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Chairman's Letter - March 2018

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March 2019 - National Celery Month Paczki Day NIBA is excited to welcome new members: Nanhua USA (FCM); Sudrania Fund Services (Service Provider); and Zilliak Law (Service Provider). March brings changes to policies, rules and regulations that every registered derivatives professional needs to be aware of. First, updates to NFA’s Interpretive Notice regarding ISSPs, including instructions for notifying NFA of a cybersecurity incident go into effect April 1, 2019. Each registrant should review its current policy carefully and make the appropriate updates. During February, the NFA held member workshops to discuss these requirements -- the Notice can be viewed at the NFA’s website. An Interpretive Notice entitled Compliance Rule 2-9: CPO Internal Controls System will also go into effect on April 1. Although the exact system a CPO should adopt will vary according the size and complexity of its operations, this Interpretive Notice lays out certain key components it must include. On March 8, FinCEN updated its list of FATF-jurisdictions with strategic AML deficiencies. The list can be found on FinCEN’s website or at NFA Notice 1-19-08. All NFA member FCMs and IBs need to review and revise their AML programs accordingly. And, on March 1, NFA issued Notice 1-19-06, which is a reminder to access and review information about your annual and ongoing filing requirements. This Notice pertains to FCMs and IBs; a separate Notice was issued to CTAs. At the Feb. Chicago NFA Workshop, members had several questions about the dates of certain required filings - these Notices address those questions. NIBA’s spring membership meeting is just around the corner -- make your reservations now for April 10 at the New York Athletic Club. We’ve got a terrific program focused on sending you back to the office with regulatory updates, market information and the chance to catch up with your colleagues. Questions: Howard, hrennell@e-windham.com, Melinda, melinda@futuresrep.com, Steve, petillo@straitsfinancial.com or Mike, mikeb@highgroundtrading.com. Questions about your IB/CTA membership: Brad, bjanitz@midlandira.com. Best, Melinda Melinda Schramm, Founder & Chairman melinda@futuresrep.com

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