NIBA Journal

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

AP Agreements: Why Your Firm Needs Them and What They Should Address
5 min read

AP Agreements: Why Your Firm Needs Them and What They Should Address

In this age of heightened regulatory scrutiny and the ever increasing risk of litigation from former employees and customers, coupled with the need to protect valuable trade secrets, it has become a best practice—if not a legal imperative—for IBs to require associated persons (APs) to enter into AP agreements. AP agreements are designed to help reduce risks to IB employers and clarify expectations with APs. Moreover, without such an agreement, a court may find that an IB has no trade secrets and no ownership of such important information as customer contact lists, marketing strategies or key documents. AP agreements touch on several different areas of law—laws that are prone to shift—and are also subject to a dynamic regulatory environment. Thus, the preparation of AP agreements requires careful attention. However, a carefully crafted AP agreement can help minimize risks to both parties while also establishing the parties’ expectations. In addition to...

By NIBARead article
Chairman's Letter
Member Announcements
3 min read

Chairman's Letter

Dear Members - Many NIBA Members are already feeling the effects of CFTC Regulation 1.22 as FCMs begin to phase in the changes to margining customer accounts as enumerated. The so-called "residual interest" provision in the rule, due in November 2014, shortens the three-day period which customers currently have to meet margin requirements. The time period further shortens in four years. The NIBA has vigorously opposed CFTC Reg. 1.22 since it was proposed. Included as part of the sweeping customer protection rules enacted by the Commission as a result of the Dodd-Frank Act and in response to the failures of MF Global and PFG Best, we have argued implementation of this rule could drive our customers, including farmers, ranchers and small hedgers, out of the futures markets by requiring "pre-margining" to maintain their accounts. Pre-margining would eliminate their ability to use futures as a risk management tool due to higher...

By NIBARead article
July Housekeeping Items
Housekeeping
1 min read

July Housekeeping Items

Upcoming IB Filings: 1-FRs for IBs are due 7/24/2014 for the 6/30/14 filing.  That is 2 days from today (Tuesday July 22)  Please be sure to file this prior to the deadline as there is now a $1,000 per day fine for a late filing Upcoming CTA Filings: In 2013, the NFA amended Compliance Rule 2-46 to impose a quarterly reporting requirement on all CTAs. This filing requires each CTA to report general information about the CTA and its trading programs.  For CTAs who have a 6/30/2014 quarterly filing, the due date is on Thursday 8/14/2014. New CFTC Rules: CFTC Rule 1.55 (j) requires each FCM to provide certain information that is specific to the clearing firm and its business in a new, mandatory FCM specific disclosure document.  According to the CFTC this new FCM d-doc is designed to enable customers to make informed judgments regarding the appropriateness of selecting...

By NIBARead article
July 8 DePaul Event Follow-up
Member Announcements
1 min read

July 8 DePaul Event Follow-up

On July 8, 2014, the NIBA presented its first co-sponsored event with DePaul University on the University campus in Chicago. DePaul staff recorded the program, and the full video will be posted on this site within the next few days. The afternoon program included a session on the effect CFTC Reg. 1.22 will have on our customer relationships, and one on managed futures as an alternative investment class. Attendees received handouts from NIBA service providers, as well as from DePaul, and we all enjoyed a reception on the 11th Floor terrace of the campus downtown building. Approximately 140 individuals registered for the July 8 event which was open to all industry professionals. Thanks to DePaul University -- Alex Perry and Dr. Carl Luft specifically, session speakers, members of the NIBA Board of Directors and volunteers who created and presented a terrific program. We're all looking forward to more NIBA/DePaul events...

By NIBARead article
CME Direct/ClearPort Agency Cross
Swaps FX
2 min read

CME Direct/ClearPort Agency Cross

Agency Cross on CME Direct On June 9th the CME launched Agency Cross on CME Direct. Agency Cross, also known as non-block trading, allows brokers to trade ClearPort products directly into Globex in non-block sizes. Block trading restrictions have become a major area of contention for many IBs. Agency Cross functionality is a welcomed addition for many brokers and traders, besides being a necessary addition by the CME to keep up with ICE. Agency Cross was rolled out to little fanfare as many firms were not even aware of it's introduction. This was more of a soft launch for the CME to test their systems and technical infrastructure. With the success of it's initial launch, the The CME is confident that additional markets will become available this October.  The standard ClearPort qualifications still need to be met by clients and the product listing is still missing many of the popular...

