News & Analysis as of September 19, 2024

Cybersecurity › CPOs

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

Lowenstein Sandler LLP on 5/5/2022

Summaries of recent legislative and regulatory developments with respect to: •SEC’s 2022 Examination Priorities • Proposed Amendments to Form PF Requirements- •Proposed New Rules Applicable to Private Fund Advisers and...more

Important Dates and Reminders for Investment Advisers, Exempt Reporting Advisers, Commodity Trading Advisors and Commodity Pool...

Foley Hoag LLP on 2/14/2022

INVESTMENT ADVISERS - Annual Compliance Reviews - All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and...more

[Event] Ohio Insurance Cybersecurity Seminar - January 24th, Cincinnati, OH

Bricker Graydon LLP on 1/15/2020

What GCs, CIOs, CSOs and CPOs need to know about Ohio's new requirements under S.B. 273 - Please join GBQ and Bricker & Eckler for our Ohio Insurance Cybersecurity Seminar on Ohio Senate Bill 273 (codified @ Ohio Rev....more

NFA Amends its Information System Security Program Requirements; CFTC-Registered CPOs and CTAs Need to Take Action by April 1

Dechert LLP on 2/8/2019

The National Futures Association (NFA), the self-regulatory organization of the futures and swap trading industry, announced to its membership on January 7, 2019 that it had amended its requirements for NFA Member Information...more

Update to the NFA’s ISSP training, approval and notice requirements

Eversheds Sutherland (US) LLP on 1/31/2019

On January 7, 2019, the National Futures Association (NFA) issued an amendment to its Interpretive Notice on required Information Systems Security Programs (ISSPs) for NFA Members. ISSPs are required by the NFA so that NFA...more

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

Akin Gump Strauss Hauer & Feld LLP on 1/15/2019

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

NFA Proposes Interpretive Notice Addressing CPO Internal Controls

K&L Gates LLP on 1/4/2019

Introduction - By letter dated December 10, 2018, the National Futures Association (“NFA”), the self-regulatory organization for the U.S. derivatives industry, submitted to the U.S. Commodity Futures Trading Commission...more

Bridging the Week - December 2018

Katten Muchin Rosenman LLP on 12/11/2018

A federal judge said that it is not a violation of federal law for a trading firm and its chief executive officer to be smarter than their counterparties in ruling against the Commodity Futures Trading Commission in an...more

New Disclosure Rules Enhance Crypto Investor Protection

Kramer Levin Naftalis & Frankel LLP on 9/5/2018

Amid concerns that many investors may not fully understand the risks associated with virtual currencies, or the limits of regulatory oversight, the National Futures Association (NFA) recently issued an interpretive notice...more

Bridging the Week - October 2017

Katten Muchin Rosenman LLP on 10/5/2017

Two Commodity Pool Operators Charged by CFTC with Failure to Supervise: The Commodity Futures Trading Commission brought and settled enforcement actions against two commodity pool operators for failure to supervise. In one...more

Reminder: March 1, 2016 Effective Date for Information Systems Security Programs Including Cybersecurity for NFA Members

Foley Hoag LLP - Security, Privacy and the... on 2/25/2016

As noted in our earlier Foley Adviser, March 1, 2016 is the effective date for NFA member firms (including futures commissions merchants, commodity trading advisors, commodity pool operators, introducing brokers, retail...more

NFA Adopts Cybersecurity Guidance

Dechert LLP on 11/6/2015

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

Four Cybersecurity Ideas from CFTC Commissioner Bowen

McGuireWoods LLP on 9/25/2015

On Sept. 17, 2015, Commissioner Sharon Y. Bowen of the U.S. Commodity Futures Trading Commission (CFTC) gave the keynote address for the International Swaps and Derivatives Association’s 2015 North American Conference in New...more

Cybersecurity Update: National Futures Association Proposes Cybersecurity Guidance Setting Forth General Requirements for Member...

K&L Gates LLP on 9/10/2015

The National Futures Association (“NFA”) submitted to the Commodity Futures Trading Commission (“CFTC”) on August 28, 2015 a proposed Interpretive Notice (“Proposed Guidance”) for CFTC’s approval, which provides guidance to...more

NFA Proposes Cybersecurity Guidance for Derivatives Traders

McGuireWoods LLP on 9/8/2015

On August 28, 2015, the National Futures Association (NFA) submitted a proposed interpretative notice (Notice) to the Commodity Futures Trading Commission (CFTC) to require information systems security programs (ISSPs). If...more

Bridging the Week - April 2015 #2

Katten Muchin Rosenman LLP on 4/14/2015

IOSCO Seeks Views on Business Continuity and Recovery Planning by Trading Venues and Intermediaries; NYS Warns on Third-Party Service Providers - The International Organization of Securities Commissions issued two...more

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Cybersecurity › CPOs

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