Paul has been involved in the IB business for more than 30 years. He has served the NIBA in all officer positions before being elected to the NFA Board of Directors. Paul has served on several committees at the NFA as well as Vice Chairman of the Board of Directors. IB owners, office managers, and compliance personnel; 2016 will be another year of adjustments and likely more consolidation in the futures industry. Since Congress passed the Dodd-Frank bill, the CFTC has been developing regulation to meet the goals of this legislation which continues to impact our business. In recent conversations....
Joint Statement of Douglas Bry and Ernest Jaffarian Candidates for NFA Board of Directors CTA/CPO Seats
Dear CTA/CPO NFA Member – Two of the CTA/CPO Board Seats are contested this year, your vote is critical, and we would appreciate your consideration. We’ve served on the NFA Board for the past 4 years, running in and winning contested elections in 2012. The decision to run was driven by our disappointment with NFA’s response to the bankruptcy of MF Global, and our belief that a fresh perspective was needed to move the organization forward. Each of us has experienced over 25 years of growth and evolution in the futures industry, and we bring a small business entrepreneurial spirit....
POSITION PAPER OF JAMES L. KOUTOULAS, ESQ. AND JOHN L. ROE
Dear Members, It is time for another NFA Board of Directors election. If it seems like we just asked you for your vote, it’s because we did as you elected us to two-year terms less than a year ago. However, due to changes to the Board’s composition, we currently find ourselves up for election yet again in the only two contested races on the whole Board. We know that the constant stream of elections may seem unimportant, but as someone who makes their living subject to ever-increasing regulation, taking the time to vote for effective Board representation directly benefits your....
The CFTC’s Proposal to Regulate Automated Trading: Our Top 10 Takeaways
The Commodity Futures Trading Commission (“CFTC”) has proposed a new rule — so-called Regulation AT — to regulate the use of automated, or algorithmic, trading systems that trade commodity interests (e.g., futures and swaps). The CFTC’s proposal comes at the end of a year that saw a noticeable increase of enforcement actions arising from disruptive trading practices, including spoofing and market manipulation, and which included the first criminal conviction for spoofing in U.S. v. Michael Coscia. In this Client Alert, we highlight the most significant aspects of Regulation AT. 1. A New Registration Mandate. Under Reg. AT, registration will....
Chairman Letter December 2015
Dear Members – The NIBA was founded in June 1991. During the past 25 years, we have become known as the association who educates and speaks for the retail professional community. We have earned the respect of our regulators and our industry by participating in the rule- making process at both the CFTC and NFA, and submitting position papers on everything from ethics training requirements to increased transparency for FCM financial reports. As we enter our 25th Anniversary Year, NIBA will continue to represent your opinions. You will also see some changes. Originally, the NIBA’s membership was almost entirely made....
2016 Member Events
The following association events are currently scheduled for 2016. Please mark your calendar now to save-the-dates. If you are interested in being on the planning committee for any meeting, please contact the meeting chairperson. April 20: New York City – Annual east coast meeting held at the New York Athletic Club. Two or three business sessions beginning at about 1:30pm followed by a networking cocktail hour. (CTA Expo NYC is scheduled for April 21, the following day) Chairman: Howard Rennell, [email protected] July 14: Chicago – Co-sponsored event held at DePaul University, downtown Chicago campus. Two business sessions beginning at about....
Ask the NFA
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 NFA and NIBA members open, not to fix any specific individual concerns. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA....
NIBA – Get to Know the Regulator
U.S. Commodity Futures Trading Commission Division of Clearing and Risk Who is in charge of the Division of Clearing and Risk: DCR is run by a Director, who is assisted by the DCR Deputy Directors and Chief Counsel. Jeffrey Bandman is the Acting Director, and the Deputies and their respective branches are as follows: Eileen Donovan, Deputy Director of Clearing Policy; Sarah Josephson, Deputy Director of Product Review; John Lawton, Deputy Director of Risk Surveillance; and Julie Mohr, Deputy Director of Examinations. Robert Wasserman is the DCR Chief Counsel. How many employees are a part of DCR: DCR has 72....
Housekeeping, Reminders, and Updates December 2015
COMMODITY FUTURES TRADING COMMISSION Extension of Time-Limited No-Action Relief from Certain Recordkeeping Requirements On December 8th, the Commodity Futures Trading Commission (“CFTC”) issued a press release regarding the no-action letter issued by the Pision of Swap Dealer and Intermediary Oversight and Pision of Market Oversight (Press Release: PR729-15) . The no-action letter extended the relief relating to records of oral communications, which was originally set forth in CFTC Staff Letter No. 14-147, from 2014. The relief in Letter No. 14-147 was set to expire on December 31, 2015. The 2014 letter granted no-action relief to commodity trading advisors (“CTAs”) that....
NIBA in DC
On November 9, 2015, Steve Petillo, Mike Burke and I travelled to Washington, DC to meet with members of the Commodity Futures Trading Commission at their offices. Here’s a summary of that meeting as well as the other meetings we had while there. We brought three issues which were suggested by NIBA members to the attention of Chairman Massad and Commission Bowen. Both Commissioners, along with their staff, told us that monitoring the effectiveness of Regulation 1.35 (Recording Communication that may lead to a Transaction) and Regulation 1.22 (“Residual Interest”) is ongoing. We reiterated that we believe Reg. 1.35 in....