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Who’s Left Holding the Bag? The FCM, of Course

  ♦Third-Party Vendor Blues♦ An FCM develops a robust Information System Security Program that requires assessment of potential vulnerabilities in its computer systems. The firm hires a third-party IT provider to conduct quarterly network penetration tests, vulnerability scans and firewall audits. The firm has the…
Charlie Frank
April 5, 2018
News

The New Mantra for Market Conduct Compliance

  ♦The Market Conduct Mantra♦ In a recent issue of his Bridging the Week newsletter, Gary DeWaal coined this mantra: "Training, training and more training -- and make it specific!" DeWaal, Special Counsel with Katten Muchin Rosenman LLP, was referring to the need for market…
Charlie Frank
March 31, 2018
News

When Regulators Come Knocking

♦CFTC Stance: "No Pause, No Letup"♦ In 2017, the Commodity Futures Trading Commission (CFTC) collected total monetary sanctions of more than $413 million. And according to CFTC Chairman Christopher Giancarlo, that aggressive pace is not about to abate. At an industry conference, Giancarlo said there…
Charlie Frank
February 20, 2018
News

AML Compliance Deadline is Looming

  ♦Are You Ready for the AML Compliance Deadline?♦ Mark your compliance calendar for May 11! That’s the date on which compliance with new FinCEN Anti-Money Laundering rules (published May 11, 2016) is required. This deadline is important to note even if your firm has…
Charlie Frank
February 5, 2018
News

The Anti-Spoofing Rule is Here to Stay

  ♦And so is the Firm's Responsibility to Detect and Prevent Infractions♦ When Clifford Histed was deputy chief of the Securities and Commodities Fraud Section of the U.S. Attorney’s Office, Northern District of Illinois, he supervised the office’s investigation and indictment in the landmark Michael…
Charlie Frank
January 9, 2018
News

Why Bother with Market Conduct Training?

  ♦Providing In-Depth Coverage♦ Market Conduct is an important component of the CFTC’s Statement of Acceptable Practices, however there are many other areas that a Futures Ethics course must address. With so much ground to cover, Ethics training can only provide a high-level overview of…
Charlie Frank
November 27, 2017
News

Just Released: Market Conduct Training Course

  ♦Market Conduct Course Protects Against "Failure to Supervise"♦ Increasingly, firms are being slapped with "failure to supervise" and "insufficient training" charges for the indiscretions of their brokers, proprietary traders and even their customers. Recent cases resulting in large fines -- and for the first…
Charlie Frank
November 13, 2017
News

AML Training Course for Mortgage Lenders

  ♦Designed for the RMLO Industry♦ Our Anti-Money Laundering course was designed specifically for the Non-Bank Residential Mortgage Lending and Origination (RMLO) industry. It's delivered online and taken on-demand. Since 2012, the RMLO industry has been required to offer initial and ongoing AML training for…
Charlie Frank
November 8, 2017