Adaptation of CFTC Regulations to Incorporate Swaps - Comment Letter - National Introducing Brokers Association - August 8, 2011

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Adaptation of CFTC Regulations to Incorporate Swaps
August 8, 2011

The letter from the NIBA addresses Regulation 1.35(a), that will require introducing brokers to "record all oral communications thatlead to the execution of transactions in a commodity interest or cash commodity." NIBA suggests that the requirement "effectively does away with the stigma and burden of the NFA requirement on the disciplined firms by imposing an overbroad burden on all IBs and APs, most of which run their businesses in accordance with the rules." NIBA further argues:

  • the provision will hurt small IBs who must invest heavily into new technology in order to comply with the regulation; and
  • the provision will effectively cut off all communication between brokers and customers while the broker is out of the office.


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