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.
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.
I will be attending the FIA Law & Compliance event in Washington on June 22 through June 24, 2015. Hope to see you there.
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
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
Everyone who has tried their hand at marketing has obsessed over the content of an ad or promo piece, and we have all struggled with the difficulty of reaching and engaging our target audience. I won’t diminish the importance of the message, but to reach certain audiences, the medium of communication may be as important … READ MORE
Due to the rapid rise and rapid fall of the crude oil market in 2008, the CFTC has recently proposed a new rule on speculative position limits for the energy markets. Numerous comments have been sent to the Commission and the debate is ongoing over the economic, legal and philosophical merits of imposing position limits … READ MORE
