By Catherine M. Anderson and Kate Leonard
The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs (“ISSPs”), which includes cybersecurity guidance and ongoing testing and training obligations.
The Cybersecurity Notice will be effective March 1, 2016 and applies to futures commissions merchants, commodity trading advisors,… More