The closure of the government for several weeks did not stop the progress on new rules being discussed and implemented by the CFTC. As the IBs focus on building his/her business and serving customers’ needs, the regulatory responsibilities ramp up. The Commodity Futures Trading Commission (CFTC) is working on capital requirement adjustments for FCMs which could impact margin requirements and ultimately the amount of money customers will need per contract.
The CFTC Rule 1.35(a) taping rule comes into effect on December 21, 2013. If you are an IB and fall under the guidelines set by CFTC, it is very important you comply with this rule. As discussed by the panel of attorneys at the NIBA Conference in September, compliance with new rules will likely be monitored closely by regulators. For Guaranteed IBs, make sure you check with your FCMs for guidance on policies and procedures you need to have in place to be compliant.
This is the time to get to know your compliance officers and regulators because they can help you through this turbulent time of new regulations. It also is the time to stay in touch with the NIBA on issues that impact you. The NIBA is your voice in the industry. Let’s remember that with every challenge comes new opportunity. We must accept change and work together to grow!
Paul J. Georgy
NFA Board GIB Rep