It can be difficult to keep track of the various regulatory announcements and changes that occur from month to month.  To better assist you, Turnkey Trading Partners has put together a summary of the various regulatory notices and adjustments which have occurred since our last newsletter.
On January 13, the NFA decided to use its platform to remind all NFA members of their Third Party Service Provider (TPSP) and Information Systems Security Program (ISSP) obligations. Every futures commission merchant (FCM), commodity trading advisor (CTA), commodity pool operator (CPO), and introducing broker (IB) is required to develop and maintain annually, an ISSP and TPSP policy.  Turnkey has developed and updated 100’s of ISSP policies and written over 100 TPSP policies and accompanying risk programs since the new interpretation passed in September of 2021.
NFA also put out reminders to their members about their ongoing annual obligations. You can read more about these obligations for FCM’s and IBs here, and for CTA and CPO members here. Alternatively you can consider some of Turnkey’s advice from November of 2021 here.
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