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NFA approved the adoption of a new interpretive notice to
Compliance Rules 2-9 ( Supervision ) and 2-36 ( Requirements for Forex
Transactions ) that requires CFTC-registered firms that
outsource regulatory obligations to implement a written supervisory
framework governing the outsourcing arrangements.
NFA stated that firms should tailor their written supervisory
frameworks to their specific business activities, and should
address the following areas:
Initial Risk Assessment. A firm should
determine the appropriateness of outsourcing a particular
regulatory function, including the third-party provider s
security with regard to confidential, personally identifying