NIBA Journal

Insights, analysis, and updates from the National Introducing Brokers Association

October 23, 2025

Special Alert: Introducing Brokers will be featured at FIA EXPO 2025

FIA Futures and Options Expo returns to the Sheraton Grand Chicago Riverwalk November 17 & 18th. SPECIAL ALERT: For the first time in several years, Introducing Brokers will be featured at EXPO. On Tuesday, November 18, 3:15pm IBs will present a panel you don't want to miss! Introduced by Melinda Schramm, President of MHS Capital Resource and Founder & Chairman of the NIBA, the panel includes: Morad Askar, EdgeClear Elaine Levin, Powerhouse TL Steve Petillo, Pinion Global Abbey Wilkins, Sweet Futures Matt Kluchenek, Katten Muchin This panel will discuss how Introducing Brokers are viewing and meeting industry and technology changes that are impacting our relationships with our customers, our FCMs and our trading platforms. Click here to view the full 2025 FIA EXPO Program To learn more about the Introducing Broker session contact Melinda, melinda@futuresrep.com. NIBA is proud to be an Association Partner of FIA Conferences.

From the Classroom to the Trading Floor

There is no single, clearly defined education path for entering the derivatives industry as professionals come from a range of academic backgrounds. Still, higher education plays a crucial role in preparing students for success in this complex and fast-evolving field. A strong foundation in finance, economics, and mathematics is essential. At the undergraduate level, students should prioritize courses in financial markets and institutions, investment analysis, corporate finance, and introductory derivatives. Just as important are courses in statistics and calculus, which help build the analytical and quantitative skills required for understanding pricing models, volatility, and risk management strategies. With the increasing reliance on algorithmic trading and quantitative research, a concentration or minor in applied mathematics, data science, or computer programming can provide a competitive edge. Where Futures Are Forged: DePaul Alumni making a footprint DePaul University boasts a strong track record of alumni who have gone on to hold prominent positions...

From Insight to Impact: Building a Risk-Smart Community

With a more complex global environment and continuous financial innovation, new and more sophisticated areas of risk have emerged. At the same time, rapid advances in artificial intelligence (AI) and machine learning offer powerful opportunities for private sector firms and financial institutions to enhance their risk management capabilities. Honoring a Legacy: The Founding and Mission of the Arditti Center Founded in 2006, the Arditti Center for Risk Management honors the life and legacy of the late Fred Arditti - a distinguished economist, pioneer in the futures industry, and former executive at the Chicago Mercantile Exchange - who also served as a member of DePaul University's finance faculty. The Center promotes the development of the risk management field by bridging the gap between industry and academia. Each year, it hosts seminars, conferences, and educational programs for students, faculty, scholars, and professionals. The Arditti Center has cultivated deep ties with the Chicago...

By NIBARead article

January 30, 2025

7 min read

2025 Compliance Outlook

Contributed by: Joe Schifano, Global Head of Regulatory Affairs at Eventus I. Introduction As the new Trump administration takes office in 2025, it brings a shift in leadership across federal regulatory and enforcement agencies, notably the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), and Department of Justice (DOJ). In the short term, market commentators predict that this transition may affect the scope and intensity of enforcement actions, as the administration could prioritize deregulation and scale back certain investigations and prosecutions. However, Introducing Brokers (IBs) and Commodity Trading Advisors (CTAs) must not become complacent. Enforcement priorities can shift quickly, and a future administration or even a change in leadership within the same administration might re-energize oversight and compliance requirements. Maintaining robust compliance programs is therefore a prudent strategy, particularly because technology and best practices are evolving rapidly. Indeed, compliance departments are under dual pressures: they may see reduced...

By NIBARead article

November 6, 2024

4 min read

CFTC Further Narrows Regulation 4.7 Exemption for CTAs and CPOs

Authored by: Jeff Henderson & Doug Arend, Greenberg Traurig Not all IBs operate exclusively as IBs. Some are also registered as CTAs and CPOs because of the nature of their business activities. Many IBs that are dually registered take advantage of the “registration lite” limited exemptive relief set forth in Commodity Futures Trading Commission (CFTC) Regulation 4.7 (Reg. 4.7) under the Commodity Exchange Act, as amended (CEA). Such IBs should be aware of changes to Reg. 4.7 adopted by CFTC on September 12, 2024. In a divided vote, CFTC Commissioners took another step toward limiting the availability and scope of relief provided by Reg. 4.7. Although the changes adopted by CFTC in the final rule (Final Rule) are less comprehensive than those the CFTC proposed earlier in the year (Proposed Rule), they are the latest in a series of changes further scaling back both the extent to which Reg. 4.7...

