“To Trend or Not to Trend” – 10:00AM Need we say more? Andrew Strasman, Totem Asset Group (CTA) leads a panel discussion which opens with a review of the “40in20out.com” academic project. Traders and others from the investment community will share their thoughts on the pros and cons of this approach to trading. If you are already involved in, or just thinking about getting into the managed futures world, you will benefit from including this panel in your day with the NIBA. To get the most out of the discussion, do your homework before the session — take a quick....
September Chairman’s Letter
From NIBA Chairman, Melinda Schramm September 08, 2016 Anniversary: the celebration or commemoration of an event recurring each year -Websters College Dictionaries, 2015 By now you know that NIBA is celebrating its 25th Anniversary Year during 2016. In February, FCM and Service Provider Members joined the NIBA Board of Directors to review the accomplishments of the Association and toast the coming year. In April, New York-based members of the NIBA were able to celebrate our 25th year with a half-day forum concentrating on the metals and energies markets and the very new NFA guidance for your firm’s cybersecurity compliance. And,....
NFA Notice to Members
On August 24, 2016, NFA notified members that effective 2017, they will institute electronic voting. An essential component of the new process is the designation of your Executive Representative – the only person from your firm who will be allowed to cast votes in the contested NFA director elections, and to submit nomination petitions. NIBA supports this initiative. Mike Burke, IIB representative to the NFA Board presented both the idea of electronic voting and a designated firm rep to NIBA Board Members when he was first elected — it received an unanimously positive response. NIBA believes NFA’s new process for....
NIBA’s First-Ever Compliance Debate – September 14th
Do you occasionally feel like there is a huge “gray area” surrounding a regulation? Did you ever think there must be a second or even a third way to approach compliance with a particular rule? Inspired by this year’s Presidential Debates, the NIBA is hosting our first-ever compliance debate! On September 14, during this year’s 25th Anniversary Conference, regulators, attorneys, compliance consultants and industry representatives will take the stage to debate the Pros and Cons of issues where multiple rules could apply, or there just might be more than one way to comply with regulation. We have an all-star line....
Housekeeping, Reminders, and Updates
Mark E. Ruddy, Esq. and Elizabeth A. Cannon August 24, 2016 NATIONAL FUTURES ASSOCIATION NFA Updates Self-Examination Questionnaire for FCMs, FDMs, IBs, CPOs and CTAs On August 15, 2016, the National Futures Association (“NFA”) announced updates to its Self-Examination Questionnaire. On an annual basis, NFA member futures commission merchants (“FCMs”), forex dealer members (“FDMs”), introducing brokers (“IBs”), commodity pool operators (“CPOs”), and commodity trading advisors (“CTAs”) have an obligation to review their operations using this questionnaire. The NFA’s Self-Examination Questionnaire is a helpful tool for members to use in order to satisfy the NFA’s obligations and continuing supervisory....
CFTC & SEC Registration Considerations for Private Fund Managers
Nicole M. Kuchera and Joseph M. Mannon, Vedder Price August 23, 2016 This article provides a simple three step guide to registration considerations for managers of various types of private fund vehicles, such as for hedge funds, fund of funds, private equity funds, venture capital funds, real estate funds and commodity pools. Registration considerations under both the Commodity Exchange Act of 1936, as amended (the “CEA”), and the Investment Advisers Act of 1940, as amended (the “Advisers Act”), are outlined below. Registration considerations for non-U.S. jurisdictions are not addressed in this summary. The following discussion is provided as a....
Life of a Brokerage Firm – Part 2
Ron Grossman and Ryan Griffeth conducted a series of interviews discussing the various stages of a brokerage firm. Interviews are presented here in Q&A form. There are a number of participants in this article series from brokerage firms, new individual brokers and industry professionals contributing their unique opinion and expertise. <Brokerage Firm> Scott Peterson, Stewart-Peterson How did you get started in the Commodity industry? At a previous employer, while writing market commentary and advice for a magazine, it occurred to me that many farmers and ranchers needed more than published comments. (This was before internet provided information at our fingertips.) ....
August’s Chairman Letter
Teamwork: Cooperative or coordinated effort on the part of a group of persons acting together in the interests of a common cause. Dictionary.com Teamwork is one of the great strengths of the NIBA. For 25 years, the Association’s team members have worked together to further the interests of the professional derivatives community — to keep it strong, to make it’s voice heard and, at times, to even ensure its relevancy. Much of the success of the NIBA is due to the contributions of its team members. From the very first board meeting in May 1991, the CME Group has been....
DePaul NIBA Conference Review
CTAs- do your Due Diligence priorities line up with those of your next prospective allocator? The NFA? What keeps CMEGroup’s Chief Security Officer up at night? Why does DePaul University include Cybersecurity in their Master of Science in Enterprise Risk Management program? These issues and more were addressed by at last month’s NIBA/ DePaul University conference. Valuable perspectives and harrowing experiences were shared by highly qualified panelists from legal, compliance, cap source as well as directors at the NFA. The NIBA will be launching its new members only portal mid September and will be featuring the video of this conference....
The CFTC Proposes Significant Relief For Non-U.S. Market Participants
The U.S. Commodity Futures Trading Commission (“CFTC“), which regulates commodity interest transactions such as swaps and futures contracts, has requested comments from industry market participants on its proposed amendments to CFTC Rule 3.10. CFTC Rule 3.10 sets forth the exemptions that may apply to non-U.S. market participants, and the rule impacts brokers, advisers and fund operators. The CFTC’s stated goal, subject to receiving comments, is to expand the exemptions from registration for non-U.S. firms engaged in commodity interest transactions in the U.S. on behalf of customers located outside of the U.S. The proposal also seeks to simplify the exemptions’ requirements.....