Ballard Spahr is a national law firm with offices in 15 United States cities. The firm's introducing broker practice is managed by Scott Diamond who has over thirty years of commodities law experience. Scott started his career at the CFTC in Washington, DC, and then moved to a New York based major futures commission merchant. He has also worked extensively in the swaps area as Head of Investment Banking Legal and as Chief Compliance Officer of a small securities broker-dealer. Scott’s experience with NFA examiners and management on a broad range of issues will benefit the IB community. Services to NIBA members include:
• IB Agreements with FCMs and customers
• Policies and procedures on AML, Business Continuity and Disaster Recovery, Cybersecurity; Automatic Order Routing Supervision; Review and Approval of Promotional Materials; Supervision of Associated Persons, including E-Mail Monitoring; and Customer Complaints
• Customer agreements with FCMs
• Swap Introducing Brokers
• NFA examination support
• Customer onboarding and risk disclosures
• Registration process and updates (7R & 8R)
• Statutory disqualification and enhanced supervision representation
• Annual Questionnaire assistance
• Series 3 requirements
• Cybersecurity incident management
• Subordinated Loan Agreements for net capital purposes
• AML obligations
• General business law
• General counsel work
