New recording
requirements went into effect in January. Although some IBs are exempted, many
are not. The NIBA has opposed this requirement from its beginnings, noting that
enforcement is difficult -- if not impossible, it requires new expenses for
many offices, and requirements for recording of transactions vary greatly from
state-to-state.
We want to revisit this issue with the CFTC. Will you send us a note explaining
how the requirement is affecting you? Please include additional costs
(equipment, legal advice, extra staff, etc), you have expended and expect to
spend to stay in compliance; and, other issues you are running up against in
order to implement this rule.
Address your note to Melinda Schramm, and send it to melinda@futuresrep.com by March 1, 2014. We
want to get enough feed-back to bring before the Commission. We'll compile the
comments -- no individual's or IB's will be separately identified.
Melinda
Schramm, Chairman, NIBA
melinda@futuresrep.com
