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Ask NFA - March 2017

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NIBA
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2 min
As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly.  Just email us at nfacomments@theniba.com and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. I am an AP of an IB and also want to become a CTA.  What considerations are there for both firms if I decide to proceed with this setup? All NFA Members must meet the compliance and registration requirements associated with their categories. Visit NFA's and the CFTC's websites for additional information regarding registration and compliance requirements. For specific questions, please contact NFA's Information Center between 8:00 a.m. and 5:00 p.m. Central Time (312-781-1410 or information@nfa.futures.org). What are the do's and don'ts of working with an LOD systems provider from a broker's standpoint? NFA Members are ultimately responsible for compliance with NFA rules and CFTC regulations even when third-party service providers are utilized. NFA's Cybersecurity Interpretive Notice requires each Member firm to assess and prioritize the risks associated with the use of its information technology systems, including systems provided by a third-party service. In addition to other vulnerabilities, Members should assess the threats or vulnerabilities posted by third-party service providers and know the devices connected to their networks. Each Member's security assessment should, among other things, consider known threats identified by the firm's critical third-party service providers. I am looking to start an IB and considering having my trust or llc registered as the principal.  Each entity has multiple trustees/members do each also need to become registered? Each membership and registration application is unique to each applicant. NFA encourages those with unique questions on NFA membership or CFTC registration requirements to contact NFA's Information Center between 8:00 a.m. and 5:00 p.m. Central Time (312-781-1410 or information@nfa.futures.org).

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