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Swap Dealers Information Systems Security Program (ISSP)

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
Dechert LLP

NFA Adopts Cybersecurity Guidance

Dechert LLP on

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

Foley Hoag LLP - Security, Privacy and the...

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs...more

McGuireWoods LLP

Four Cybersecurity Ideas from CFTC Commissioner Bowen

McGuireWoods LLP on

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

K&L Gates LLP

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

K&L Gates LLP on

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

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