Still Stupid After All These Years
To be perfectly honest, I’m not sure any professional Fund of Fund managers anywhere would admit using any of the techniques below, much less advocating their use. That said, in…
To be perfectly honest, I’m not sure any professional Fund of Fund managers anywhere would admit using any of the techniques below, much less advocating their use. That said, in…
Since April 24, 2002, NFA Compliance Rule 2-9(c) has required all NFA Member FCMs and IBs to have an anti-money laundering (AML) compliance program in place. At a minimum, the…
Most introducing brokers (“IBs”) view their Anti-Money Laundering (“AML”) obligations quite minimally but this can be a monumental mistake. Generally IBs believe their AML responsibilities are limited to ensuring a…
Federal law and NFA rules require Introducing Brokers to maintain an Anti-Money Laundering program implemented by written policies, procedures and controls. NFA provides a number of materials to help IBs…
In a sense, introducing brokers act as gatekeepers to the futures and derivatives markets. Following the passage of the Dodd-Frank Act, certain OTC products which were formerly not regulated are…
Recently, the Commodity Futures Trading Commission (“CFTC”) issued an interpretive letter regarding new CFTC Regulation 1.73 and its applicability to introducing brokers (“IBs”) that enter into give up arrangements with…
A number of factors are having a significant impact on NFA's operating budget for Fiscal Year 2014. The substantial expansion of NFA's regulatory duties has resulted in an 18 percent…
This is a reminder that Monday, May 27, 2013 is Memorial Day. This holiday will impact your regulatory filings as follows: Daily segregated, 30.7 secured, sequestered and daily forex statements…
While most of the attention in the futures industry has been focused upon the new swaps regulatory framework, the Commodity Futures Trading Commission (“CFTC”) and the National Futures Association (“NFA”)…
Every five years, the Commodity Exchange Act must be “re-authorized” by Congress. The Senate is gearing up for that process now. We hope that strengthening customer protections will be the…