CFTC, NFA, CME – Written Supervisory Procedures

Commodity Futures Trading Commission (“CFTC”) registrants often mistakenly believe company written supervisory procedures (“WSPs”) once established do not need to be adjusted. Many times, after Turnkey Trading Partners (“Turnkey”) establishes a consulting relationship with a new customer, it is quickly determined that an overhaul of company policies and procedures is necessary. How can this be? Where is the disconnect between industry participants and regulators occurring? Can this problem be avoided?