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The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") issued a Staff Advisory that outlines the recommended best practices for covered financial institutions to comply with Gramm-Leach-Bliley Act ("GLBA") Title V and CFTC Rule 160 ("Privacy of Consumer Financial Information under Title V of the Gramm-Leach-Bliley Act") regarding security safeguards. Pursuant to CFTC Rule 160, futures commission merchants ("FCMs"), CTAs, CPOs, introducing brokers, retail foreign exchange dealers, swap dealers ("SDs") and major swap participants ("MSPs") must adopt policies and procedures that