From Paul J Georgy, GIB Representative on NFA Board of directors
The CFTC is not done writing rules mandated by the Dodd-Frank Bill. Customer protection is the focus and who can argue with that? However, it will have an impact on…
NFA Representatives Panel Preview
I’ve been asked to moderate the NFA Representatives Panel at the upcoming NIBA membership meeting in September. This is an opportunity I’ve been hoping for -- an opportunity to discuss…
New Recording Requirements; Compliance Deadline: December 21, 2013
The CFTC has amended its Rule 1.35 to require futures commission merchants (FCMs), certain introducing brokers (IBs), retail foreign exchange dealers and certain other registrants to record all oral communications…
NIBA Legal Update Panel Preview
I have the privilege of leading the NIBA Legal Update once again this year. This panel of industry experts including Mike Coglianese and Jeff Kopiwoda will address legal developments -…
Five Ideas of CTA Due Diligence
Over the years I’ve found people perform varying degrees of due diligence of a Commodity Trading Advisor (CTA). Some may only crunch the returns of the manager. Others will only…
Still Stupid After All These Years
To be perfectly honest, I’m not sure any professional Fund of Fund managers anywhere would admit using any of the techniques below, much less advocating their use. That said, in…
Marketing of Commodity Trading Advisors
With expanding areas of potential client pools and capital, commodity trading advisors (“CTA”) are often looking outside of their firms to tap into these untouched resources. To accomplish this, CTAs…
Understanding an IB’s AML Program Requirements
Since April 24, 2002, NFA Compliance Rule 2-9(c) has required all NFA Member FCMs and IBs to have an anti-money laundering (AML) compliance program in place. At a minimum, the…
Common Mistakes, Introducing Brokers and AML Procedures
Most introducing brokers (“IBs”) view their Anti-Money Laundering (“AML”) obligations quite minimally but this can be a monumental mistake. Generally IBs believe their AML responsibilities are limited to ensuring a…
Overview of AML Policies and Procedures for Introducing Brokers
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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