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 to assess the adherence to and effectiveness of the program. Presumably, each FCM will need to complete this requirement by July, 2015
RPM has extensive experience in developing FCM policy and procedures and assessing regulatory compliance. I think that RPM is the ideal group to work with to provide this service.
If I can be of assistance in solving your Risk Management Program issues, please contact me.