In a press release on June 8th, the Commodity Futures Trading Commission (the “CFTC”) published its first release in a series called the “SOFR First Transition Initiative” as a best practice. One goal for this sort of “best...more
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
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