It has been my great pleasure for the last year to serve as your NFA Board of Directors IIB Representative. I appreciate your continued support and it is my honor to be allowed to serve a second one year term in this position in addition to serving my first term as President of the NIBA.
I am pleased to report that during my first term on the NFA Board my suggestion to NFA staff to offer electronic voting to NFA members in NFA elections has been approved by the NFA Board and will come to fruition. While on the face this initiative may not seem to be a major accomplishment, it will allow for changes to be made that will give IB owners the ultimate control over who can be nominated as their representative for NFA board positions, who can sign petitions for individuals to be placed on the ballot for NFA board positions and most importantly who will be designated at the IB to cast the vote for that IB’s representative to the NFA board. The current structure allows for any registrant in an IB office to nominate a candidate, sign a petition for a potential candidate and to cast the one vote allowed to elect the NFA Board representative. These critical choices should be controlled and decided by the owner(s) of an IB.
It is imperative that IBs have a representative who can share and effectively communicate the wants, needs and concerns of the IB community to the NFA and CFTC. This past year I was able to arrange meetings of the NFA IB Subcommittee for input on a variety of items relevant to all IBs. One of those meetings allowed NFA staff to gather input from several IBs on the proposed Cybersecurity Interpretive Notice. As this notice is implemented and as new policies are created related to Cybersecurity, I will continue to ensure that IBs opinions and concerns are taken into account throughout the regulatory rulemaking process. In November, I was part of the NIBA committee that met with CFTC Commissioners in order to share the concerns voiced by several IBs relating to the cost of compliance and questionable benefits of some recently implemented CFTC rules. Specifically we discussed the scope and cost/ benefit of the “taping rule”, CFTC Rule 1.35. We also asked to be included in discussions of a costs/ benefits analysis on this rule. Additionally we volunteered our time to gather information and provide input relating to reviews of current rules and fact gathering and input on future proposed rulemaking that would impact the IB community.
I welcome input from all of you on topics you feel should be brought before the NFA Board or the CFTC. Please feel free to contact me directly via email mikeb@highgroundtrading.com or phone (312) 604-3043 to discuss these topics or with any questions, concerns, or comments that you have.
Again it is my honor to serve you as your IIB NFA Board Representative and as the President of the NIBA. Thank you for your continued support.
Sincerely,
Michael T. Burke
