NIBA Journal

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

October 13, 2016

NFA Rep Panel Recap

I had the pleasure to moderating the NFA Rep Panel. The three panelists shared their insights with the audience concerning the key issues and challenges facing the IB and CTA/CPO communities as they are addressed on the NFA Board level. The panelists also responded to pertinent questions raised from the audience that covered a wide range of topics with very thoughtful and relevant responses. One of the biggest takeaways gleaned from the Panel was the inspiring response that all three gave to the question of “how can I get involved.” The Panelists encouraged the audience to volunteer to serve on the various committees at the NFA and reflected on the value and practical insight that the IB and CTA/CPO communities can bring to the NFA through this type of service, and reinforced the importance of “speaking with one voice” through the NIBA. Thanks to our NFA elected representatives who participated:...

How CME Group Agricultural Markets Operate

Nothing is more important to CME Group than the integrity of our markets. We use a variety of controls throughout the life of each trade, and those protections help to ensure customers have confidence in the market so they can manage their risk. We want to provide you with more information on how CME Group maintains the integrity of each market throughout the lifecycle of every trade. Please use the following link to read the full article: How CME Group Agricultural Markets Operate

Life of a Brokerage Firm <Part Three>

Life of a Brokerage Firm <Part Three> Ron Grossman and Ryan Griffeth conducted as series of interviews discussing the various stages of a brokerage firm. Interviews are presented here in Q&A form. The focus of part three is on the exit strategy, or lack thereof, and what firms who have formalized these types of strategies are doing to implement them successfully. <Industry Professional> Michael Coglianese, Coglianese, CPA How many firms do you talk to that have an exit strategy formalized? 10%. They all should have them. What would you advise a firm or broker who had an exit strategy but was unsure of how to execute it? Talk to an attorney and accountant who has experience in this area. It will be the best money they spend If a firm or broker does not have a non-compete or a transfer and assignment agreement in their contract what if any remedy...

NIBA Washington DC Visit

On October 27, representatives of the NIBA will be in Washington, DC. Melinda Schramm, Mike Burke and Ryan Griffeth will visit with CFTC Commissioners, staff and representatives of the Commodity Markets Council. To submit any topics you’d like us to include in these discussions, please forward them by COB October 24 to Melinda, melinda@futuresrep.com; Mike, mikeb@highgroundtrading.com; or Ryan, ryan.griffeth@potrockbrokerage.com. A summary of the Commission and CMC meetings will be published in the November newsletter.

Save the Date: SoCal Conference Feb 23, 2017

Newport Beach, CA - February 23, 2017 Mark your calendar now for the NIBA winter event February 23 at the Newport Beach, CA Marriott! After taking a year away, members told the board they wanted the Association to meet in southern California again. More than 75 members attended each SoCal meeting in 2013-2015. February 23 will be an afternoon of two-three business sessions followed by an open reception very similar to the NIBA forums presented annually in New York City and at DePaul University, Chicago campus. Program agenda and registration will be open @theniba.com about the first week in December. John Jensen & Ralph Preston are NIBA co-chairs for this event. To suggest topics or speakers, or to volunteer to help plan and implement the meeting, contact John, jjensen@hwfi.com, Ralph, rpreston@hwfi.com or Melinda, melinda@futuresrep.com Sponsorship opportunities are available. Contact Melinda or Mike, mikeb@highgroundtrading.com.

Chairman's Letter - Oct 2016

“Don’t cry because it’s over, smile because it happened” -- Dr. Seuss, aka Theodor Geisel (1901-1991)   Don’t you just love Dr. Seuss? His quote above perfectly sums up my feelings about our 25th Anniversary Conference held in Chicago at the CME Group, September 14. With over 240 registered members on hand to help celebrate, NIBA presented some of the most valuable conferences we have held in our 25 year history. And we had fun while we learned.   Thank you to Ryan Griffeth, NIBA conference chairman and his entire committee: Steve Petillo, Brian Gaffud, Barbara Schmidt-Bailey, Mike Burke, Shane Stiles, Jerry Nolan, Tom Sandy and Ralph Preston. Each and every panel broke new ground to present educational, fully actionable information to NIBA members. Ryan assembled a terrific group of speakers and moderators. You can find articles/features on many of the session topics in the NIBA archives.   Special thanks...

