CFTC

Reminder: NFA Cybersecurity Interpretive Notice Goes Into Effect on March 1, 2016

The National Futures Association ("NFA") Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49, entitled Information Systems Security Programs, becomes effective on March 1, 2016 and applies to all membership categories.

Key Focus Points
The Cybersecurity Interpretive Notice focuses on the following key topic areas:

Q1 2016 Regulatory Reporting Deadlines

The first quarter of 2016 is a busy one for regulatory filings. This alert provides an overview of the regulatory filing submission deadlines occurring from February through March 2016 for the reports supported by ACA’s Regulatory Reporting platform (RR).

Please note that the submission dates below are not an exhaustive list of regulatory filing deadlines occurring during this quarter, but are rather the dates for the reporting modules supported by RR.

CFTC Approves NFA Cybersecurity Interpretive Notice

The Commodity Futures Trading Commission ("CFTC") recently approved the National Futures Association ("NFA") Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49, entitled Information Systems Security Programs. The Cybersecurity lnterpretive Notice will become effective on March 1, 2016 and applies to all membership categories.

Key Focus Points
The Cybersecurity Interpretive Notice focuses on the following key topic areas:

NFA Releases Cybersecurity Interpretive Notice

The National Futures Association ("NFA") has released a proposed Interpretive Notice on information security systems programs. This notice is provided as an interpretation of the NFA Compliance Rules 2-9, 2-36, and 2-49. The NFA board approved the proposal on August 20, 2015, and has submitted it to the CFTC for review and approval.

Key Focus Points
The NFA Interpretive Notice focuses on the following key topic areas:

ETF Insider Trading

Bloomberg recently reported that the U.S. Securities and Exchange Commission (“SEC”) has initiated a probe into whether exchange-traded funds (“ETFs”) are being used to trade on inside information. ETFs are similar to mutual funds in that they hold a variety of underlying securities such as stocks and bonds and are traded on stock exchanges. However, unlike a mutual fund, ETF prices can fluctuate throughout the day.

CPO/CTA Registration Deadline Approaching

The December 31 CPO/CTA registration deadline is rapidly approaching. As a reminder, December 31 is the current deadline for actual registration (not application). The process for registering with the CFTC and becoming an NFA member is time-consuming. It involves various stages such as drafting and filing applications, preparing for and passing individual proficiency examinations (e.g., the Series 3 examination), conducting fingerprinting and background checks, and then awaiting NFA’s approval.