Dear Members -
For the 23th year in a row, this year’s NIBA fall conference was the best one yet!
It does seem as if we always think the NIBA meeting we have just finished was the absolutely best one ever. And looking back over the conferences since our first one in May, 1991, it is true. Each meeting addresses the hot topics of the day, highlights new products and services and brings old friends and colleagues together.
Thank you to all the speakers, sponsors and supporters for making the September 22 Chicago event a success. Please take a moment to take our survey and let us know what you want to talk about at our next member meeting - southern California in January, 2015.
In November, the first phase of CFTC Reg. 1.22 dubbed the “residual interest” regulation will be implemented. Although NIBA President Steve Petillo and I suggested to the Commission at our meetings in late August, that the industry as a whole was not ready for the rule and that they should consider pushing the effective date to at least January, 2015, it is highly unlikely this will happen. The Commission is confident all FCMs should be able to comply and, in turn, the FCMs will have the protocols in place to enable IBs to comply. The Commission indicated they will be studying the effectiveness of the regulation carefully, and will be open to possible changes by the time the rule is entirely implemented in four years.
This is a regulation NIBA is also following this closely. The vast majority of our members was opposed to it when it was first proposed and those opinions formed the basis of our opinion letter submitted to the Commission long before this regulation became final. Please continue to send us your comments regarding Reg. 1.22, including your costs to implement and comply with the rule, and changes you have made with regard to your customer relationships (and FCM relationships, if any.)
Best regards,
Melinda
Melinda Schramm, Founder & Chairman
melinda@futuresrep.com