Dear
Members -
If you think endless snow storms and wind chills below zero have gotten you
pretty far down, don't even look at the new and proposed regulation discussed
below.
Over at the NFA, fines are now in place for registrants, including IBs, who are
late filing various reports. Fines are in the amount of $1,000 per day! No
doubt there are some bad apples who file late regularly, but currently there
are no exemption or waiver procedures in place for an IB who is late once
during the term of membership.
Also at the NFA, a proposal to have CPOs/CTAs meet minimum financial standards
has been suggested, along with a rule that requires an independent third party
to review and authorize a CPO's disbursement of any pool funds, and an
independent verification of performance results if those results are prepared
by a third party. This proposal also includes discussion of whether inactive
Members in the CTA/CPO category should be allowed to remain as NFA members. The
comment period on this proposal closes April 15, and we understand there has
already been quite a bit of discussion from the CPO/CTA community.
The weather we can't do much about, but the NIBA is preparing comments on the
two NFA initiatives above. I'd like to hear your opinions. Please send me an
email, melinda@futuresrep.com.
Next up: the CFTC's recording requirements which took effect in January. The
Commission estimated that only about 5% of total IBs registered would have to
comply with the new requirements after eliminating those who qualified for the
financial exemption. But we have heard from GIBs and IIBs alike who had to make
significant changes in their offices in order to implement this rule. Will you
share your experiences in the new Comment Section of this newsletter, or send
them directly to Ryan Griffeth, Newsletter Committee, ryan.griffeth@postrockbrokerage.com
And finally, an update on the CME Market Data Fees Policy. We reprinted the
update release just as we received it. The NIBA has an on-going conversation
with the Market Data Team and various account managers at the exchange. Your
comments have resulted in the changes outlined in the update. Contact the
exchange directly at the numbers provided on the release or send your comments
to Steve Petillo, NIBA President, petillo@coquest.com.
Congratulations to Paul Georgy, Douglas Bry and Ernest Jaffarian for winning
seats on the NFA Board of Directors to represent Guaranteed Introducing
Brokers, and CTAs/CPOs respectively.
Oh, wait...we can do something about the weather! Meet us in Newport Beach, CA
for our second annual NIBA SoCal Member Meeting. This event is
co-sponsored by CME Group and the NFA, who, along with McGladrey LLP, will
present two business sessions on managed futures and compliance and a networking reception. No charge to attend however, registration is
required. Contact Ralph Preston, Chairman of the event, with questions at rpreston@hwfi.com
Best regards, Melinda
Melinda Schramm, Chairman
melinda@futuresrep.com
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