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NFA Proposes "Financial Health" Reporting Requirements for CPOs and CTAs

September 29, 2016

5 min read

NFA Proposes "Financial Health" Reporting Requirements for CPOs and CTAs

In an effort to better understand and monitor the financial health of certain members of the National Futures Association (“NFA”), the NFA has submitted a proposal to the Commodity Futures Trading Commission (“CFTC”) that would require commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) to report additional information about their financial condition on a regular basis. The recent proposal comes two years after NFA previously sought comments on possible minimum net capital requirements for CPOs and CTAs. Financial reporting may not, at first blush, seem as onerous as minimum net capital requirements. However, financial reporting will nonetheless require the careful attention and additional resources of CPOs and CTAs to calculate and report this information on an ongoing basis, as well as create additional recordkeeping requirements. The NFA proposal would amend NFA Rule 2-46 and adopt a new interpretive notice, NFA Compliance Rule 2-46: Reporting Financial Information on NFA Forms...

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NIBA "What's on the Radar at the NFA" Conference Session Recap

September 29, 2016

3 min read

NIBA "What's on the Radar at the NFA" Conference Session Recap

NIBA’s September 14 Conference opened up first thing in the morning with a panel discussion on none other than “What's on the radar at the NFA!” By the look on the faces of the crowed audience, the topics had many eyes wide open…more than your average cup of Latte can do in the morning. The panel, which was moderated by Robert DeMuria of Compliance Supervisors International, Inc., consisted of very reputable and qualified individuals: Joseph Mazza, CPA of Compliance Supervisors International, Inc.; Anibal Carlo, Manager of National Futures Association and Michael Coglianese, CPA of Michael Coglianese CPA, P.C. The discussion kicked right off with NFA discussing many of the key areas they focus on in their examinations. Suffice it to say that for 45 minutes, the panel made it clear that ALL NFA Member firms need to adopt and enforce reasonable and sound internal controls around their day-to-day processes. Whether...

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September 29, 2016

3 min read

NIBA Compliance Debate Recap

Inspired by this year’s presidential debate, the NIBA hosted its first ever compliance debate at a conference for their 25th year anniversary held at the CME Group on Sept. 14. Robert DeMuria, Vice President and Co-founder of Compliance Supervisors International, and Alexandra Lively, OSMTH United Nations Delegate, moderated the debate with an outstanding group of industry professionals. The panelists included Joseph Mazza, President and Co-founder of Compliance Supervisors International, James Bibbings, Founder and President of Turnkey Trading Partners, Patricia Cushing, Director of Compliance at National Futures Association, Scott Williamson, Deputy Regional Counsel at the CFTC, Erin Middleton, Senior Rules and Regulatory Outreach Specialist at the CME Group, Matt Kluchenek, Partner at Baker & McKenzie, Marc Nagel, Independent Compliance Consultant and Expert Witness, and John Roe, Co-founder of the Commodity Customer Coalition; Principal at BTR Trading Group; Founder of Roe Capital Management. Pictured Left to Right: Mr. Williamson, Miss Lively and...

Housekeeping, Reminders and Updates -- September 2016

Financial Crimes Enforcement Network Advisory on FATF List of Jurisdiction with AML/CFT Deficiencies On September 7, 2016, 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 purpose 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 lists may affect US financial institutions’ obligation and risk-based approaches with respect to relevant jurisdictions. Updates to the FATF lists are outlined in FinCEN Advisory FIN-2016-A004. National Futures Association Changes to Form PQR and Compliance Reminders to CPOs and CTAs The National Futures Association (“NFA”) announced a minor change to the quarterly report (Form PQR) for commodity pool operators (“CPOs”). The change to the PQR...

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