NIBA Comments to the NFA's Proposals for CTA/CPO Capital Requirements
In Re: Notice to Members I-14-03 Request for Comments - CPO/CTA Capital Requirement and Customer Protection Measures April 14, 2014 National Futures Association: The following comments regarding the above captioned Notice to Members are submitted by the National Introducing Brokers Association (NIBA). The NIBA, founded in 1991 is a membership association of Introducing Brokers (IBs), Commodity Trading Advisors (CTAs), Futures Commission Merchants FCMs) and other registered professionals who transact futures and options business primarily in, and for, the retail sector of the industry. These comments represent the opinion of our IB and CTA members only. The NFA should not impose a minimum capital requirement on CTA members. By definition, a CTA holds no funds and cannot control funds. The CTA’s client funds are held on deposit with an FCM. Since many CTA customers have a primary relationship with either an IB or FCM, that IB or FCM is monitoring the...