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NIBA Briefings

November 7, 2013

4 min read

Five Ideas of CTA Due Diligence Part 2

In Part 1 of the article Five Ideas of CTA Due Diligence, we discussed several foundational concepts to keep in mind when applying a research due diligence process to a Commodity Trading Advisor. At the heart of a due diligence process is to understand as much about the manager as possible. A couple of years ago I met a journalism professor and I mentioned the students in my graduate level managed futures course at DePaul University write due diligence papers on managers. He said the due diligence process is very similar to how he teaches his investigative journalism students. Until he mentioned it, I never thought about it in those terms, but he was correct, it is the same process as investigative journalism and one can use similar techniques. During the NIBA due diligence panel I was a part of on September 18, 2013 some of the audience questions included...

Fed Likely to Postpone QE Tapering Decision Into 2014

The Federal Reserve is likely to postpone any decision on exiting or tapering its quantitative easing program until 2014. Current members of the FOMC are hyper-sensitive to economic data, especially regarding US labor markets. The government shutdown and debt ceiling debate has negatively impacted economic growth as well as made what economic data that is being released suspect in terms of informational value. Our own view is that the events in Washington, DC, will possibly cost the US economy about 1.5% real GDP growth in Q4/2013. Our projections back in the summer of 2013 were for a 2% annualized growth rate in Q4/2013, and now we have lowered our projection to 0.5% real GDP growth. The Fed will likely want to wait on more dependable evidence to form its own conclusions, and thus any decision on QE is now on hold. A key problem stemming from the government shutdown is...

Futures Market Education and The Equity World

As the retail futures industry navigates the equity world, it’s important for everyone within the industry to focus on educating their clients and prospects about futures trading. We know that people trade futures markets for a variety of reasons and helping your clients understand what the markets may offer them is one of the first steps to take. Market education, along with product awareness, is the foundation that provides the new or maturing futures trader with the greatest chance for success. Once a customer understands the basics of futures, it becomes easier to build awareness of the benefits. Efficiency in capital use and seamless access across different asset classes are concepts that can generate market interest and growth. One of the most important questions I received while on this panel was, “As we grow our business, is it Equities vs. Futures or Equities with Futures?” At CME Group we believe...

AML Discussion at the 2013 NIBA Conference

Normal 0 false false false EN-US JA X-NONE /* Style Definitions */ table.MsoNormalTable {mso-style-name:"Table Normal"; mso-tstyle-rowband-size:0; mso-tstyle-colband-size:0; mso-style-noshow:yes; mso-style-priority:99; mso-style-parent:""; mso-padding-alt:0in 5.4pt 0in 5.4pt; mso-para-margin-top:0in; mso-para-margin-right:0in; mso-para-margin-bottom:10.0pt; mso-para-margin-left:0in; line-height:115%; mso-pagination:widow-orphan; font-size:11.0pt; font-family:Calibri; mso-ascii-font-family:Calibri; mso-ascii-theme-font:minor-latin; mso-hansi-font-family:Calibri; mso-hansi-theme-font:minor-latin;} The NIBA conference held in Chicago last month offered a wide variety of informational sessions applicable to Introducing Brokers’ business. My compliments to Melinda Schramm and the NIBA board for assembling a conference schedule that covered topics of importance to the IB community, many of which were very timely, and provided an essential understanding of certain issues that currently impact IB business. I participated on the panel discussion on Anti-Money Laundering (“AML”) with attorney Neal Stevens, who provided a comprehensive overview of AML requirements, and NFA Associate Director, Valerie O’Malley, who discussed common deficiencies found in NFA reviews and their consequences. My focus was on the operational aspects of effective AML procedures and relevant...

Not a NIBA Member Yet? No Problem.

Are you planning on attending the NIBA fall conference in September, but youʼre not a member yet? No problem. You can join the Association when you register for the conference. Attendance at the event is complimentary for NIBA members. IBs and CTAs pay $150 per year. APs pay $75 per year. Also included in the IB and CTA membership is a subscription to the NIBA Journal, our online Newsletter and a listing in the online Broker Directory for the remainder of 2013. FCMs, Service Providers and others are urged to contact me directly. The NIBA membership meeting is more important than ever this fall. NFA and CFTC regulation changes will affect your day-to-day business. Reporting and recording requirements, plus potential substantial changes in FCM capitalization requirements will have an effect on your daily operations. Each of our business sessions will help you understand, prepare and comply with the NFA and...

