National Futures Association

News & Analysis as of

Private Equity Fund Managers: Annual Compliance Reminders and New Developments

Summary of private equity firms’ compliance obligations, discussion of notable developments in 2015 and outlook for 2016. US federal laws and regulations, as well as the rules of self-regulatory organizations (SROs),...more

Bridging the Week - January 2016 #2

FINRA Will Grade Members on Culture, Supervision and Liquidity Management; BDs Not Managing Spoofing Likely to Get Bad Scores: The Financial Industry Regulatory Authority kicked off the new year by issuing its annual...more

Guidance on CPO and CTA Annual Affirmations Requirements Due By February 29, 2016 and General Compliance Requirements for...

On December 1, 2015, the National Futures Association (the NFA) issued a notice to members to remind them of certain Commodity Futures Trading Commission (CFTC) regulations that require any person claiming an exemption or...more

NFA Amends Interpretive Notice Regarding NFA Compliance Rules 2-7 and 2-24 and Registration Rule 401

Proficiency Requirements for Security Futures Products - The term security futures product (“SFP”) encompasses security futures and options on security futures. The term security future includes both futures on a single...more

CFTC Regulation Automated Trading (Regulation AT)

On November 24, 2015, the Commodity Futures Trading Commission (“CFTC”) held an open meeting at which it unanimously approved its long-anticipated notice of proposed rules referred to as Regulation Automated Trading...more

CFTC and NFA Issue FAQS on Form CPO-PQR and Form CTA-PR

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission (the “CFTC”) recently issued answers to Frequently Asked Questions (“FAQs”) regarding CFTC Form CPO-PQR applicable to...more

Financial Services Weekly News - December 2015 #3

Regulatory Developments - SEC Proposes New Derivatives Rules for Registered Investment Companies and Business Development Companies - On Dec. 11, the SEC proposed new Rule 18f-4 under the Investment Company Act,...more

NFA Issues Notice on the Inclusion of Legal Entity Identifiers in the Swap Dealer/Major Swap

The National Futures Association (NFA) has issued Notice I-15-28, which discusses the legal entity identifiers (LEIs) that are now being used in the NFA’s swap dealer/major swap participant registry (SD/MSP Registry). The...more

CFTC Proposes “Regulation AT” for Automated Trading

I. Executive Summary - On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or...more

Cybersecurity Update: National Futures Association Adopts Cybersecurity Guidance for Member Firm Information Systems Security...

The Commodity Futures Trading Commission (CFTC) recently approved the National Futures Association’s Interpretive Notice to NFA Compliance Rules 2-9, 2-36 and 2-49, entitled Information Systems Security Programs (the...more

NFA Adopts Cybersecurity Guidance

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

National Futures Association Issues Updated Self-Examination Questionnaire

The National Futures Association (NFA) has updated the Self-Examination Questionnaire that all NFA members must complete annually. The revised questionnaire incorporates recent changes to NFA rules and Commodity Futures...more

SEC Cybersecurity Update

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

NYCCHR’s Enforcement Guidance on NYC Credit Check Law: Answers and New Questions

On September 2, 2015, the New York City Commission on Human Rights (NYCCHR or Commission) issued Enforcement Guidance (Guidance) on the New York City Stop Credit Discrimination in Employment Act (SCDEA), which took effect on...more

CFTC Requires Introducing Brokers, Commodity Pool Operators, and Most Commodity Trading Advisors That Use Swaps to Become Members...

On September 14, 2015, the Commodity Futures Trading Commission (CFTC) published a final rule requiring introducing brokers (IBs), commodity pool operators (CPOs), and most commodity trading advisors (CTAs) to become members...more

"CFTC Extends Registered Futures Association Membership Requirement to Introducing Brokers, Commodity Pool Operators and Commodity...

The Commodity Futures Trading Commission (“CFTC”) unanimously approved a final rule (“Final Rule”) that formally extends the existing registered futures association (“RFA”) membership requirement to registered introducing...more

National Futures Association proposes cybersecurity rules for its members

The National Futures Association (NFA) recently approved new mandatory cybersecurity rules for members of the futures industry. Members of the NFA include exchange-traded futures, forex and over-the-counter swaps industries....more

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

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

CFTC Approves National Futures Association Rules Enhancing Protections for Retail Forex Customers

On August 27, 2015, the U.S. Commodity Futures Trading Commission (CFTC) approved rule amendments and a new interpretive notice proposed by the National Futures Association (NFA). The rule amendments and interpretive notice...more

National Futures Association Proposes Cybersecurity Guidance for NFA Member Firms

NFA links NFA’s supervisory requirements with its proposed requirements mandating that NFA Members have information systems security programs. The National Futures Association (NFA) has proposed cybersecurity...more

Forex Dealer Members—The Times, They Are A-changing

On January 15, 2015, two days after the Swiss National Bank reaffirmed its commitment to a three-year peg on the franc, and less than a month after stating that the cap was “absolutely central,” and it would continue to...more

Bridging the Week - August 2015 #5

Charles Schwab Fined US $2 Million by FINRA for Net Capital Deficiencies: Charles Schwab & Co. agreed to pay US $2 million to the Financial Industry Regulatory Authority to resolve allegations that it had net capital...more

CFTC Staff Exempts Certain Commodity Trading Advisors from Form CTA-PR Reporting

The reporting relief applies to commodity trading advisors that do not “direct” trading of any client commodity interest trading accounts. On July 23, the CFTC’s Division of Swap Dealer and Intermediary Oversight issued...more

NFA Requires Notice From CPOs that Consolidate Filings of Subsidiary Pools

National Futures Association (NFA) has issued a notice requiring all commodity pool operators (CPOs) that have filed a notice of claim under Commodity Futures Trading Commission Letter No. 14-112 to submit an additional...more

NFA Revises CPO Form PQR and CTA Form PR

The National Futures Association (NFA) has made enhancements to the CPO Form PQR and CTA Form PR (CPR) effective for the quarter ending June 30. In the PQR, commodity pool operators may no longer list themselves as...more

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