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NFA Amends Interpretive Notice Regarding ISSPs

On January 7, the National Futures Association (NFA) issued a notice to its members that amendments to its Interpretative Notice, entitled NFA Compliance Rules 2-9, 2-36 and 2-49: Information Systems Security Programs, were finalized and will take effect on April 1.

The amendments make certain changes to the Interpretive Notice related to employee training obligations and information systems security program approval, as well as require NFA members to notify the NFA of certain cybersecurity incidents related to a member’s commodity interest activities.

The proposed amendments were previously discussed in the December 7, 2018 edition of Corporate & Financial Weekly Digest.

NFA Notice I-19-01 is available here.

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About this Author

Christian B. Hennion, Finance Attorney, Katten Muchin Law Firm

Christian B. Hennion concentrates his practice in financial services and asset management matters, including counseling fund managers, registered investment advisers and commodity trading advisors on both transactional and regulatory matters. Chris has advised a wide range of US and international managers, from start-ups to large institutions, regarding a variety of matters, including private fund launches and reorganizations, advisory engagements, Investment Advisers Act and Commodity Exchange Act compliance obligations, Securities and Exchange Commission (SEC) and Commodity Futures...


Timothy Kertland concentrates his practice on transactional, corporate and regulatory aspects of financial services matters. Timothy is able to provide legal services to a wide variety of clients including proprietary trading firms, hedge funds, broker-dealers, registered investment advisers, and commodity trading advisers.

While in law school, Timothy served as an editor of the Virginia Tax Review. As a first-year law student, he represented the University of Virginia School of Law at the National Transactional LawMeets Competition.