NIBA Legal Update Panel Preview

I have the privilege of leading the NIBA Legal Update once again this year. This panel of industry experts including Mike Coglianese and Jeff Kopiwoda will address legal developments - CFTC, NFA and others - which will affect an IB or CTA business. One issue we will discuss is CFTC Reauthorization and why it is important to each of us. The NIBA has submitted a number of suggestions to the U.S. Senate Committee chaired by Debbie Stabenow which is responsible for the reauthorization process. Included are comments on customer protections, liquidation processes in the event of an FCM bankruptcy, Reg. 1.35 Recordkeeping Requirements, customer account insurance and FCM bankruptcy reform. We will be include all of this and more in our panel at 2:30pm, September 18, CME Group Building, Chicago. I look forward to seeing you in Chicago. Please contact me directly if there are issues you would like addressed...

NIBA Board of Directors Letter to Senate Committee

July 1, 2013 The Honorable Debbie Stabenow Chairwoman U.S. Senate Committee on Agriculture, Nutrition and Forestry 328A Russell Senate Office Building Washington, DC 20510 The Honorable Thad Cochran Ranking Republican Member U.S. Senate Committee On Agriculture, Nutrition and Forestry 328A Russell Senate Office Building Washington, DC 20510 Dear Chairwoman Stabenow and Ranking Member Cochran: The National Introducing Brokers Association appreciates the opportunity to submit the following comments to the Senate Agriculture Committee (Committee) with regard to issues relating to the reauthorization of the Commodity Futures Trading Commission (CFTC). The National Introducing Brokers Association (NIBA) is a non-profit membership association of Introducing Brokers (IBs), Commodity Trading Advisors (CTAs) and Associated Persons (APs). Founded in 1991, the NIBA’s purpose is to provide education to registrants primarily engaged in futures and options transactions on behalf of retail market users. The Association has the support of Futures Commission Merchants (FCMs) and Exchanges, and has...

A note from Jeff Malec, IIB representative for the NFA Board of Directors

It has been a quick three months since I was elected as the Independent Introducing Broker representative on the NFA Board of Directors, and I wanted to take a moment to thank those members of the NIBA who supported me. With just one meeting under my belt, I have begun to talk with various industry people about changes I believe need to be made at the NFA. These include better customer protections, accountability for mistakes made with MF Global and PFG, an overhaul of the promotional review process, better hiring and training for auditors, and an upgrade to the technology at NFA (who else struggles with the clunky online registration system) ? all of which I believe will make NFA not just a better self regulatory organization; but a better regulator for its members. One thing that has surprised me in my initial talks with various industry people is that...

Poll: 17.5 or 21 hour Day, What do you Say?

On April 17, 2013, the CME Group reduced grain and oilseed trading hours from 21 hours to 17-1/2 hours per day. This schedule cut afternoon hours and created a 45-minute pause in trading during the morning before open-outcry trading begins. This change back to the 1:15pm close was reportedly instituted by the exchange in response to complaints the longer hours were reducing liquidity and increasing operating costs. The NIBA took no official position in January in advance of the change as it was being contemplated because we did not receive any comment or opinions from NIBA members. Board members’ opinions were almost evenly split. Since the change of trading hours took effect, NIBA has received emails from members. Again, the opinions are evenly split. Some brokers like the return to the traditional close with comments like “less hours to cover” and “we have plenty of time to get our business...

Letter from Paul Georgy, GIB Representative to NFA Boards of Directors

Dear NIBA Members, It is not my intention to be the bearer of bad news, but managing an IB in 2013 will have even more challenges. The impact of Dodd-Frank is trickling down. It will impact us as the CFTC continues to develop new rules, and the NFA must assure they are implemented. A few rules we should all be aware of that will affect how we do business includes the “taping rule” which takes effect on December 21, 2013. This change will impact larger IBs which generate more than $5 million in revenue over 3 years. Another change which affects all of us is the amount of time in which margins calls have to be met before the FCM will receive a capital charge. The old fashion way of sending checks via US Mail may not be quick enough to meet FCM requirements. It may be beneficial to prepare...

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