NIBA Journal

NIBA CFTC Comment Letter

March 16, 2016 Mr. Christopher J. Kirkpatrick Secretary of the Commission Commodity Futures Trading Commission Three LaFayette Centre, 1155 21st Street, NW Washington, DC 20581 RE: Proposed Rulemaking on Regulation Automated Trading (“Reg AT”) RIN 3038-AD52 VIA ELECTRONIC SUBMISSION Mr. Kirkpatrick: NIBA appreciates the opportunity to comment on the Commodity Futures Trading Commission’s (“Commission” or “CFTC”) proposed rulemaking on Regulation Automated Trading (“Reg AT”). Founded in 1991, NIBA is a trade association of registered derivatives professionals whose members include Introducing Brokers (“IBs”), Commodity Trading Advisors (“CTAs”) and Associated Persons. Our members handle transactions for customers in the futures, options, forex and swaps markets. The mission of the NIBA is to provide education which helps our members grow their businesses while staying in compliance, and to provide a forum for their opinions. We have the support of ten futures commission merchants (“FCMs”), various exchanges and trading platforms, and a solid, long-term...

Ask the NFA

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 NFA and NIBA members open, not to fix any specific individual concerns. This month's questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Q: If my office is required to record phone calls, do intra office calls need to be recorded or just calls with prospective and current customers? A: It depends on the rule that requires your office to record phone calls. NFA Compliance Rule 2-10 in part, requires that Members...

NYC Cybersecurity Panel Preview

Our industry has certainly transformed over the past decade. Much of this transformation stems from new rules and regulations, some of which are aimed at addressing the use of technology in the futures industry. As we are all aware, effective March 1, 2016, each and every NFA Member firm must adopt and enforce an information systems security program (“ISSP”). If you are not aware that this requirement exists, we encourage you to attend this session! NFA issued an interpretative notice approved by its Board of Directors on August 20, 2015 that provides guidance regarding information systems security practices that Member firms should adopt and tailor to their particular business activities and risks. This requirement falls upon all types of firms (FCMs, IBs, CPOs, CTA, RFEDs, Swap Dealers, and Major Swap Participants). During NIBA’s April 20, 2016 conference, I will be moderating a cybersecurity panel made up of experts spanning from...

The Value of Strategic Partnerships – Maximize Your Rate of Returns

Whether you are running a hedge fund, Introducing Broker, CTA, or CPO you are required to spend most of your time managing your investors, investments, and returns. In our regulated industry, you also need to hire an attorney, an auditor, a compliance expert, and an administrator that compiles your monthly performance results. These hires can be considered necessary evils. But if you hire the right team, you can extract more value to drive efficiency and reduce your business risk so you can focus more time on working with you investors, managing investments, and more importantly, making money. I have been in this industry for over 30 years. I started with the NFA when self-regulation was the start of an idea. As a NFA compliance auditor and as a futures industry compliance guru I have come across a number of success stories. The successful CTAs, IBs, and CPOs figured it out....

NIBA at the RJO Annual IB Conference

NIBA wants to thank RJ O’Brien for inviting us to exhibit and attend its Annual IB Conference March 4 and 5. It was great to see NIBA members who clear through  RJO and to participate in the sessions and social events. RJO is a founding member of NIBA. Participating in their conference is another wonderful way to celebrate NIBA’s 25th Anniversary Year.   Pictured below from left to right of top picture: Frank and Linda Stone, KC Trading Group, Melinda Schramm, NIBA Chairman and Kevin Craney, RJO Oasis. Lower picture: Jerry Nolan, Melinda Schramm, Shane Stiles

NIBA New York City Event- April 20th

April 20 - New York City All members are invited to the NIBA Spring Membership Meeting April 20 at the New York Athletic Club in New York City. Onsite registration opens at 1:30pm. The program closes at 5:00pm with a Networking Cocktail Reception. Registration is open now. The afternoon’s agenda includes*: *Two market updates presented by industry experts: Metals Update-- Jim Steel of HSBC Changing Ownership of Crude Futures Open Interest/Status of Barrel Ownership--Al Helmig, Grey House Energy market outlook-- “Oil & Gas: All Stored UP and No Where to Go” presented by Brian Milne of Schneider Electric *Cybersecurity Compliance Panel including: Rob DeMuria, Compliance Supervisors Ted Theisen, UnitedLex Amy McCormick, National Futures Association Michael Brice, B(W) CyberServices This program is complimentary for all NIBA members, including IBs, CTAs, FCMs and Service Providers. CTA EXPO/ New York will be held April 21 - the day following NIBA. For questions, suggestions...

Thank You - FCMs and Service Providers

Thank You - FCMs and Service Providers On February 25, NIBA held its annual thank-you reception for member FCMs and Service Providers. Thirty-nine guests attended the event held at Pazzo’s Restaurant in Chicago. We appreciate the support our ten member FCMs show NIBA and to the entire IB and CTAs community. FCM members have sponsorship opportunities throughout the year, are featured in our newsletter and rotate as advisors to the Board of Directors. If you would like to become an NIBA FCM Member, please contact Mike Burke, mikeb@highgroundtrading.com or Mike Coglianese, mike@cogcpa.com. Service Provider members provide the unique products and services needed for us to carry on our businesses while staying in compliance and up-to-the minute. Service Providers can join NIBA in three categories and receive various benefits in each. If you would like to become an NIBA Service Provider Member, please contact Ralph Preston, rpreston@hwfi.com. As we celebrate our...

Staying Focused on your Financial Goals

March Chairman’s Letter

Members - Wow - has this been a busy 30 days for the NIBA! Thank you to all the FCMs and Service Provider representatives who attended the Thank You Reception on February 25 in Chicago. Over 40 NIBA members gathered to review our 2015 activities, and preview the events scheduled for 2016. On March 4 & 5, NIBA was invited to exhibit at RJ O’Brien’s Annual IB Conference. RJO’s staff presented a terrific program which included cybersecurity compliance and IB business generating ideas, as well as product sessions. Thanks to RJO for a great time and the opportunity to catch-up with NIBA members and old friends. This month we have progress to report on two NIBA initiatives originated as suggestions from our Advisory Group. We met with representatives of the CME Group to discuss a series of videos which can be used by brokers to more fully understand the usefulness...

NIBA/ DePaul Internship Joint Endeavor

NIBA/ DePaul Internship Joint Endeavor- The NIBA is out to make your life easier! The idea for this internship program was proposed and found strong support among NIBAs Advisory Group. Qualified students will be matched with members looking for candidates trained in a broad array of critical sectors, including Finance, Statistics, Media, Marketing, and Law. The goal of our program is to foster meaningful development-importantly - for both the interns and the member. According to Tom Sandy, NIBA Member Rice Dairy’s experience with DePaul interns has gone very well and the company looks forward to participating in this new joint internship endeavor. NIBA and DePaul will work together to ensure a successful match. Additional information regarding the program, its progress and how to participate will be provided periodically in future Newsletter articles. The board asks all members- yes you- for constructive ideas toward strengthening the value of this program. NIBA...