NFA Compliance – Preparing for an NFA Exam

Since 2012, the number of CPOs, CTAs, and IBs required to register with NFA has seen a dramatic increase.  With this increase came a renewed commitment by regulators to not only audit new NFA Members within the first year, but more frequently thereafter as well. The frequency of subsequent on site audits depends upon an analysis of risk factors.  Some…...

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Panel Summary-Top 5 Questions

Michael Coglianese had the pleasure of moderating a Panel of experts at the NIBA Conference.  Mike was impressed by the answers as well as the insight of the questions from the audience.  Here are some of the questions summarized below: Why should IRAs be important to the Business of an Introducing Broker? First, the managed futures industry is important to…...

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Ask the NFA–Revision to August

Revised Answer to Question 1 of the August 2015 Ask the NFA Article: Selecting and Recommending CTAs– A Recommending CTAs-  A Recommending CTA is one who recommends various trading advisors to clients (e.g. individuals, other CTAs or CPOs) but does not have any other authority regarding these trading CTAs.  A Recommending CTA is required to be registered and an NFA…...

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Housekeeping, Reminders and Updates–Sept 2015

NATIONAL FUTURES ASSOCIATION Effective Date of New Requirements for Forex Dealer Members (“FDMs”) The NFA announced the effective date of the new capital and compliance requirements for FDMs after the Commodity Futures Trading Commission (“CFTC”) approved the NFA’s amendments to NFA Financial Requirements Section 11, NFA Financial Requirements Section 12 and NFA Compliance Rule 2-36. The CFTC’s approval of changes…...

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Ownership and Control Reporting (“OCR”)

The reporting deadline under the CFTC’s Ownership and Control Reporting (“OCR”) rules is September 30, 2015.   Although these rules became effective in February 2015, the CFTC granted firms an extension which until September 30 (six months) to collect and report the additional information information.    What to Know In November 2013, the CFTC finalized new rules for Ownership and Control…...

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NFA Representative Annual Report

Introducing Broker and CTA/CPO representatives on the NFA Board of Directors will present their annual report to NIBA members on September 24 during our Annual Members Meeting. The following representatives will be present: Paul Georgy, GIB Mike Burke, IIB James Koutoulas, CTA/CPO John Roe, CTA/CPO Doug Bry & Ernest Jaffarain, CTA/CPO (invited) Each year your elected representatives to the NFA…...

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HOUSEKEEPING, REMINDERS AND UPDATES: AUGUST 2015

FINANCIAL CRIMES ENFORCEMENT NETWORK In an August 25, 2015, press release, the Financial Crimes Enforcement Network (“FinCEN”) announced proposed anti-money laundering (“AML”) regulations for investment advisers. FinCEN has published a Notice of Proposed Rulemaking regarding AML programs and suspicious activity report (“SAR”) requirements that would apply to certain investment advisers. The purpose of FinCEN’s proposed rule is to prescribe minimal…...

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NIBA FCM Risk Management Series- Interactive Brokers

NIBA will be featuring a recurring article in its monthly newsletter to membership with a focus on FCM Risk Management. The article will feature a different Member FCM each month discussing their approach to risk management. The questions below are a guide and are not required to be answered, and questions can be added and/or removed as you see fit.…...

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Ask the NFA

Q: What is needed (checklist, step by step, guide, etc) to setup a non-trading 4.7 exempt CTA for a stand alone entity? A: “Selecting and Recommending CTAs – A Recommending CTA is one who recommends various trading advisors to clients (e.g., individuals, other CTAs or CPOs) but does not have any other authority regarding these trading CTAs.  The recommending CTA is…...

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NIBA/DePaul Event Video Recap

Thank you again to DePaul University and to the speakers at the NIBA/DePaul co-sponsored event in Chicago. Nearly one hundred NIBA members heard sessions on meeting the challenges of marketing managed futures and updates on cybersecurity compliance before joining colleagues at a cocktail reception on the University Terrace. NIBA is in the second year of our academic partnership with DePaul…...

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