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
Early in November, after a highly anticipated week-long trail, a jury of twelve found CME futures trader, Michael Coscia, 53, guilty of six counts of commodities fraud and six counts of spoofing in Illinois Federal Court. The outcome of the case serves as a warning to other market participants as this may be only the tip of the iceberg for … Read More
Almost daily, headlines are peppered with reports of hackers breaching the cyber defenses of major institutions and governmental bodies, garnering information that could seriously compromise not only the financial well-being of countless individuals but also the financial stability of the nation. Even governmental bodies such as the U.S. Office of Personnel Management are susceptible to unwanted intrusions.  If the … Read More
How can an individual or financial services firm resolve futures and securities disputes? Ziliak Law Partner Michelle M. Comella outlines the options.
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.
FINRA issued Regulatory Notice 15-06 through which they announced their proposal to require associated persons of FINRA member firms who are either (i) primarily responsible for the design, development or significant modification of algorithmic trading strategies, or (ii) responsible for supervising such activities to register as Securities Traders. Read more from Ziliak Law Partner Michelle M. Comella. Update: The comment period … Read More
FINRA’s 2015 priorities, while often overlapping with those on the SEC OICE’s list, cover an expansive list of topics firms should be sure to review. Ziliak Law Partner Michelle M. Comella and Associate Diona Rogers provide insight.
This is the first of a series on financial regulators’ 2015 examination priorities. The SEC’s priorities focus on three broad topics: 1) protecting retail investors and, in particular, investors saving for retirement; 2) assessing market-wide risks; and 3) identifying and examining potential illegal activity through the use of data analytics. Ziliak Law Partner Michelle M. Comella and Associate Diona Rogers … Read More
Ziliak Law’s Doug Cahanin (Associate) and Zach Ziliak (Managing Partner) examine how ICE’s new anti-spoofing Rule 4.02(l) tracks—and differs from—CME’s earlier Rule 575.
Ziliak Law Associate Doug Cahanin, Founder of Derivatives Law Blog, wrote this blog on disruptive trading practices on October 21, 2014. It is excerpted below, the full article is available by clicking “read more.” Starting Point: The Commodity Exchange Act The Chicago Mercantile Exchange (“CME”) recently issued a new rule, CME Rule 575, and an accompanying Market Regulation Advisory Notice … Read More