 1, 2019. In order to demonstrate an adequate internal controls system, the Interpretive Notice also requires…...

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CME Institute: Market Regulation Course

Market Regulation works to protect market integrity, to enforce rules that protect all market participants, and to act proactively to mitigate risks to prevent damage to the marketplace. Market participants need to understand and comply with Exchange Rules. This course can assist market participants by providing information and resources necessary to meet their compliance needs. [Begin Course]  ...

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FIA Spoofing, Surveillance & Supervision

The CFTC and futures exchanges continue to aggressively pursue “spoofing” cases against traders. When evidence of criminal willful intent exists, they refer certain matters to the Department of Justice for criminal prosecution. The CFTC settled its first spoofing case in late December 2016. The month prior, the DOJ obtained its first criminal conviction for spoofing. Since that time, the CFTC has expanded its enforcement efforts in this area to target firms for failing to supervise traders being investigated for spoofing activity. With this Webinar, Jim Lundy and Nicholas Wendland from Drinker Biddle & Reath LLP will explore the increased regulatory…...

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FY 2018 Agency Financial Report – CFTC

Each year the CFTC publishes an agency financial report which provides data on financial and performance, operations management and information on the CFTC.  This is the 14th annual report that has been published.  Please see the link below to access the report: CFTC 2018 Report...

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Be Prepared – Tax Law Impacts

The recently enacted Tax Cuts and Jobs Act (TCJA) has made several changes to the tax law. Below we have summarized some of the changes we feel may affect some of our client base, mainly traders and investors. The TCJA suspended all miscellaneous itemized deductions, subject to a 2% floor, for individuals including investment fees and expenses. Therefore, investors are no longer entitled to these investment expenses. An important thing to note is that the TCJA did not change investment-interest expense rules. The itemized deduction is limited to investment income, and any excess is carried forward to subsequent years. The…...

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What is an ISSP

An Introduction for Introducing Brokers Security matters, and the NFA and other financial regulators are pushing to help market participants appropriately protect their customers and themselves against cyber threats which could result in stolen data, compromised systems, and the potential theft of funds or other illegal transactions. An Information Systems Security Program (ISSP) is mandated by the NFA & CFTC for futures market participants including FCMs, CTAs and IBs. An ISSP is a written document that describes the actions a Member takes to protect its systems and data against associated risks. It could save your business. NFA guidance allows Members…...

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CFTC & Compliance Issues for 2019

The beginning of a new year is typically when Commodity Futures Trading Commission (“CFTC”) registered, National Futures Association (“NFA”) member firms are most focused on growing their book of business. While the launch of new marketing or trading campaigns is important, attention to shifting operational and regulatory issues is just as critical to running a successful brokerage and/or trading operation. For Futures Commission Merchants (“FCMs”), Introducing Brokers (“IBs”), Commodity Pool Operators (“CPOs”), and Commodity Trading Advisors (“CTAs”) the end of 2018 is the perfect time to take an account of company regulatory obligations. Based on experience with a diverse group…...

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