NATIONAL FUTURES ASSOCIATION Information Systems Security Programs – Cybersecurity On October 23rd the National Futures Association (“NFA”) announced the adoption of the interpretive notice regarding NFA Compliance Rules 2-9, 2-36 and 2-49. The purpose of the interpretive notice was to address information systems security programs – cybersecurity. The interpretive notice entitled Information Systems Security Programs (“Cybersecurity Interpretive Notice”) was recently approved by the Commodity Futures Trading Commission (“CFTC”). The Cybersecurity Interpretive Notice requires Member firms to adopt and enforce written policies and procedures to secure customer data and access to their electronic systems. The terms of the Interpretive Notice become…