As we all settle into a new year, the growth of your business is your obvious goal. However, the matrix of industry rules, regulations and compliance procedures continues to evolve. So keeping up with the times, and remaining aware and diligent of your regulatory and business obligations, is not be overlooked. Note that at the April 20, NIBA Conference in New York, I will be moderating a Panel of attorneys and industry professionals for an interactive panel discussion entitled Rules, Regulations and Your Revenue. The Conference also includes several other Panels and presents a wonderful opportunity for NIBA members to ask questions to help them "keep up with the times" while growing their businesses.
Social Networking
One topic we will discuss is the use of Social Networking sites in the role of business development. While sites such as LinkedIn, FaceBook and others can be useful to introduce new opportunities which help build a virtual footprint for your business, they are not without potential pitfalls. As the use of these social networking resources continues to expand, we will discuss the importance of limiting the liability of your company through the creation of internal policies and procedures.
Compliance Rule 2-9: Self Audit Questionnaires
On another topic, NFA has proposed amendments to Compliance Rule 2-9: Self Audit Questionnaires. Clearly, as the CFTC and NFA have finally reeled forex operations into their regulatory jurisdiction, several amendments pertain to those issues. However, the proposed changes to not stop there. IBs must continue to stay on top of their AML requirement. CTAs and CPOs will be well served to keep abreast developments regarding review of disclosure documents and potential changes to registration requirements.
I look forward to seeing you in New York where we will have the time and resources to get deeper into these and other issues which will impact your business operations in the years to come.
Steve Pherson is a Partner at Schuyler, Roche & Crisham (SRC), a law firm very familiar with legal issues in the financial industry. Steve is the legal advisor for the NIBA; SRC is the sponsor of Focus on the Membership, a column appearing regularly in the NIBA Journal. Contact Steve at spherson@srcattorneys.com.
