NFA: Information Systems Security Programs Due March 1, 2016

Steven BylinaBest Practices, Market Rules & Responsibilities, Operations

national-futures-association-and-information-systems-security-programs

The National Futures Association (NFA) held its first NFA Cybersecurity Workshop on February 2, 2016 in Chicago. The workshop consisted of discussion of NFA Cybersecurity Interpretive Notice to Compliance Rules 2-9, 2-36, and 2-49 entitled Information Systems Security Programs (ISSP) and ISSP policy development. The NFA is requiring CPO’s, CTA’s, IB’s, FCM’s, retail foreign exchange dealers, swap dealers, and major … Read More

Another Shot Across the Bow for Proprietary Trading Groups, and By Association, HFTs and Algorithmic Trading Strategies

Michelle ComellaBest Practices, Market Rules & Responsibilities

The SEC published a proposed amendment to Rule 15b9-1 on April 2, 2015 that will impact Proprietary Trading Groups, and by association, HFTs‬ and ‎Algorithmic Trading‬ Strategies. Ziliak Law’s Thomas F. Cashman (Of Counsel) and Michelle M. Comella (Partner) provide insights on the Rule’s history and the potential changes.‬‬‬‬‬‬