By NIBARead article
Trading Technology for Retail FX
Swaps FX
5 min read

Trading Technology for Retail FX

Trading Technology for Retail FX  The FX market offers many advantages to active traders – 24 hour trading, low transaction costs, the ability to earn interest on overnight positions, plus deep liquidity from a $5.3 trillion/day market.   One of the most important advantages though is the abundance of top notch technology and trading platforms that are offered completely free to traders by FX brokers.     FXCM, one of the largest FX brokers in the world, offers an array of free platforms and technology that allow for advanced system trading, an increasingly popular trend in FX trading.      Additionally, FXCM now offers system developers the opportunity to sell and distribute their custom strategies on FXCMApps.com Metatrader4 MetaTrader 4 (MT4) is the most popular and widely used trading platform among retail forex traders.  The popularity of MT4 is primarily due to the fact that it allows traders to customize...

By NIBARead article
The Cloud
Trading Technology
3 min read

The Cloud

I wrote this article in the “cloud”. You’ve certainly heard this term and have no doubt used a cloud service. But, what does the cloud mean and how are financial services firm taking advantage of it? To start, if you use Gmail or Google Drive / Docs you are using the cloud or a cloud service. Both are convenient services in the sense that you can access them from anywhere (and any device) and in the case of Google Docs you can share access and make simultaneous contributions. None of the information is stored on your computer (or phone or tablet) nor do you install any software (you simply use a browser), and in the case of a business operation you do not need to acquire and maintain any servers—in a physical sense. Google handles all of this for you—giving you a cloud to operate within. You essentially are leasing...

By NIBARead article
GIB Boot Camp: How to appeal to your FCM
Marketing
6 min read

GIB Boot Camp: How to appeal to your FCM

The futures industry is ever evolving and in case you haven't noticed there are fewer and fewer FCMs interested in taking on new GIB business. A myriad of items and issues are responsible for the change in appetite the FCM has for GIB business. In particular the increase in regulatory oversight and concern for exposure to fines and other sanctions have resulted in the FCM community stepping up their review process for new IB applicants as well as retention process for existing guaranteed IBs. The FCM business has not been the most profitable in the recent past as the economy struggled and interest rates have been stagnant, which historically was a major source of revenue within the FCM community. The largest issue for the FCMs in taking on new (or keeping smaller existing) GIB relationships is the risk, which comes in many forms these days such as regulatory risk, market...

By NIBARead article
CTA Insights: Novodyn Advisors on Risk Management
Managed Futures
5 min read

CTA Insights: Novodyn Advisors on Risk Management

It’s All About Risk Bruce Schneier, an author who wrote about how we perceive danger, outlined cognitive biases people fall victim to when making decisions about risk (Housel, 2011). Although general in nature, they apply to investing, specifically diversifying, or the lack there of.  The unknown is perceived to be riskier than the familiar. Schneier's example: "People fear kidnapping by strangers when the data supports kidnapping by relatives being much more common."  In investing: The Flash Crash in 2010 caused untold anxiety. Years later, it is still frequently mentioned as a serious risk to markets. In reality, though, it was a non-event. The entire event came and went in a few minutes. Most investors didn't even realize it occurred until it was over and losses were reversed. What made it scary is that it had never happened before and was so unexpected. Meanwhile, the risks posed by the herd mentality...

By NIBARead article
NIBA Member Spotlight on The Windham Group
5 min read

NIBA Member Spotlight on The Windham Group

NIBA Member Spotlight on The Windham Group Firm Name: The Windham Group, Inc. Founded: April 1997 # of Brokers: Four IB Status: Independent NIBA Member Since: 1997 Address: 363 West 22nd Street, NY NY 10011 Branch Offices: n/a Web: www.e-windham.com About the Firm:  How did you get started? Do you provide additional services besides brokerage? After working for thirteen years with Cargill Investor Services, primarily in the energy futures area, I left the firm to join ING Derivatives to head up their New York branch office. But after two years with the firm ING decided to exit the futures business, and I set off on mine own and established my own firm The Windham Group, an IB specializing in the energy futures and options markets. We had a tremendous advantage in being able to tap into the client relationships that we had developed over the years at both CIS and ING to help...

By NIBARead article