NIBA Journal

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

Thank you DePaul University!
Member Announcements
June 25, 2015
1 min read

Thank you DePaul University!

Thank you to DePaul University and to the speakers at last week's NIBA/DePaul co-sponsored event in Chicago. Thank you especially to Dr. Carl Luft, Alex Perry, Mark Shore and Dr. Jacob Furst, all of DePaul, who along with Jerry Nolan, Steve Petillo, John Nelson and Holli Kranz of the NIBA, planned and presented the program. Nearly one hundred NIBA members heard sessions on meeting the challenges of marketing managed futures and updates on cybersecurity compliance before joining colleagues at a cocktail reception on the University Terrace. NIBA is in the second year of our academic partnership with DePaul University. A video of last week's business sessions will be posted on our website within a few days. Melinda Schramm, Chairman, celebrates the Blackhawks win during the NIBA/DePaul Chicago Event

By NIBARead article
NFA Reminder to Update ORS
Member Announcements
June 25, 2015
2 min read

NFA Reminder to Update ORS

Regulatory reminder: Accurate and current business contact information and email address When a firm first applies for registration, the applicant must provide the address of its main office location, its telephone number, and may provide a general email address. The applicant must also list the names, addresses and telephone numbers of the individuals whom the applicant designates as the firm's contacts for a variety of functions such as compliance, membership and enforcement. Email addresses are required for enforcement contacts and may be added for other contacts as well. On an annual basis, all registered firms must review the information in their registration records contained in NFA's Online Registration System (ORS), update any outdated or incorrect information and certify that all of the information is complete and accurate. Beyond the formal annual registration review process, registered firms have an obligation to continually update the information in their registration records to keep...

By NIBARead article
Housekeeping, Reminders & Updates
June 25, 2015
8 min read

Housekeeping, Reminders & Updates

Securities and Exchange Commission SEC Proposed Modernizing and Enhancing Information Disclosed and Reported by RICs and RIAs The Commissioners of the Securities and Exchange Commission (“SEC”) unanimously approved two (2) rules which would require enhanced disclosures and increased reporting by registered investment companies (“RICs”) and registered investment advisers (“RIAs”), as well as RIAs’ maintenance of additional performance-related records. RIAs are now required to report: Aggregate information related to the types of assets held in separately managed accounts (“SMAs”) and the SMAs’ use of borrowing and derivatives; and Additional information about an adviser’s advisory business, branch office operations and the use of social media. RIAs are now required to maintain: Back-up records of the calculations of performance information that is distributed to any person (current rules have this requirement with regard to information distributed to ten (10) or more persons); and Communications related to performance or rate of return of account...

By NIBARead article
Get to Know the Regulator: CFTC Division of Swap Dealer and Intermediary Oversight
June 25, 2015
5 min read

Get to Know the Regulator: CFTC Division of Swap Dealer and Intermediary Oversight

Who is in charge of the Division of Swap Dealer and Intermediary Oversight: DSIO is run by a Director, who is assisted by the DSIO Deputy Directors and Chief Counsel. Tom Smith is the Acting Director, and the Deputies and their respective branches are as follows: Mr. Smith, who also serves as Deputy Director of Capital, Margin and Segregation; Erik Remmler, Deputy Director of Registration and Compliance; and Kevin Piccoli, Deputy Director of Examinations. Frank Fisanich is the DSIO Chief Counsel. How many employees are a part of DSIO: DSIO has 89 employees, who are located in the CFTC’s Washington, D.C. Headquarters and in the regional offices in Chicago, Kansas City and New York. What is the general function of DSIO: DSIO oversees compliance with the Commission’s registration and follow-on regulations applicable to intermediaries. For example, DSIO assesses and monitors intermediaries’ compliance with requirements for: capital, margin, and customer asset...

By NIBARead article
Secrets from Inside the NFA
June 25, 2015
8 min read

Secrets from Inside the NFA

Until recently I was working as a field auditor with the National Futures Association (“NFA”). During my time at NFA, the self-regulator was enduring a great deal of criticism. After the failures of MF Global and PFG calls for the heads of NFA’s leadership were coming in at a frenetic pace. While this period was no doubt painful for NFA to endure, the long hard look in the mirror they had to take as an organization became transformative. Today NFA is implementing some of the most sweeping changes to its audit approach since becoming the industry’s lead watch dog. After joining Turnkey Trading Partners (“Turnkey”, a leading compliance service provider) I have frequently been asked by clients what internal changes NFA has made since the collapse of the aforementioned FCMs and final implementation of the Wall Street Reform Act (“Dodd Frank”) regulations. In this article I will provide some of...

