US regulators are calling attention to financial firms’ obligations to protect against evolving cybersecurity threats. On October 2, 2019, the Financial Industry Regulatory Authority (FINRA) issued an information notice to...more
On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more
As predicted, the start of 2019 provided scant respite from the frenetic pace of privacy and cybersecurity developments during 2018. This past month alone, in a blizzard of activity, regulators amended regulations and...more
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
A well-renowned think tank sued the Securities and Exchange Commission claiming that the SEC’s prohibition against respondents contesting allegations in enforcement settlements violates the freedom of speech guarantee under...more
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
Commencing March 1, 2016, all commodity pool operators, commodity trading advisors, futures commission merchants, retail foreign exchange dealers, investment brokers, major swap participants and swap dealers that are National...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
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
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