By William Kelly Acknowledging the rapid evolution of information technology and correspondent threats, on August 20, 2015 the National Futures Association (“NFA”) issued an Interpretive Notice addressing cybersecurity concerns. The Interpretive Notice established general requirements relating to the information systems security programs (“ISSPs”) of futures commission merchants, commodity trading advisors, commodity pool operators, introducing brokers, retail foreign exchange dealers, swap dealers, and major swap participants …
New Derivative Position Limit Rule
Under the Dodd–Frank Wall Street Reform and Consumer Protection Act (commonly referred to as “Dodd-Frank”), Congress required the Commodities Futures Trading Commission (“CFTC”) to impose limits in speculative positions in physical commodity futures and options contracts and economically equivalent swaps. On November 5, 2013, the CFTC in a 3-1 vote approved a new rule (the “Rule”) that establishes position limits in 28 physical commodity futures …