NIBA Journal

Insights, analysis, and updates from the National Introducing Brokers Association

June 13, 2017

When Black Swans Aren't

When Black Swans Aren’t: Geopolitical Risk Management in the Age of “Extreme” Events Thursday, June 22nd, 2017 (11:30 am to 4:30 pm; boxed lunch and reception included) The past year has seen many seemingly unexpected events come to pass, from Brexit to the United States Presidential Election. The upheaval has continued into 2017: the rise of the National Front and Marine Le Pen in the French Election; the growing fractures in long-standing international alliances like NATO, NAFTA, and the European Union; and the wave of autocracy, nationalism, and populist retrenchment in the face of globalization. However, are we witnessing a series of "black swan" events? Could we see any of this coming? What types of models and practices can be used to identify and absorb the myriad financial, strategic, political, and operational risks associated with the current global upheaval and the realities of the twin, competing forces of populism and...

Chairman's Letter - June 2017

In the Good Old Summertime - Published 1902; Music by George Evans/Lyrics by Ren Shields “In the Good Old Summertime” is an American Tin Pan Alley song first published in 1902. It was one of the biggest hits of that era, going on to appear in many films including the 1949 film of the same name starring Judy Garland and a Mickey Mouse cartoon, circa 1930. The song was featured in the opening paragraphs of the book Elmer Gantry. “In the Good Old Summertime” has been recorded by The Andrew Sisters (1949); Les Paul & Mary Ford (1952); Bing Crosby (1954) and Connie Francis (1961), as well as the John Phillip Sousa Band (1903) and Nate King Cole (1963). Here in Chicago, the good old summertime has finally arrived. This summer there is much for the NIBA to do. On July 20, we hold our 4th joint symposium with DePaul...

John Lothian to Keynote Joint NIBA/DePaul University Symposium

NIBA and DePaul University will hold the 4th Annual Joint Symposium on July 20, 2017 at the downtown campus of the university. This afternoon event includes three business sessions and a reception. Attendance is complimentary for registered derivatives professionals -- registration is required. NIBA is happy to announce John Lothian of John Lothian News as the Keynote Speaker. John’s session will be followed by a Managed Futures session led by Mark Shore, Adjunct Professor, DePaul University and a Marketing session, led by Matt Kluchenek, Baker & McKenzie. Mark’s session is entitled “Allocator Triage/Operational Integrity.” His panel includes Tony Lombardo, AON. Matt’s session is entitled “Marketing Managed Accounts & Funds: Regulatory Traps and Considerations” and will focus on the numerous enforcement actions regarding performance figures, and the JOBS Act in the context of marketing a fund, among other issues. His panel members include: Turnkey Trading Partners, Shane O’Mara, NFA and Chris...

CME Group Planned Changes to Live Cattle Futures Contract Specifications

The Chicago Mercantile Exchange Inc. ("CME or Exchange"), based on discussions with market participants and with the USDA, intends to implement amendments to its Live Cattle futures contract to alleviate delivery capacity constraints impacting the contract after last trade date. The Exchange intends to implement the amendments, summarized below, as quickly as possible, and potentially beginning with the October 2017 expiration, and seeks industry feedback on the roll-out of the following amendments: Click Here to Read Planned Change to Live Cattle Futures Contract Specifications

By NIBARead article

May 25, 2017

4 min read

CFTC/NFA Cyber Security: One Year In

By: Greg Baracy, Turnkey Trading Partners As everyone in the Commodity Futures Industry surely knows during March of 2016 the CFTC and NFA implemented cyber security obligations which were applied to all member firms. At that time Futures Commission Merchants (“FCMs”), Commodity Pool Operators (“CPOs”), Introducing Brokers (“IBs”), and Commodity Trading Advisors (“CTAs”) were all obligated to put in place and maintain a written Information Systems Security Program (“ISSP”) specifically tailored to their unique operations. This article intends to identify areas that NFA has focused on during regulatory examinations Turnkey Trading Partners has assisted with during 2017. Ongoing Risks and Current NFA Focus There isn’t a day that goes by when we don’t hear of a cyber-attack happening somewhere. Whether it’s a hit on a multi-national corporation or a widely used email and networking platform, each incident makes the world stop and think “Was I affected by this and what...

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Housekeeping, Reminders and Updates - May 2017

May 25, 2017

6 min read

Housekeeping, Reminders and Updates - May 2017

Written by: Mark E. Ruddy, Esq. Jessica I. Brown, CAMS COMMODITY FUTURES TRADING COMMISSION Revisions to Form 8-R The Commodity Futures Trading Commission (“CFTC”) has revised Form 8-R, at the request of the National Futures Association (“NFA”). Form 8-R is the application form for individuals registering as an associated person (“AP”), floor broker, floor trader or to be listed as a principal of an NFA Member firm. The following is a summary of changes to Form 8-R: “Floor Trader Order Enterer” has been added to the list of registration categories. “Floor trader order enterer” is defined as an individual responsible for entry of orders from an entity floor trader’s own account. Individuals registering as a principal are required to report their title from a list of options. The list of titles under “Principal Information” has been revised. The following title options have been added to the list: “Sole Proprietor”; “Indirect...

By NIBARead article

May 25, 2017

2 min read

Ask NFA - May 2017

As your industry advocate, the NIBA provides many services which help your business stay in compliance with NFA regulations. “Ask the NFA,” is the way you can ask questions about those regulations and compliance requirements without having to call NFA directly. Just email us at nfacomments@theniba.com and we will get the answers for you. Please keep in mind the purpose of this contact is to keep the lines of communication between the NFA and NIBA members. This month’s questions were selected from those submitted by NIBA members. The answers were supplied by NFA staff. Have there been any enforcement related items surrounding cybersecurity this year? Are any expected? Given the sensitive nature of customer data that Member firms possess and the growing risks associated with cyber breaches, NFA's Cybersecurity Interpretive Notice requires Members to adopt and enforce procedures to secure both customer data and access to their electronic systems. This...

By NIBARead article