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. Identifying foreseeable internal and external risks to security 3.Design safeguards 4.Train staff 5.Test 6. Third party review. See CFTC Staff Advisory No. 14-21
