Exchange Analytics

Exchange Analytics has recently begun offering a training program devoted to Block trading and EFRP.¬† This course, entitled “Non-Competitive Trading Practices” is designed to educate all staff in the requirements at the CME, ICE and ICE Europe.  

CYBERSECURITY TRAINING

Exchange Analytics, has launched a Cybersecurity Training program for the futures and derivatives industry. This 45 minute online course has been designed to satisfy the NFA cybersecurity requirements that went into effect on March 1, 2016. Please contact Exchange Analytics for details.

Training in the New Customer Protection Rules

I have worked in conjunction with Exchange Analytics to develop an online course to satisfy the annual training requirements of the “Customer Protection Rules” that took effect in January, 2014. Exchange Analytics is the leading provider of Ethics and AML training to the futures industry. We are proud to say that 24 futures FCMs have … READ MORE

Risk Management Reviews-The Deadline Approaches

I am working with RPM Financial Markets Group, LLC to provide an independent review service for FCM Risk Management Programs. The Enhanced Customer Protection rules that became effective in July, 2014, require every FCM to adopt and implement a Risk Management Program. In addition there is a requirement for an annual review of the program … READ MORE

Customer Protection

We are in the home stretch in implementing the Customer Protection Rules adopted by the CFTC in October 2013. On July 12, 2014, FCMs will need to have the following in place: Detailed Financial Disclosures on their website. Firm specific Risk Disclosure. Implementation of a Risk Management Program. New acknowledgement letters from depositories. The only … READ MORE

Acknowledgment Letters

The Joint Audit Committee issued a Regulatory Alert to remind FCMs that any new accounts for segregated funds, secured funds or sequestered funds will need an acknowledgment letter in the form of the revised standard template and that all existing accounts will need new acknowledgment letters by July 12, 2014.  

CFTC Outlines the Safeguards for Customer Records

On Feb. 26, 2014, the CFTC issued an advisory to remind FCMs, IBs, CTAs, and CPOs of their obligations under Gramm-Leach-Bliley to “adopt policies and procedures that address administrative, technical and physical safeguards for the protection of customer records and information.” The advisory outlined best practices including: 1. Designating a privacy and security manager 2. … READ MORE

CME Market Data Fees

Effective March 1, 2014, CME Market Data fees will apply to all new accounts using CME data for trading. For “non-professional” traders the fee is only $15 per month for all CME divisions. For “professional” traders¬† the fee is $85 per CME division per month or $340 per month for the entire Exchange. “Professional” is … READ MORE

Segregated Funds

January 10,2014 Segregated and Secured Funds- The CFTC recently issued no action relief Letters 14-02 and 14-03 regarding the handling of customer funds that are intended for both segregated and secured accounts. This is a subtle but important point in the customer protection area.