By NIBARead article

October 25, 2024

4 min read

JFX Cybersecurity Briefing: Guidelines for AI Usage

Contributed by: John Falck, JFX, LLC AI tools offer many efficiency benefits, but also introduce potential risks such as leakage of confidential data and providing false (“hallucinated”) or inappropriate information. These guidelines are intended to help small companies with their initial use of AI tools, enabling experimentation while supporting risk protection and management oversight. Disclose usage of AI tools To assist learning and supervision, use of AI tools should be disclosed verbally and as a note in documents or code documentation. Suggested examples, “Grammarly was used to review a draft and to suggest edits, most of which were adopted.”; “Copilot drafted an initial response to the topic question, which was reviewed for accuracy and edited. No company or client information was provided in the prompt.” Use paid versions of AI tools Although service terms change, free versions of AI tools have a higher chance of using user provided information in...

By NIBARead article

October 18, 2024

4 min read

Is a New Approach to Off Channel Communications Compliance on the Horizon?

Article Contributed by: John Ruark, Clark Hill The SEC and the CFTC have brought numerous “off channel” communications enforcement actions throughout 2024 for failure to preserve various forms of electronic communications, such as text messages and “WhatsApp” chat messages and for inadequate supervision of such messaging. For example, the SEC brought actions against 11 firms in September 2024, totaling $88 million in sanctions(1). That’s on top of SEC actions against 26 firms in August 2024, totaling more than $390 million in sanctions(2). The CFTC brought actions against four swap dealer and FCM firms in August 2024, with sanctions totaling $260 million(3). In September, the CFTC brought further actions totaling more than $30 million for off-channel communication recordkeeping and supervision issues(4)(4.1). Interestingly, all this enforcement activity has led to a few dissents from Commissioners of both the CFTC and the SEC. For example, CFTC Commissioner Summer K. Mersinger dissented with respect...

By NIBARead article

October 11, 2024

2 min read

Recent CFTC Order and Dissenting Statement

Contributed by: Braden Perry, KennyHertz Perry, LLC The recent CFTC Order (Release Number 8972-24) and the Dissenting Statement by Commissioner Mersinger raise significant questions about how the Commission interprets the rules regarding offline communications and recordkeeping, especially under Regulation 1.35. This is an important discussion for firms in the commodity trading realm, including all NIBA members, as it directly impacts compliance procedures and communication methods. Commissioner Mersinger’s statement brings to light a critical issue: the challenge of aligning modern communication methods with existing recordkeeping requirements. Her dissent suggests that the CFTC’s current approach to recordkeeping may lack flexibility and a clear understanding of how communications in the commodities space differ from those in other financial markets. Possible Rule Clarifications and Future Adjustments: Clarifying Offline Communication Scope: The CFTC may need to define what constitutes “unapproved communication methods” more clearly and establish guidelines tailored to the nuances of commodity trading. This...

AI Innovation in Finance, Agriculture, and Marketing

Author: Shane Stiles, President, Gate 39 Media As a marketing and technology agency serving financial and agricultural clients, Gate 39 is witnessing firsthand the transformative impact of artificial intelligence (AI) across these sectors. AI analyzes vast amounts of data to predict commodity prices, uncover patterns, and consider market sentiment, weather, and disruptions to provide a comprehensive market view. AI in Financial Services In finance, AI is revolutionizing risk management, fraud detection, and customer service. Machine learning algorithms swiftly analyze transaction data to identify suspicious activities, safeguarding the financial system's integrity. AI-powered chatbots are transforming customer service by offering personalized advice and support, enhancing satisfaction, and building long-term client relationships. Early AI tools in finance focus on simple reporting, summarizing data into visuals or reports. However, accuracy remains a concern, as many predictive analytics tools are correct only 80-90% of the time. While this may not be sufficient for financial decisions...

By NIBARead article

September 12, 2024

3 min read

A Powerful New Challenge to Exchange Enforcement Actions

Written by: Renato Mariotti and Maggie DePoy, Paul Hastings LLP Self-regulatory organizations, including futures exchanges, could face aggressive challenges in the wake of the SEC v. Jarkesy decision, which provides a new avenue to challenge regulatory enforcement matters. Its reach may extend beyond the SEC and other federal agencies to reach the NFA and even exchanges like CME and ICE that use administrative proceedings to police market participants. SEC v. Jarkesy In Jarkesy, the Supreme Court held that the Seventh Amendment entitles defendants accused of securities fraud the right to a jury trial. The Court reasoned that the Seventh Amendment applies to claims created by federal statute if they are “legal in nature,” as opposed to claims that seek equitable relief. Whether a claim is “legal in nature” depends on the cause of action and the relief sought. Under the Court’s two-part analysis, a securities fraud action is legal in...

By NIBARead article

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