NIBA Journal

NIBA New York City Event- April 20th

April 20 - New York City All members are invited to the NIBA Spring Membership Meeting April 20 at the New York Athletic Club in New York City. Onsite registration opens at 1:30pm. The program closes at 5:00pm with a Networking Cocktail Reception. Registration is open now. The afternoon’s agenda includes*: *Two market updates presented by industry experts: Metals Update-- Jim Steel of HSBC Changing Ownership of Crude Futures Open Interest/Status of Barrel Ownership--Al Helmig, Grey House Energy market outlook-- “Oil & Gas: All Stored UP and No Where to Go” presented by Brian Milne of Schneider Electric *Cybersecurity Compliance Panel including: Rob DeMuria, Compliance Supervisors Ted Theisen, UnitedLex Amy McCormick, National Futures Association Michael Brice, B(W) CyberServices This program is complimentary for all NIBA members, including IBs, CTAs, FCMs and Service Providers. CTA EXPO/ New York will be held April 21 - the day following NIBA. For questions, suggestions...

Thank You - FCMs and Service Providers

Thank You - FCMs and Service Providers On February 25, NIBA held its annual thank-you reception for member FCMs and Service Providers. Thirty-nine guests attended the event held at Pazzo’s Restaurant in Chicago. We appreciate the support our ten member FCMs show NIBA and to the entire IB and CTAs community. FCM members have sponsorship opportunities throughout the year, are featured in our newsletter and rotate as advisors to the Board of Directors. If you would like to become an NIBA FCM Member, please contact Mike Burke, mikeb@highgroundtrading.com or Mike Coglianese, mike@cogcpa.com. Service Provider members provide the unique products and services needed for us to carry on our businesses while staying in compliance and up-to-the minute. Service Providers can join NIBA in three categories and receive various benefits in each. If you would like to become an NIBA Service Provider Member, please contact Ralph Preston, rpreston@hwfi.com. As we celebrate our...

Staying Focused on your Financial Goals

March Chairman’s Letter

Members - Wow - has this been a busy 30 days for the NIBA! Thank you to all the FCMs and Service Provider representatives who attended the Thank You Reception on February 25 in Chicago. Over 40 NIBA members gathered to review our 2015 activities, and preview the events scheduled for 2016. On March 4 & 5, NIBA was invited to exhibit at RJ O’Brien’s Annual IB Conference. RJO’s staff presented a terrific program which included cybersecurity compliance and IB business generating ideas, as well as product sessions. Thanks to RJO for a great time and the opportunity to catch-up with NIBA members and old friends. This month we have progress to report on two NIBA initiatives originated as suggestions from our Advisory Group. We met with representatives of the CME Group to discuss a series of videos which can be used by brokers to more fully understand the usefulness...

NIBA/ DePaul Internship Joint Endeavor

NIBA/ DePaul Internship Joint Endeavor- The NIBA is out to make your life easier! The idea for this internship program was proposed and found strong support among NIBAs Advisory Group. Qualified students will be matched with members looking for candidates trained in a broad array of critical sectors, including Finance, Statistics, Media, Marketing, and Law. The goal of our program is to foster meaningful development-importantly - for both the interns and the member. According to Tom Sandy, NIBA Member Rice Dairy’s experience with DePaul interns has gone very well and the company looks forward to participating in this new joint internship endeavor. NIBA and DePaul will work together to ensure a successful match. Additional information regarding the program, its progress and how to participate will be provided periodically in future Newsletter articles. The board asks all members- yes you- for constructive ideas toward strengthening the value of this program. NIBA...

Cybersecurity Questionnaire

For the last several months Cybersecurity has been on everyone's radar. Now that the implementation deadline has passed, many NIBA IBs have put something basic in place. For those NIBA members who may still be looking to fine tune their program, policy and/or procedures, we’d like to offer a potential solution. Courtesy of Turnkey Trading Partners, the NIBA has obtained the following Cybersecurity questionnaire for you. Turnkey has been using this document to best determine how to implement Cybersecurity policies for nearly 100 CFTC registrants since the beginning of this year. If you have any questions or concerns after reviewing this questionnaire, it’s likely you will need additional assistance with your program. NIBA members with any doubts about their respective Cybersecurity programs would be well advised to contact a professional compliance provider for additional assistance.

Housekeeping, Reminders and Updates

Financial Crimes Enforcement Network The Financial Action Task Force (“FATF”) updated its list of jurisdictions with strategic anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) deficiencies. In response, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory in January announcing the updates to the list of jurisdictions identified as having strategic deficiencies in their AML/CFT regimes. Countries with inadequate AML/CFT programs, as identified by FATF, are categorized as: (i) jurisdictions that are subject to FATF’s call for countermeasures or are subject to enhanced due diligence (“EDD”) due to their AML/CFT deficiencies; and (ii) jurisdictions identified by FATF to have AML/CFT deficiencies. Countries subject to EDD or countermeasures are identified on the FATF Public Statement and the list of countries with strategic AML/CFT deficiencies is available in FATF’s Improving Global AML/CFTC Compliance; On-Going Process. FinCEN’s advisory, FIN-2016-A0001, urges financial institutions to review the changes to the list of jurisdictions to ensure that...

Ask the NFA

1. During the course of an NFA audit, when an item is noted in the audit report, how is that viewed internally by NFA? This depends on a number of factors. The purpose of examinations is to review compliance with NFA rules and CFTC regulations. NFA's philosophy has always been to provide education and direction to its members to ensure they understand their regulatory obligations. When instances of non-compliance are noted, firms are expected to come into compliance and demonstrate how it will be achieved. There are several factors NFA considers when evaluating examination findings: number of violations, repeat nature of violations, time period of non-compliance, lack of corrective action, etc. 2. I have specific questions on NFA's new cybersecurity policies we need to implement, is there a specific person or department at NFA that can give detailed answers to questions on that subject? In light of the almost daily...

Fix Your Users!

The cyber security industry has gotten great at boundary defense. “Firewalls, Firewalls, Firewalls” - that’s all you heard for a long time emanating from the boardroom. Well the times they have changed. Now there are so many regulatory bodies and frameworks to be in compliance with, it is a struggle to keep every mandate straight. Questions like: ”Is your networking properly segmented?”, “How often are passwords changed?”, “what is your password complexity?”, “Is anyone checking those firewall logs?” Meanwhile the bad guys are waiting for your cyber defenses to fail, or worse, finding their own way in. The way they are finding in is through your most valuable resource: your employees. And what common element do all those employees have? ACCESS. They have access to your valuable data associated with your business practices and your clients. This valuable data can be quickly monetized on the seedy side of the Internet:...

Prepare for 2016; NFA Examination Focus

The National Futures Association (“NFA”) Rules and Commodity Futures Trading Commission (“CFTC”) regulations that govern the futures, forex, and swap trading industry are subject to continuous interpretation, amendment, and update. Staying abreast of these changes is a critical component of maintaining regulatory and operational compliance for your next examination. NFA regularly emails member firms to advise them of pertinent rule changes, amendments, and interpretive notices. These Notices to Members are archived on the NFA website and are an excellent resource for Introducing Brokers (“IB”) and Commodity Trading Advisors (“CTA”) to stay up to date with the most recent industrywide regulation and rule adjustments. While NFA does it’s best to provide firm’s notice of changes, there are subtle nuances to the rules and expectations placed on regulated entities that may not necessarily be conveyed in these publications. Oftentimes, NFA Members are caught unawares or ill prepared in an NFA examination as...