March 16, 2016 Mr. Christopher J. Kirkpatrick Secretary of the Commission Commodity Futures Trading Commission Three LaFayette Centre, 1155 21st Street, NW Washington, DC 20581 RE: Proposed Rulemaking on Regulation Automated Trading (“Reg AT”) RIN 3038-AD52 VIA ELECTRONIC SUBMISSION Mr. Kirkpatrick: NIBA appreciates the opportunity to comment on the Commodity Futures Trading Commission’s (“Commission” or “CFTC”) proposed rulemaking on Regulation Automated Trading (“Reg AT”). Founded in 1991, NIBA is a trade association of registered derivatives professionals whose members include Introducing Brokers (“IBs”), Commodity Trading Advisors (“CTAs”) and Associated Persons. Our members handle transactions for customers in the futures, options, forex....
NIBA/ DePaul Internship Joint Endeavor
NIBA/ DePaul Internship Joint Endeavor- The NIBA is out to make your life easier! The idea for this internship program was proposed and found strong support among NIBAs Advisory Group. Qualified students will be matched with members looking for candidates trained in a broad array of critical sectors, including Finance, Statistics, Media, Marketing, and Law. The goal of our program is to foster meaningful development-importantly – for both the interns and the member. According to Tom Sandy, NIBA Member Rice Dairy’s experience with DePaul interns has gone very well and the company looks forward to participating in this new joint....
March Chairman’s Letter
Members – Wow – has this been a busy 30 days for the NIBA! Thank you to all the FCMs and Service Provider representatives who attended the Thank You Reception on February 25 in Chicago. Over 40 NIBA members gathered to review our 2015 activities, and preview the events scheduled for 2016. On March 4 & 5, NIBA was invited to exhibit at RJ O’Brien’s Annual IB Conference. RJO’s staff presented a terrific program which included cybersecurity compliance and IB business generating ideas, as well as product sessions. Thanks to RJO for a great time and the opportunity to catch-up....
Cybersecurity Questionnaire
For the last several months Cybersecurity has been on everyone’s radar. Now that the implementation deadline has passed, many NIBA IBs have put something basic in place. For those NIBA members who may still be looking to fine tune their program, policy and/or procedures, we’d like to offer a potential solution. Courtesy of Turnkey Trading Partners, the NIBA has obtained the following Cybersecurity questionnaire for you. Turnkey has been using this document to best determine how to implement Cybersecurity policies for nearly 100 CFTC registrants since the beginning of this year. If you have any questions or concerns after reviewing this....
Thank You – FCMs and Service Providers
Thank You – FCMs and Service Providers On February 25, NIBA held its annual thank-you reception for member FCMs and Service Providers. Thirty-nine guests attended the event held at Pazzo’s Restaurant in Chicago. We appreciate the support our ten member FCMs show NIBA and to the entire IB and CTAs community. FCM members have sponsorship opportunities throughout the year, are featured in our newsletter and rotate as advisors to the Board of Directors. If you would like to become an NIBA FCM Member, please contact Mike Burke, [email protected] or Mike Coglianese, [email protected]. Service Provider members provide the unique products and....
NIBA New York City Event- April 20th
April 20 – New York City All members are invited to the NIBA Spring Membership Meeting April 20 at the New York Athletic Club in New York City. Onsite registration opens at 1:30pm. The program closes at 5:00pm with a Networking Cocktail Reception. Registration is open now. The afternoon’s agenda includes*: *Two market updates presented by industry experts: Metals Update– Jim Steel of HSBC Changing Ownership of Crude Futures Open Interest/Status of Barrel Ownership–Al Helmig, Grey House Energy market outlook– “Oil & Gas: All Stored UP and No Where to Go” presented by Brian Milne of Schneider Electric *Cybersecurity Compliance....
NIBA at the RJO Annual IB Conference
NIBA wants to thank RJ O’Brien for inviting us to exhibit and attend its Annual IB Conference March 4 and 5. It was great to see NIBA members who clear through RJO and to participate in the sessions and social events. RJO is a founding member of NIBA. Participating in their conference is another wonderful way to celebrate NIBA’s 25th Anniversary Year. Pictured below from left to right of top picture: Frank and Linda Stone, KC Trading Group, Melinda Schramm, NIBA Chairman and Kevin Craney, RJO Oasis. Lower picture: Jerry Nolan, Melinda Schramm, Shane Stiles...
Housekeeping, Reminders and Updates
Financial Crimes Enforcement Network The Financial Action Task Force (“FATF”) updated its list of jurisdictions with strategic anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) deficiencies. In response, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory in January announcing the updates to the list of jurisdictions identified as having strategic deficiencies in their AML/CFT regimes. Countries with inadequate AML/CFT programs, as identified by FATF, are categorized as: (i) jurisdictions that are subject to FATF’s call for countermeasures or are subject to enhanced due diligence (“EDD”) due to their AML/CFT deficiencies; and (ii) jurisdictions identified by FATF to have AML/CFT deficiencies.....
Ask the NFA
1. During the course of an NFA audit, when an item is noted in the audit report, how is that viewed internally by NFA? This depends on a number of factors. The purpose of examinations is to review compliance with NFA rules and CFTC regulations. NFA’s philosophy has always been to provide education and direction to its members to ensure they understand their regulatory obligations. When instances of non-compliance are noted, firms are expected to come into compliance and demonstrate how it will be achieved. There are several factors NFA considers when evaluating examination findings: number of violations, repeat nature....