Letter to the NIBA Membership
If you think endless snow storms and wind chills below zero have gotten you pretty far down, don't even look at the new and proposed regulation discussed below.
Over at the NFA, fines are now in place for registrants, including IBs, who are late filing various reports. Fines are in the amount of $1,000 per day! No doubt there are some bad apples who file late regularly, but currently there are no exemption or waiver procedures in place for an IB who is late once during the term of membership.
Also at the NFA, a proposal to have CPOs/CTAs meet minimum financial standards has been suggested, along with a rule that requires an independent third party to review and authorize a CPO's disbursement of any pool funds, and an independent verification of performance results if those results are prepared by a third party. This proposal also includes discussion of whether inactive Members in the CTA/CPO category should be allowed to remain as NFA members. The comment period on this proposal closes April 15, and we understand there has already been quite a bit of discussion from the CPO/CTA community.
The weather we can't do much about, but the NIBA is preparing comments on the two NFA initiatives above. I'd like to hear your opinions. Please send me an email, firstname.lastname@example.org.
Next up: the CFTC's recording requirements which took effect in January. The Commission estimated that only about 5% of total IBs registered would have to comply with the new requirements after eliminating those who qualified for the financial exemption. But we have heard from GIBs and IIBs alike who had to make significant changes in their offices in order to implement this rule. Will you share your experiences in the new Comment Section of this newsletter, or send them directly to Ryan Griffeth, Newsletter Committee, email@example.com
And finally, an update on the CME Market Data Fees Policy. We reprinted the update release just as we received it. The NIBA has an on-going conversation with the Market Data Team and various account managers at the exchange. Your comments have resulted in the changes outlined in the update. Contact the exchange directly at the numbers provided on the release or send your comments to Steve Petillo, NIBA President, firstname.lastname@example.org.
Congratulations to Paul Georgy, Douglas Bry and Ernest Jaffarian for winning seats on the NFA Board of Directors to represent Guaranteed Introducing Brokers, and CTAs/CPOs respectively.