NIBA Journal

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

April 9, 2021

NFA to hold Member Town Hall webinar on April 20

To provide Members with an opportunity to ask questions of NFA's leadership, NFA will conduct a Town Hall webinar on Tuesday, April 20, 2021, at 9:30 a.m. CT/10:30 a.m. ET. During the webinar, NFA Board Chair Maureen Downs, NFA Public Directors Ron Filler and Doug Harris, President and CEO Thomas Sexton and NFA's officers will provide a short update on NFA's recent initiatives and respond to questions submitted by Members. If you would like to submit a question prior to the webinar, please email it to feedback@nfa.futures.org. There is no charge to attend the webinar; however, registration is required. Register now. If you are unable to attend, a transcript and archived version of the webinar will be available on NFA's website in early May.

TotalView | Conquer the Wave

  Article for NIBA Newsletter | Copyright Jane Rubin 2021 Ad Agency: TOTALVIEW Global | totalviewglobal.com TEL 917-539-0899 | solutions@totalviewglobal.com __________________________________________________________________________ Commit to it. NIBA Members are experts in the art of trading, trading technology, and trading systems. You provide depth and cutting-edge products and services. You have years of experience with a range of futures and commodities instruments and complex global markets. You are obsessed with industry innovation. You are equally obsessed with precise, consistent execution. You provide round-the-clock attention to detail in how you service your clients. However, too often your branding does not live up to that depth and expertise. The intention of my bluntness is to motivate: Having reviewed the websites of numerous firms in the NIBA Directory, in terms of online presence they fall into two general categories: 1) unoriginal template-based design, (i.e. WordPress or Joomla sites;) or 2) not designed at all, (i.e. textual...

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Springtime Compliance Housekeeping Items

March 25, 2021

5 min read

Springtime Compliance Housekeeping Items

In January 2021, at the request of Futures Industry Association (“FIA”), CME Group Inc. (“CME”), ICE Futures U.S. (“IFUS”), and the Minneapolis Grain Exchange, LLC (“MGEX”), the CFTC granted partial extensions to previously issued No-Action positions to facilitate the physical separation of registrant personnel in response to the COVID-19 Pandemic. In connection with an industry-wide response to the COVID-19 pandemic, the CFTC granted no-action relief in a series of letters in 2020 for failure to comply with certain CFTC regulations, where compliance was anticipated to be particularly challenging or impossible because of the displacement of the personnel from their normal business sites, due to implementing recommended practices, such as social distancing and closures, to curtail the spread of the COVID-19 pandemic. In the CFTC recent extensions, the CFTC is extending the relief for timestamping orders until April 15, 2021 and the extension of relief for Oral Recordkeeping until March 31,...

Looking for a Summer Intern?

DePaul University remains a terrific source of qualified, quick-to-learn, hardworking individuals who have an interest in the derivatives business. Many NIBA members have welcomed students from the University as summer interns -- several of those interns have gone on to become employees. For more information, contact Mark Shore, mshore1@depaul.edu.

Artificial Intelligence & Machine Learning in the Palm of your Hand

With an overwhelming majority of traders using online brokerages, QuantGate’s mission is to empower traders worldwide to trade more dynamically in any market at any time. Using proprietary algorithmic logic and advanced machine learning that has been developed over 20 years, we quantify the collective perception of the market by monitoring the collective behaviour of all traders who are actively participating in the market. With multiple types of platforms available, it is our mission to bring this technology to all types of traders across multiple asset classes. It’s not where the market has been nor where it is right now that matters (which is what price charts offer), but rather the direction in which it’s heading (what price charts do not offer). When people refer to sentiment they generally refer to social media sentiment and the at-the-moment effects. These positive or negative social media trends can affect anything from a...

