NFA reminded members of the April 1, 2019 effective date for an Interpretive Notice relating to CPO internal control systems. The Interpretive Notice mandates that CPOs implement an internal control framework designed to protect customer funds and ensure the accuracy of books and records. As previously covered, the Interpretive Notice requires that CPOs have written internal control policies that: comply with applicable NFA and CFTC requirements; explain the firms' internal controls; subject all personnel, including senior management, to internal control procedures; include escalation

Its impossible to make fun of either of them without losing clients and friends. Just not worth it. Instead, let's make an upbeat playlist! Enjoy:

NFA reminded members of recently amended (i) NFA Bylaw 301 and NFA Compliance Rule 2-24, and (ii) Interpretive Notice implementing swaps proficiency requirements. As previously covered, the amendments require that any individual engaged in swaps activities (whether registered as a swap firm intermediary or swap-associated person ("AP")), or simply acting as an AP of a swap dealer, satisfies NFA's Swaps Proficiency Requirements. NFA stated that the swaps proficiency requirements will become effective on January 31, 2020. The Interpretive Notice, titled NFA Bylaw 301 and Compliance Rule 2-24

FINRA proposed new Rule 7640B ("Data Products Offered by NYSE"). The proposed Rule 7640B would: describe FINRA's practices with respect to the distribution of market data for OTC transactions in National Market System stocks; and identify NYSE products that distribute FINRA/NYSE Trade Reporting Facility ("TRF") data to third parties. According to FINRA, Rule 7640B is "substantively identical" to Rule 7640A ("Data Products Offered by NASDAQ"), which concerns the distribution of FINRA/Nasdaq TRF data in market data products developed by Nasdaq, Inc. In addition, FINRA stated, the new rule would

The SEC named Jeffrey Dinwoodie as Senior Counsel and Policy Advisor for Market and Activities-Based Risk. SEC Chair Jay Clayton established this position to "manage and coordinate the agency's efforts to identify, monitor and respond to market risks" impacting the U.S. capital markets. According to the SEC, Mr. Dinwoodie will be Mr. Clayton's Deputy Representative to the Financial Stability Oversight Council and the "primary liaison" to other federal regulatory agencies and international organizations on the subject of addressing market risk. Since 2017, Mr. Dinwoodie has been the lead