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Compliance / Legal

Overview of AML Policies and Procedures for Introducing Brokers

  • Post published:August 6, 2013
  • Post category:Compliance / Legal

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…

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What Constitutes a Swap?

  • Post published:August 6, 2013
  • Post category:Compliance / Legal

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…

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CFTC Issues Interpretive Letter on Regulation 1.73

  • Post published:June 26, 2013
  • Post category:Compliance / Legal

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…

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NFA’s Board approves expanded Fiscal Year 2014 budget

  • Post published:June 6, 2013
  • Post category:Compliance / Legal

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…

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Reporting Requirements for Memorial Day

  • Post published:May 20, 2013
  • Post category:Compliance / Legal

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…

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Legal Updates for IBs, FCMs and Other CFTC Registrants

  • Post published:May 1, 2013
  • Post category:Compliance / Legal

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”)…

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Strengthening Customer Protections Through Re-Authorization

  • Post published:May 1, 2013
  • Post category:Compliance / Legal

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…

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IB Certified Audits—Reporting Requirements to Keep In Mind

  • Post published:April 29, 2013
  • Post category:Compliance / Legal

After a busy audit season that included many new rules implemented by NFA and CFTC, we would like to share some reminders and insights. Use of Online Payment Systems If…

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FCM Responsibilities for Introducing Brokers’ Communications with the Public

  • Post published:March 27, 2013
  • Post category:Compliance / Legal

FCM Responsibilities for the Review and Approval of their Guaranteed Introducing Brokers' Communications with the Public Recently, NFA has experienced a sharp increase in the number of promotional material submissions…

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Chief Compliance Officer Requirements Become Effective for All FCMs

  • Post published:March 11, 2013
  • Post category:Compliance / Legal

Chief Compliance Officer Requirements Become Effective for All FCMs on March 29, 2013 As we notified Members in Notice I-12-21, the Chief Compliance Officer (CCO) requirements under CFTC Regulation 3.3…

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