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
CME Market Data Fees
Effective March 1, 2014, CME Market Data fees will apply to all new accounts using CME data for trading. For “non-professional” traders the fee is only $15 per month for all CME divisions. For “professional” traders the fee is $85 per CME division per month or $340 per month for the entire Exchange. “Professional” is … READ MORE
Segregated Funds
January 10,2014 Segregated and Secured Funds- The CFTC recently issued no action relief Letters 14-02 and 14-03 regarding the handling of customer funds that are intended for both segregated and secured accounts. This is a subtle but important point in the customer protection area.
NFA Requests Comments
January 23, 2014 Request for Comments- The NFA is requesting comments on proposed customer protection measures regarding managed accounts and pooled accounts. Among the areas being considered are capital requirements, 3rd party custodians and verification of pooled assets. Comments are due April 15, 2014.
FIA Law & Compliance June 22- June 24, 2015
I will be attending the FIA Law & Compliance event in Washington on June 22 through June 24, 2015. Hope to see you there.
The Blame Game
MF Global was a Broker-Dealer/ FCM that speculated in highly leveraged sovereign debt with their proprietary funds. At some point they used their customer segregated accounts to support their proprietary positions. The result was a bankruptcy filing on Oct. 31 that has caused massive hardship to their customers and wreaked havoc on the futures industry. … READ MORE
MF Global “Disgraceful Disconnect”
An unintentional loss of connection to the CME Globex trading engine is called an “ungraceful disconnect.” Your working orders are canceled and your position essentially is frozen. What happened on Monday, Oct. 31, 2011 had a similar result, but the cause was a total disgrace — the MF Global bankruptcy filing a “disgraceful disconnect.” The … READ MORE