New Recording Requirements; Compliance Deadline: December 21, 2013

A new oral communications recordkeeping requirement was one of the key topics discussed at the 2013 NIBA Conference in Chicago on September 18, 2013.  Covered registrants must comply by December 21, 2013, unless they obtain an extension.  A recap of the Legal Panel discussion on the new recording requirements follows for the benefit of those not in attendance.  Covered Oral Communications  The Commodity Futures Trading Commission amended Regulation 1.35(a) to require futures commission merchants (FCMs), large introducing brokers (IBs), retail foreign exchange dealers (RFEDs), and certain other registrants to record oral communications that lead to the execution of a transaction…

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