December 4, 2015
The Commodity Futures Trading Commission (the “CFTC”) recently approved an Interpretive Notice by the National Futures Association (“NFA”) entitled NFA Compliance Rules 2-9, 2-36 and 2-49: Information Systems Security Programs (the “Interpretive Notice”).  The Interpretive Notice will become effective on March 1, 2016 and applies to all NFA membership categories (“Members”), including commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”).
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