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”). [1] 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”).
Finn Dixon & Herling LLP is a law firm with extensive experience providing corporate, transactional, investment management, securities, tax, executive compensation, bankruptcy and litigation counsel. Our clients include large and small corporations, venture capital and private equity firms, financial institutions, hedge funds and other investment funds, investment advisers, broker-dealers, public and private businesses, executives, management teams and entrepreneurs.
Copyright © 2015 Finn Dixon & Herling LLP. All Rights Reserved. These materials may not be reproduced or disseminated in any form without the express permission of Finn Dixon & Herling LLP. These materials are intended to inform our clients and friends about developments in the law. They are not intended to constitute a legal opinion or advice or to address any client’s legal problems or specific situations. The format of these materials, and the complex nature of the subject matter, required the making of general statements that summarize an extremely complex body of law and that may be incomplete in some respects. Accordingly, the reader is cautioned against using any of this material in specific situations without obtaining the advice of competent counsel. In light of the foregoing, and the general nature of these materials, these materials should not be regarded, or relied upon, as legal advice.