As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly. Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members.  This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Q: A colleague recently forwarded an NFA Notice…...

Written by: Mark E. Ruddy, Esq. Maria Fielding   Increase in National Futures Association (“NFA”) Assessment Fee The NFA’s Executive Committee is recommending an increase in the NFA’s assessment fee beginning January 1, 2018. The Executive Committee voted in favor of recommending that the assessment fee increases from $0.01 per side to $0.02 per side for futures and options contracts, bringing the assessment fee back to its amount prior to being reduced in October 2014 to $0.01. The NFA maintains that an increase in the assessment fee is necessary in order to continue operations and maintain reserves properly. The recommended…...

NIBA – The Association for Derivatives Professionals 55 W. Monroe, Ste. 3600 Chicago, IL 60603 (312) 977-0598 www.theniba.com BY ELECTRONIC SUBMISSION Christopher Kirkpatrick, Secretary Commodity Futures Trading Commission 1155 21st Street, NW Washington, DC 20581 September 28, 2017 Re: CFTC Request for Public Input to Make Regulations(s) Simpler, Less Burdensome and Less Costly (Project KISS) Mr. Kirkpatrick: The NIBA appreciates the opportunity to provide suggestions and comments to the Commodity Futures Trading Commission (“CFTC” or “Commission”) as it reviews existing rules and regulations with an eye toward possible reevaluation of certain of them. We support the review, and look forward…...

Compliance Supervisors International Inc. (“CSI”), is excited to welcome John Brand to lead our Chicago Compliance Division. John is an excellent addition to CSI, and we look forward to leveraging his extensive and deep industry knowledge, with the current and ever-changing compliance and regulatory policies to better help our clients.  Mr. Brand’s compliance and examination experience spans across two decades, where he served in numerous compliance roles, most recently as Managing Director of Compliance at the National Futures Association. Mr. Brand also held various compliance and Anti-Money Laundering Compliance positions in the FCM community and for a Derivatives Clearing Organization.…...

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly. Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members.  This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Q: I heard NFA updated the individual application…...

  National Futures Association (“NFA”) Updates Financial Statement Filings The NFA is adding additional questions to independent introducing brokers’ (“IBs’”) financial statement filings beginning with the September 30, 2017 filings. The additional questions do not concern new information being collected by the NFA, but rather information that had previously been collected by way of a follow up from the NFA to an IB after financial statements were submitted. The hope is that the financial statement filing process will be streamlined by asking these questions at the time of submission filings instead of the NFA having to call up the IBs…...

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly. Just email us at [email protected] and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Q: How do I find information for IBs…...

Written by: Mark E. Ruddy, Esq. Maria Fielding, Legal Assistant   Three of the Commodity Futures Trading Commission (“CFTC”) Nominees Confirmed The United States Senate confirmed J. Christopher Giancarlo as Chairman and Rostin Behnam and Brian Quintenz as commissioners of the CFTC. The Senate did not vote on the fourth and final nominee currently awaiting confirmation, Dawn DeBerry Stump. As announced in Press Release pr7602-17, Commissioner Quintez was sworn in on August 15, 2017. As acting Chairman, Giancarlo already proposed earlier this year notable restructuring of the CFTC as well as a more thoughtful approach regarding rules and regulations and…...

What is Intelligence as a Service? Intelligence-as-a-Service (“IntaaS”) is the combination of automated domain expertise with traditional internet software. Imagine if your CRM came pre-filled with customer information, your taxes were pre-loaded and completed in your tax software, or your digital compliance system was pre-filled with all your data: this is the promise of IntaaS. Software-as-a-Service reduced the marginal cost of delivering services. IntaaS reduces the cost of both creating and delivering a unit of intelligence to customers. What we Do In systems where the inputs are standard and the output is identical (think self-driving cars), deep learning works extraordinarily well. Even in…...

Written by:      Mark E. Ruddy, Esq. Jessica I. Brown, CAMS Commodity Trading Advisors (“CTAs”) Third-Party Record Keeping Relief CTAs now have the ability to request relief from certain Commodity Futures Trading Commission (“CFTC”) Regulation 4.33 and 4.7(c)(2) record-keeping requirements. CFTC Exemptive Letter No 17-24 provided CTAs relief from the requirement that books and records must be kept at the registrant’s main office. Letter 17-24, issued by the Division of Swap Dealers and Intermediary Oversight (“DSIO”), allows CTAs to submit a request for relief so that the firm may use a third-party record keeper to comply with Regulations 4.33 and 4.7(c)(2).…...