The End of CFTC/NFA Remote Work?

Since last March, the world has grappled with the transformational effects of the Coronavirus (Covid-19) pandemic. A fundamental shift in how industries operate unfolded before our very eyes. Old standards were replaced almost overnight by newer and more efficient ones.

NFA Trade Execution Audit: Are you Prepared?

One of the trends we have identified during recent audits of Introducing Brokers (“IBs”) is that National Futures Association, Commodity Futures Trading Commission, and CME Group examiners are becoming increasingly granular about their testing of trade execution record keeping. In particular, we are seeing attempts to evaluate how brokerage firms are able to “recreate the trade”.

CFTC, NFA Third Party Service Provider Obligations

In February, NFA adopted an Interpretive Notice entitled “NFA Compliance Rules 2-9 and 2-36: Members’ Use of Third-Party Service Providers” which will become effective September 30, 2021. This notice is the first time NFA has publicly laid out its expectations for how member firms outsource certain of their company functions. It is important to recognize that NFA has not prohibited any registrant or member firm from outsourcing any function. Rather, they have set standards for what they believe reasonable outsourcing risks should and could look like.