Posts from September 2013.

The National Futures Association (“NFA”) announced its new quarterly filing requirement for commodity trading advisors (“CTAs”). The form is called NFA Form PR, and it requires CTAs to report to the NFA such information as general contact information, trading programs...

Recently, the Commodity Futures Trading Commission (“CFTC”) adopted final rules (the “Harmonization Rules”) amending the compliance requirements for operators of investment companies (“RICs”) registered with the Securities and Exchange Commissions (“SEC”), who are also subject to registration as commodity pool...

The stability of our financial economy can be deeply affected by the act of money laundering.  Anti-Money Laundering ("AML") programs for financial institutions are governed by various laws, including the Bank Secrecy Act of 1970 ("BSA"), the Money Laundering Control...

The role of the Chief Compliance Officer ("CCO") is to ensure that a firm complies with its outside regulatory requirements and internal policies.  This requires the CCO to administer, test and supervise the policies and procedures (P&Ps) of a firm...

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