information systems security program

Members of the U.S. futures market will soon be measured against heightened cybersecurity standards geared towards enhancing incident preparation, prevention, and response among industry participants regulated by the National Futures Association (NFA)—a non-profit enforcement entity tasked with overseeing futures trading in collaboration with the Commodity Futures Trading Commission (CFTC).  Earlier this year, the NFA submitted an August 28, 2015 Proposed Interpretive Notice to the CFTC for review, seeking approval to implement new regulatory guidance ostensibly intended to clarify NFA Compliance Rules imposing an obligation of diligent supervision among NFA members. With the CFTC lending its approval on October 23, 2015, regulated industry participants will be required to design and implement enhanced cybersecurity measures that satisfy the NFA’s newly prescribed “acceptable standards for supervisory procedures,” now officially slated to take effect on March 1, 2016.