NYC Conference Follow Up: Attaining a Viable Cyber Security Program at a Reasonable Price

Attaining a Viable Cyber Security Program at a Reasonable Price; is it Possible? We’ve all heard about the hacks at Sony, Target, and even the U.S. Government. Fortune 500 companies and US government agencies getting hacked is exciting news. Well, actually – it’s terrifying. And even more disturbing is the complexity associated with solving this problem. For a Fortune 500 company, the solution involves throwing money at the problem by hiring another 25-50 cyber security experts and investing another $50-$100m in cyber security. But what if you’re a smaller firm, but no less meaningful to its owners or stakeholders, with…...

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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 of this contact is to keep the lines of communication between NFA and NIBA members open, not to fix any specific individual concerns. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA…...

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The How, Why and When of Selecting a Fund Auditor

How or when to select or change a fund audit firm for your hedge fund, CTA or other alternative investment business can seem like a daunting decision for any fund manager. However, it can be done with the right considerations and processes in place. WHEN TO SELECT A FUND AUDITOR Many fund managers are under the assumption that since fund audits are typically performed at year end that they don’t need to search for a fund auditor until much later. However, it’s actually in a fund managers’ best interest to select their fund auditor as soon as a fund is…...

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The Value of Strategic Partnerships – Maximize Your Rate of Returns

Whether you are running a hedge fund, Introducing Broker, CTA, or CPO you are required to spend most of your time managing your investors, investments, and returns. In our regulated industry, you also need to hire an attorney, an auditor, a compliance expert, and an administrator that compiles your monthly performance results. These hires can be considered necessary evils. But if you hire the right team, you can extract more value to drive efficiency and reduce your business risk so you can focus more time on working with you investors, managing investments, and more importantly, making money. I have been…...

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NYC Cybersecurity Panel Preview

Our industry has certainly transformed over the past decade. Much of this transformation stems from new rules and regulations, some of which are aimed at addressing the use of technology in the futures industry. As we are all aware, effective March 1, 2016, each and every NFA Member firm must adopt and enforce an information systems security program (“ISSP”). If you are not aware that this requirement exists, we encourage you to attend this session! NFA issued an interpretative notice approved by its Board of Directors on August 20, 2015 that provides guidance regarding information systems security practices that Member…...

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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 of this contact is to keep the lines of communication between NFA and NIBA members open, not to fix any specific individual concerns. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA…...

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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 Automated Trading (“Reg AT”). Founded in 1991, NIBA is a trade association of registered derivatives professionals whose members include Introducing Brokers (“IBs”), Commodity Trading Advisors (“CTAs”) and Associated Persons. Our members handle transactions for customers in the futures, options, forex…...

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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 the following Cybersecurity questionnaire for you. Turnkey has been using this document to best determine how to implement Cybersecurity policies for nearly 100 CFTC registrants since the beginning of this year. If you have any questions or concerns after reviewing this…...

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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 they understand their regulatory obligations. When instances of non-compliance are noted, firms are expected to come into compliance and demonstrate how it will be achieved. There are several factors NFA considers when evaluating examination findings: number of violations, repeat nature…...

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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 properly segmented?”, “How often are passwords changed?”, “what is your password complexity?”, “Is anyone checking those firewall logs?”  Meanwhile the bad guys are waiting for your cyber defenses to fail, or worse, finding their own way in.  The way they…...

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