CFTC Further Narrows Regulation 4.7 Exemption for CTAs and CPOs
Authored by: Jeff Henderson & Doug Arend, Greenberg Traurig Not all IBs operate exclusively as IBs. Some are also registered as CTAs and CPOs because of the nature of their…
JFX Cybersecurity Briefing: Guidelines for AI Usage
Contributed by: John Falck, JFX, LLC AI tools offer many efficiency benefits, but also introduce potential risks such as leakage of confidential data and providing false (“hallucinated”) or inappropriate information.…
Is a New Approach to Off Channel Communications Compliance on the Horizon?
Article Contributed by: John Ruark, Clark Hill The SEC and the CFTC have brought numerous “off channel” communications enforcement actions throughout 2024 for failure to preserve various forms of electronic…
Recent CFTC Order and Dissenting Statement
Contributed by: Braden Perry, KennyHertz Perry, LLC The recent CFTC Order (Release Number 8972-24) and the Dissenting Statement by Commissioner Mersinger raise significant questions about how the Commission interprets the…
A Powerful New Challenge to Exchange Enforcement Actions
Written by: Renato Mariotti and Maggie DePoy, Paul Hastings LLP Self-regulatory organizations, including futures exchanges, could face aggressive challenges in the wake of the SEC v. Jarkesy decision, which provides…
The Rising Tide of AI in Trade Surveillance: Adapting to an Increasingly Complex Regulatory Landscape and Solving for False Positives
Written by: Joe Schifano, Global Head of Regulatory Affairs at Eventus In recent years, the financial industry has faced mounting pressure from regulators, driving significant transformation within compliance functions. At…
Marketing and Promotional Material | Compliance Reminders from NFA
NFA Members are required to ensure that their customer solicitations and promotional materials are in compliance with NFA Compliance Rule 2-29. Subsection (a) applies to any type of communication with…
Practical Considerations in NFA’s Expanding Authority: Compliance Rule 2-51
Written by: Jeffry Henderson, Shareholder, Greenberg Traurig Douglas Arend, Of Counsel, Greenberg Traurig On March 29, 2023, National Futures Association (NFA) adopted Compliance Rule 2-51 (Rule 2-51), which became effective…
NIBA Compliance Officers Group Letter
To All Derivatives Compliance Officers: NIBA is excited to announce the formation of a new working group specifically focused on the concerns of compliance officers in the derivatives industry. The…
Regulatory Update – NFA Bylaw 1101
NIBA Service Provider Member, Scott Diamond of Ballard Spahr provides insights on recent regulatory developments concerning introducing brokers. Introducing Brokers, Commodity Trading Advisors and Commodity Pool Operators have long had…
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