Starting today, August 3, 2012, under CFTC Regulation 1.71, FCMs and IBs are required to adopt written policies and procedures that are reasonably designed to ensure that the firm and its employees are in compliance with Regulation 1.71. Subsection 1.71(a) sets forth a number of definitions that are material to understanding the requirements of the Regulation. Subsections 1.71(b) and (c).  In plain English applicable firms are required to create procedures designed to identify and consider conflicts of interest between their market research personnel and their trading/clearing personnel.

To learn more about this requirement please see: NFA’s notice on the requirements.

If your FCM or IB would like assistance in implementing these new, required policies please feel free to contact TTP at your convenience by phone or email.

Phone: (312) 324-0040