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Commentary by Bob Zwirb

The NFA provided guidance to forex dealer members ("FDM's") on how best to establish, maintain and enforce a risk management program designed to monitor and manage risks associated with forex activities. The guidance relates to amendments to NFA Compliance Rule 2-36 ("Requirements for Forex Transactions") which was approved by the NFA Board of Directors in May 2015, and became effective on January 4, 2016.

Commentary by Bob Zwirb

The NFA filed a proposal with the CFTC to amend NFA Compliance Rule 2-36. The amendments involve forex transactions and financial requirements, and would create a risk management program for forex dealer members. Specifically, the amendments to Compliance Rule 2-36 would require each forex dealer member ("FDM") to designate a principal to serve as chief compliance officer ("CCO"). Each CCO would be required to prepare annual reports to be distributed to the NFA and the FDM's board of directors or senior officer. Additionally, the amendments direct FDMs to establish risk management programs