NFA Annual Meeting Update

NFA held its Annual Meeting Feb. 2, 2021. Some take-aways and responses to NIBA members’ specific questions are: NFA General Operating well with about 3-7% of staff in the downtown office. Financial, IT and Cybersecurity areas are all strong. COVID Relief (in co-ordination with CFTC) NFA is discussing a possible re-definition of what a “branch office” is in light of “work-at-home” issues with most IBs. Oral Recording Requirement: Due to expire March 31 -- will likely not be extended by CFTC for IBs. Time-Stamping Requirement: Due to expire April 15 -- may be extended by CFTC after evaluation of the methods and efficacy firms have/are implementing. Exams Virtual or hybrid exams are currently working well. NFA continues to monitor market volatility and will closely monitor firms that are impacted. There are issues at times in getting documents or responses from firms, but for the most part the exams are being...

New Year Wishes from AFEX

On behalf of the American Financial Exchange, I wish all the NIBA members a happy, healthy and prosperous New Year. I know 2020 has been challenging, but I want to start on an uplifting note to remind us all that how we face our difficulties can make a big difference in the levels of success we achieve moving forward. Here’s to 2021, and learning lessons from this past year that will catapult us into a brighter future. I want to share with you a link to a story that ran in BankDirector.com where I talk about the end of Libor—the most important number in finance—and where we go from here… https://bit.ly/2ITC9CA Richard L. Sandor, Chairman and CEO, The American Financial Exchange  

Cybersecurity - The World We Live In

By: Cameron R. Scullen, Esq., Associate Attorney, Ruddy Gregory, PLLC* In today’s modern day world, the issue of whether not traders and firms have adequate cybersecurity is constantly discussed. In fact, regulators themselves are noting the potential severity of cyberattacks: “Cybersecurity is a risk that the Division of Swap Dealer and Intermediary Oversight (“DSIO”) and [U.S. Commodity Futures Trading Commission (“CFTC”)] take seriously.”(1) But – it is one thing to take notice and another to protect one’s business with adequate cybersecurity. The CFTC conveyed the same in its recent public statement that was titled the following: CFTC Encourages Standardized Approaches to Assessing Cybersecurity Preparedness, Including the FSSCC Cybersecurity Profile. Therein, the CFTC reiterates that firms subject to its regulatory oversight must follow “generally accepted standards and best practices with respect to the development, operation, reliability, security, and capacity of their automated systems” pursuant to CFTC regulations(2). However, the CFTC remains...

Ransomware During COVID and the Need for Proactive Cyber Hygiene

By Braden Perry, Partner at Kennyhertz Perry, LLC Earlier this year, the COVID-19 pandemic caused businesses to rapidly deploy a remote workforce, which created new challenges for financial firms to continue operating and providing critical services. It also created an opportunity for malicious actors to hack into and gain access to IT systems and sensitive, personal information that these financial firms maintain. Among the most dangerous cyber threats is ransomware, malware that encrypts user or system files. The cyber actor then demands a ransom to restore the data through the use of a decryption key. These attacks have escalated since the pandemic began and continue to rise among financial institutions through remote desktop protocol (RDP) vulnerabilities. These attacks have occurred with varying levels of debilitating damage, from affecting various systems to complete shutdown, with the cyber actors generally threatening to release victim data publicly, in addition to leaving systems locked...

Cyber Security: Safety, Compliance or Both?

Good security protects against cyber threats. Regulatory compliance protects your business too. NFA Interpretive Notice 9070 sets the requirements and guidelines for an effective security program that meets both cyber security protection and compliance goals. Cyber Security or Compliance? Some executives are unsure if their cyber security program should be compliance driven or security focused. Being secure and in compliance are not the same thing, but NFA 9070’s requirements and guidelines help member firms achieve both. This article summarizes some key elements of NFA 9070. Written ISSP Member firms are required to have a written document that describes their Information Systems Security Program (ISSP) and designates the executive responsible for it. The ISSP and its implemented controls must be documented, and must be reviewed at least annually for effectiveness by someone with appropriate security expertise (internal or external). Security Actions and Safeguards After considering technology risks and their possible impact,...

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