Training in the New Customer Protection Rules

I have worked in conjunction with Exchange Analytics to develop an online course to satisfy the annual training requirements of the “Customer Protection Rules” that took effect in January, 2014. Exchange Analytics is the leading provider of Ethics and AML training to the futures industry. We are proud to say that 24 futures FCMs have … READ MORE

Risk Management Reviews-The Deadline Approaches

I am working with RPM Financial Markets Group, LLC to provide an independent review service for FCM Risk Management Programs. The Enhanced Customer Protection rules that became effective in July, 2014, require every FCM to adopt and implement a Risk Management Program. In addition there is a requirement for an annual review of the program … READ MORE

Annual Kent Compliance Conference

The annual IIT- Chicago Kent College of Law Conference on Futures and Derivatives will take place on October 17, 2014. This is an opportunity to hear directly from the regulators and SROs about the direction they are heading. If you want information about the program, please contact me.

New Customer Protection Rules

In October 2013, the CFTC adopted a new set of rules designed to prevent the reoccurrence of another MF Global type disaster. My article on the New Customer Protection Rules has been published in the July/August issue of Futures Magazine. To read the article please click here

Customer Protection

We are in the home stretch in implementing the Customer Protection Rules adopted by the CFTC in October 2013. On July 12, 2014, FCMs will need to have the following in place: Detailed Financial Disclosures on their website. Firm specific Risk Disclosure. Implementation of a Risk Management Program. New acknowledgement letters from depositories. The only … READ MORE

Cyber Security- FCMs, IBs, CTAs and CPOs

It seems that every day there is a report of a security breach at some company or another. Credit card numbers were stolen from Target and Neiman’s. Social security numbers and personal information were stolen from Advocate Health Care. And now there’s the discovery of the “Heartbleed” bug that may represent a serious vulnerability to … READ MORE

Acknowledgment Letters

The Joint Audit Committee issued a Regulatory Alert to remind FCMs that any new accounts for segregated funds, secured funds or sequestered funds will need an acknowledgment letter in the form of the revised standard template and that all existing accounts will need new acknowledgment letters by July 12, 2014.  

CFTC Outlines the Safeguards for Customer Records

On Feb. 26, 2014, the CFTC issued an advisory to remind FCMs, IBs, CTAs, and CPOs of their obligations under Gramm-Leach-Bliley to “adopt policies and procedures that address administrative, technical and physical safeguards for the protection of customer records and information.” The advisory outlined best practices including: 1. Designating a privacy and security manager 2. … READ MORE