NIBA Journal

Insights, analysis, and updates from the National Introducing Brokers Association

April 26, 2017

NFA NYC Workshop May 10th 2017

Seats are still available for NFA's Member Regulatory Workshop in New York on May 10 and Chicago on May 11 Seats are still available for NFA's upcoming Member Regulatory Workshops for commodity pool operator (CPO) and commodity trading advisor (CTA) Members. If you've already registered, thank you. We look forward to your participation. The half-day workshops will be held at the New York Marriott Downtown in New York, N.Y. on Wednesday, May 10, 2017, and Summit West in Chicago, Ill., on Thursday, May 11, 2017. Each workshop includes two sessions—one on NFA Members' regulatory obligations regarding cybersecurity and one on reporting CPO and CTA financial information on Forms PQR and PR. During the cybersecurity session for all NFA Members, NFA staff will provide updates on NFA's cybersecurity examination findings and a panel of experts will share best practices. During the financial information session for CPOs and CTAs, NFA staff will...

By NIBARead article

April 26, 2017

3 min read

Ask NFA - April 2017

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. What are the guidelines for commission to equity ratios and do those change if a customer is trading with a CTA? NFA reviews commission to equity ratios during examinations. NFA does not have an established ratio that may or may not be acceptable. Rather, NFA views several factors in evaluating whether a ratio raises red flags...

Housekeeping, Reminders and Updates - April 2017

Written by: Mark E. Ruddy, Esq. Jessica I. Brown, CAMS FINANCIAL CRIMES ENFORCEMENT NETWORK Update to FATF List of Jurisdictions with AML/CFT Deficiencies On April 5, 2017, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory announcing that the Financial Action Task Force (“FATF”) updated its lists of identified jurisdictions with strategic deficiencies in their frameworks to combat money laundering and the financing of terrorism and proliferation. The purposes of FATF’s lists are to track and monitor compliance with the international anti-money laundering and countering the financing of terrorism (“AML/CFT”) standards. The changes to FATF’s list may affect US financial institutions’ obligation and risk-based approaches with respect to relevant jurisdictions. As per FATF’s February 2017 Public Statement, the list of jurisdictions have been updated to include the following: Jurisdiction subject to effective counter-measures Democratic People’s Republic of Korea Jurisdiction subject to enhanced due diligence Iran Jurisdiction identified as having AML/CFT...

NIBA NYC Conference

The NIBA's New York conference is quickly approaching and capacity is limited so make sure to reserve your spot now. You can register here. The full agenda has been published on the NIBA website and we have an excellent line up this year. See below for details. The NIBAs cocktail parties are well known and never disappoint and this year promises to be better than ever. NIBA has teamed up with Trader's Fulcrum to host a joint cocktail party. Traders's Fulcrum has become a big hit in Chicago and this will be their debut for the New York trading and brokerage community. Our conferences and events are not possible without the support of our members and sponsors. Thank you to our sponsors and supporters and we look forward to seeing you in the Big Apple.   NIBA NYC Conference Agenda and Sponsors Primary Sponsors CME Group Options City Straits Financial...

NIBA & DePaul Internship Program

NIBA and DePaul have joined efforts to introduce highly qualified graduates to members looking to bring state of the art edge to their own business. DePaul is dedicated to provide qualified interns to initial discovery, and NIBA is dedicated to bring qualified prospective employer to discovery. WIIFM- What’s in it for me? We don’t ask ourselves this when considering whether or not to bend down to pick up a $100 bill, but we do- we must- when the REWARD:RISK, or VALUE:EFFORT ratio is less plain. Regarding value or risk of a DePaul University internship, what you won’t get is a disinterested nephew of a company vice-president who wants to copy, shred, and get coffee. Instead, consider DePaul’s Arditti Center mission: “The Arditti Center will be a leader in the design and implementation of a state-of the-art curriculum in Risk Management” Consistent with Fred Arditti’s philosophy, the program will aim to...

Chairman's Letter - April 2017

“We do believe there are too many regulators...” Sharon Brown-Hruska, 1960- Sharon Brown-Hruska is a former Acting Chairman of the CFTC (2004-2005) and current director at NERA Economic Consulting. As a member of the Trump administration’s “landing” team, she told attendees at the New Risk in Energy Conference in Houston, TX earlier this month, that streamlining regulatory processes and relying upon fewer regulators is a Trump priority. Although she admitted there is no “game plan” as yet, she said regulatory reform is coming. The perennially proposed merger between the SEC and CFTC could be pursued “if it made sense, if there are real synergies there.” She went on to say that personally she didn’t think there were enough commonalities for the merger to take place, but the discussion is still open in this administration. Additionally, Ms. Hruska said that another possible area of reform is to “put some teeth into...

2017 NIBA SoCal - Macro-economic Outlook 2017

Erik Norland, Executive Director and Senior Economist of CME Group will present his overview of the entire economic spectrum in his presentation on the 2017 macro-economic outlook. Topics will include: The impact of Trump's fiscal policies on currency, bond and equity markets, implications of the new Administration's policies on trade and immigration, economic growth and investing in a highly leveraged world, Brexit aftershocks and the future of the EU, and China - another potential source of surprises.

2017 NIBA SoCal - Cyber-Security - Annual Review Requirements for your Information Systems Security Programs (ISSP)

As you are well aware, the number and sophistication of malicious cyber threat incidents in the financial sector has increased dramatically over the past five years and is expected to continue to grow. Robert DeMuria of Compliance Supervisors, Inc. will bring you up to speed on very important ISSP requirements, what are NFA requirements to monitor and review the effectiveness of your ISSP, cybersecurity training and making adjustments to your ISSP.

2017 NIBA SoCal - Marketing is a Process

Whether you’re an IB or a CTA, selling retail trading, institutional execution, or managed futures - marketing starts with a process. From creating leads, recording lead and sales notes, to ongoing lead management, Shane Stiles of financial marketing and technology firm Gate 39 Media walks through defining a marketing process and options for managing your leads and marketing activities. Download slides from the presentation (PDF)

By NIBARead article

March 29, 2017

3 min read

A Broker's Expanding Obligations

By Matthew Kluchenek and Michael Sefton It’s no secret that disruptive trading practices are a key concern of market regulators. Spoofing and other disruptive trading practices have garnered attention in recent years and traders and advisers have had to learn quickly the ropes on permissible trading practices. Now, it appears that FCMs (and possibly IBs) may have additional obligations as a result of the intense regulatory focus on disruptive trading practices. Recently, an FCM agreed to pay a $190,000 fine in settling a disciplinary matter at CME for violations of CME Rules 575.D and 576. See CME 15-0185-BC - Saxo Bank A/S (March 20, 2017). CME Rule 575.D prohibits trading practices that disrupt “the orderly conduct of trading or the fair execution of transactions.” CME Rule 576 prohibits the use of a Globex ID by another party. In this matter, the FCM operated an auto-liquidation algorithm to liquidate its clients’...

By NIBARead article

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