We would like to thank our friends at the National Introducing Brokers Association (“NIBA”) for stepping up and bringing this important issue to light with the Commodity Futures Trading Commission (“CFTC”).

NIBA understands this is a trying time for the industry at large and for the participants in and around our markets.  NIBA recently published information regarding the CARES act and how its members can navigate the process should they choose to do so.  Looking a few steps ahead the natural question became – are there compliance and regulatory considerations for firms that apply for and receive relief?

On Monday, April 13, NIBA together with FIA filed the following letter with the CFTC to address those concerns.  The request is focused on the accounting treatment of the government loans and/or forgiveness as it relates to a firm’s net capital requirements.  To read the full letter, please click here.