NIBA CFTC Comment Letter

March 16, 2016 Mr. Christopher J. Kirkpatrick Secretary of the Commission Commodity Futures Trading Commission Three LaFayette Centre, 1155 21st Street, NW Washington, DC 20581 RE: Proposed Rulemaking on Regulation Automated Trading (“Reg AT”) RIN 3038-AD52 VIA ELECTRONIC SUBMISSION Mr. Kirkpatrick: NIBA appreciates the opportunity to comment on the Commodity Futures Trading Commission’s (“Commission” or “CFTC”) proposed rulemaking on Regulation…...

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Cybersecurity Questionnaire

For the last several months Cybersecurity has been on everyone’s radar. Now that the implementation deadline has passed, many NIBA IBs have put something basic in place. For those NIBA members who may still be looking to fine tune their program, policy and/or procedures, we’d like to offer a potential solution. Courtesy of Turnkey Trading Partners, the NIBA has obtained…...

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Ask the NFA

1. During the course of an NFA audit, when an item is noted in the audit report, how is that viewed internally by NFA?  This depends on a number of factors. The purpose of examinations is to review compliance with NFA rules and CFTC regulations. NFA’s philosophy has always been to provide education and direction to its members to ensure…...

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Fix Your Users!

The cyber security industry has gotten great at boundary defense.  “Firewalls, Firewalls, Firewalls” – that’s all you heard for a long time emanating from the boardroom.  Well the times they have changed.  Now there are so many regulatory bodies and frameworks to be in compliance with, it is a struggle to keep every mandate straight.  Questions like: ”Is your networking…...

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Prepare for 2016; NFA Examination Focus

The National Futures Association (“NFA”) Rules and Commodity Futures Trading Commission (“CFTC”) regulations that govern the futures, forex, and swap trading industry are subject to continuous interpretation, amendment, and update. Staying abreast of these changes is a critical component of maintaining regulatory and operational compliance for your next examination. NFA regularly emails member firms to advise them of pertinent rule…...

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NFA announces Dashboard webinar on February 25

announces Dashboard webinar on February 25 In preparation for the launch of the NFA Dashboard, the new entryway to NFA’s Online Registration System (ORS), NFA will conduct a webinar on Thursday, February 25, 2016, at 10:00 a.m. CST. ORS is the web-based application that allows firms and individuals to apply for CFTC registration and NFA membership, and to manage their…...

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Cybersecurity for IBs, CTAs, and CPOs

The NFA recently adopted an Interpretive Notice titled “Information Systems Security Programs” (Cybersecurity Interpretive Notice). This new NFA policy, which goes into effect March 1, 2016, requires FCMs, IBs, CTAs, CPOs, RFEDs, SDs and MSPs to implement a cybersecurity program in order to meet existing obligations to diligently supervise trading activities. Every registrant will be required to put in place…...

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It’s a Shield, not a Sword

Brian Clark is the CEO of Ascent Technologies, Inc. (www.Ascent.is), a company that offers a compliance platform for users to help them identify, track, and manage the vast amount of regulations with which their firm has to comply. Businesses on the wrong side of the law often feel as if they’d been bludgeoned by instruments of jurisprudence, bearing a distinct…...

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The CFTC’s Proposal to Regulate Automated Trading: Our Top 10 Takeaways

The Commodity Futures Trading Commission (“CFTC”) has proposed a new rule — so-called Regulation AT — to regulate the use of automated, or algorithmic, trading systems that trade commodity interests (e.g., futures and swaps).  The CFTC’s proposal comes at the end of a year that saw a noticeable increase of enforcement actions arising from disruptive trading practices, including spoofing and…...

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Ask the NFA

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…...

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