Chairman's Message | August 2011
Dear NIBA Member: On August 8, 2011, the Association filed a comment letter relating to the Proposed Amendment to CFTC Regulation 1.35(a). This proposed amendment goes beyond the NFA Rule which requires firms with a certain number of disciplined APs to record conversations with clients. The CFTC proposal would require every IB to record all oral and written communications with a client or potential client which lead to a transaction. After receiving member comments, the NIBA Board of Directors filed our Association comment letter vigorously opposing the proposed amendment. You can view the comment at http://comments.cftc.gov. Look for the comments due 8/08/2011. In January 2011, the Association also filed a comment letter opposing Proposed CFTC Regulation 1.71: FCM-IB Conflicts of Interest which would require IBs to separate people researching or analyzing price or markets from anyone involved in the firm’s trading or clearing functions who might prejudice or bias the...