CFTC/NFA Cyber Security: One Year In

By: Greg Baracy, Turnkey Trading Partners As everyone in the Commodity Futures Industry surely knows during March of 2016 the CFTC and NFA implemented cyber security obligations which were applied to all member firms. At that time Futures Commission Merchants (“FCMs”), Commodity Pool Operators (“CPOs”), Introducing Brokers (“IBs”), and Commodity Trading Advisors (“CTAs”) were all obligated to put in place and maintain a written Information Systems Security Program (“ISSP”) specifically tailored to their unique operations. This article intends to identify areas that NFA has focused on during regulatory examinations Turnkey Trading Partners has assisted with during 2017. Ongoing Risks and…...

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Housekeeping, Reminders and Updates – May 2017

Written by:    Mark E. Ruddy, Esq. Jessica I. Brown, CAMS COMMODITY FUTURES TRADING COMMISSION  Revisions to Form 8-R The Commodity Futures Trading Commission (“CFTC”) has revised Form 8-R, at the request of the National Futures Association (“NFA”).  Form 8-R is the application form for individuals registering as an associated person (“AP”), floor broker, floor trader or to be listed as a principal of an NFA Member firm. The following is a summary of changes to Form 8-R: “Floor Trader Order Enterer” has been added to the list of registration categories. “Floor trader order enterer” is defined as an individual responsible…...

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Ask NFA – May 2017

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly. Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Have there been any enforcement related…...

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NFA NYC Workshop May 10th 2017

Seats are still available for NFA‘s Member Regulatory Workshop in New York on May 10 and Chicago on May 11 Seats are still available for NFA‘s upcoming Member Regulatory Workshops for commodity pool operator (CPO) and commodity trading advisor (CTA) Members. If you’ve already registered, thank you. We look forward to your participation. The half-day workshops will be held at the New York Marriott Downtown in New York, N.Y. on Wednesday, May 10, 2017, and Summit West in Chicago, Ill., on Thursday, May 11, 2017. Each workshop includes two sessions—one on NFA Members’ regulatory obligations regarding cybersecurity and one on…...

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Ask NFA – April 2017

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly.  Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. What are the guidelines for commission…...

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A Broker’s Expanding Obligations

­By Matthew Kluchenek and Michael Sefton It’s no secret that disruptive trading practices are a key concern of market regulators.  Spoofing and other disruptive trading practices have garnered attention in recent years and traders and advisers have had to learn quickly the ropes on permissible trading practices.  Now, it appears that FCMs (and possibly IBs) may have additional obligations as a result of the intense regulatory focus on disruptive trading practices. Recently, an FCM agreed to pay a $190,000 fine in settling a disciplinary matter at CME for violations of CME Rules 575.D and 576.  See CME 15-0185-BC – Saxo…...

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Ask NFA – March 2017

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly.  Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. I am an AP of an…...

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Housekeeping, Reminders and Updates – March 2017

Written by: Mark E. Ruddy, Esq. & Jessica I. Brown, CAMS NATIONAL FUTURES ASSOCIATION Financial Reporting Requirements of Commodity Pool Operators The Commodity Futures Trading Commission (“CFTC”) amended certain items of Part 4 regulations applicable to commodity pool operators (“CPOs”) and their financial reporting requirements. As per the amendments, CFTC regulations now permit the following: The use, in certain circumstances, of specified additional alternative generally accepted accounting principles, standards or practices; A CPO to provide unaudited Annual Report for a pool’s first fiscal year, is specific criteria are met; and A CPO to provide an unaudited Annual Report, if, during any…...

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Ask NFA–February 2017

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly.  Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Are there any scenarios when a…...

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CFTC Names J. Christopher Giancarlo Acting Chairman

Washington, DC — Commissioner J. Christopher Giancarlo was designated per seriatim as Acting Chairman of the U.S. Commodity Futures Trading Commission (CFTC) on January 20, 2017. Mr. Giancarlo joined the CFTC on June 16, 2014 after being unanimously confirmed by the U.S. Senate on June 3, 2014, to serve as a Commissioner of the CFTC, the federal agency that oversees the commodity futures, options and swaps industry. Commissioner Giancarlo succeeded Timothy Massad who has served as Chairman since June 5, 2014. Last Updated: January 20, 2017...

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