By: Greg Baracy, Turnkey Trading Partners As everyone in the Commodity Futures Industry surely knows during March of 2016 the CFTC and NFA implemented cyber security obligations which were applied to all member firms. At that time Futures Commission Merchants (“FCMs”), Commodity Pool Operators (“CPOs”), Introducing Brokers (“IBs”), and Commodity Trading Advisors (“CTAs”) were all obligated to put in place and maintain a written Information Systems Security Program (“ISSP”) specifically tailored to their unique operations. This article intends to identify areas that NFA has focused on during regulatory examinations Turnkey Trading Partners has assisted with during 2017. Ongoing Risks and…