By NIBARead article
FIA Webinar: Cybersecurity Threats: Preparation & Response
Member Announcements
June 22, 2015
1 min read

FIA Webinar: Cybersecurity Threats: Preparation & Response

Cybersecurity has been the subject of sessions at both the NIBA New York City event, April 1 and last week's joint program with DePaul University in Chicago. We will present another full session at our Annual Membership Meeting, September 24 in Chicago, directed at practices to protect your customers' data, including compliance developments and guidance. Next Monday, June 29, 2:30pm EDT, the Futures Industry Association (FIA) will host a webinar entitled "Cybersecurity Threats: Preparation & Response." We encourage you to learn more about the Financial Services Information Sharing and Analysis Center and the FIA.  Register here.

By NIBARead article
Trading at Settlement (TAS) for Agricultural Futures
June 8, 2015
1 min read

Trading at Settlement (TAS) for Agricultural Futures

First Trade Date Monday, June 8, 2015 Trading at Settlement (TAS) is an order type that allows a market participant to buy or sell futures contracts during the trading day equal to the yet-to-be determined settlement price, or at a price up to four ticks above or below that price. Why TAS Reduce uncertainty related to pricing around settlement Grain elevators and processors may use TAS orders to price forward contracts at or near the settlement value TAS orders offer a transparent alternative to floor based MOC orders, which will no longer be available after July 2 Key Features Available on CME Globex for Grain, Oilseed and Livestock futures Available for outrights and spreads Quotes will be published in real time on the screen throughout the trading day TAS order entry is not allowed prior to the beginning of each group's pre-open state Learn About TAS View SER View TAS...

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Calling All IBs!
Member Announcements
June 3, 2015
2 min read

Calling All IBs!

I have been writing The Complete IB Handbook since 1998 - this year marks the 6th edition. The Handbook is a look at the state of Introducing Broker business today and a how-to guide for starting an IB. CME Group sponsors The Complete IB Handbook and makes it available on its website. In order to update the contents for each year's edition, CME Group and I created a survey containing questions on subject areas from monthly expenses of running the company to markets most heavily traded by customers of an IB. I compile that data and write eight chapters of information which reflect how an IB business is handled. Surveys were emailed by the CME Group about mid-May. Here is the link to the survey in case you did not receive yours -- CME Group Survey You can help me write this guide by making sure it accurately reflects what...

By NIBARead article
Help Wanted!
Member Announcements
June 3, 2015
1 min read

Help Wanted!

Planning for the NIBA Annual Meeting, September 24 in Chicago is underway. If you would like to serve on the planning committee, please contact Mike Burke, mikeb@highgroundtrading.com or Melinda Schramm, melinda@futuresrep.com. This September's meeting will include five business sessions, a demo hall and a networking cocktail reception. Topics for two of the business sessions are already being developed and a committee is being formed. To serve on the committee, you must be able to attend planning sessions and help out onsite during the event. If you cannot serve on the committee, your suggestions for topics and speakers are still welcome - just send them to Mike. Thanks to the following members who have already volunteered: Tom Sandy, Rice Dairy John Nelson, Applied Research Mike Coglianese, NIBA Board of Directors Steve Petillo, NIBA Board of Directors Mike Burke, NIBA Board of Directors

By NIBARead article
June Chairman's Letter
Member Announcements
June 3, 2015
3 min read

June Chairman's Letter

Dear Members - The last few weeks have been busy for the NIBA. Just as we closed out a very successful member meeting in New York City, we stepped up work on the June 18 event co-chaired with DePaul University, Chicago and we formed a planning committee for our Annual Membership Meeting, September 24. Planning and implementing educational events is one part of the NIBA mission. Keeping up with, and notifying you about regulation update and change is another part. This month the NFA announced a proposal to reduce the number of members on its board of directors. For many years, it has been suggested that at 39 members, the NFA board was too large to get anything done in a timely, meaningful way. Overall, our members support the reduction proposal which leaves both IB positions intact but reduces the number of CTA/CPO representatives slightly to four with one of...

By NIBARead article
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