FCM Responsibilities for the Review and Approval of their Guaranteed Introducing Brokers’ Communications with the Public Recently, NFA has experienced a sharp increase in the number of promotional material submissions to NFA’s Pre-review Program by Guaranteed Introducing Brokers (“GIBs”) that have not first submitted the material to their Guarantor FCM for review and approval. In some cases, the Guarantor FCM has specifically directed its GIB to forward the material to NFA prior to its own review. In other cases, the GIB has submitted the material to NFA without the Guarantor FCM’s knowledge. Since Guarantor FCMs are required to supervise the…