NFA Institutes New Requirements for CPO Internal Controls Systems

Chelsea EllisBest Practices, Market Rules & Responsibilities, Operations


Effective April 1, 2019, every National Futures Association (“NFA”) member commodity pool operator (“CPO”) that handles customer funds must implement an internal controls system (“ICS”) that “is designed to deter fraudulent activity by employees, management, and third parties” to ensure that each Member CPO properly safeguards customer funds, provides accurate and timely financial reports, and fully complies with CFTC and … Read More

SCOTUS Decides Significant Copyright Cases, but Our Advice Remains the Same: Register Your Copyrights As Soon As Possible

Chelsea EllisStartup Tips & Resources


On March 4, 2019, the Supreme Court of the United States decided two cases that will impact the ability to practically enforce copyrights. In Fourth Estate Public Benefit Corp. v., LLC, SCOTUS held that under section 411(a) of the Copyright Act, a party can sue for copyright infringement only after official registration with the Copyright Office. This means that … Read More