The CFTC’s amendments to the recordkeeping rule became effective at the end of August 2017. Now that the CFTC has updated its recordkeeping rules to account for technological advances, what are the implications of the new rules? When updating compliance manuals, policies and procedures in respect of the new rules, market participants, such as FCMs, swap dealers, CPO/CTAs, investment advisers and BDs, should consider a comprehensive review of their recordkeeping policies to identify any weaknesses or gaps in CFTC (and SEC) requirements.
Akshay Belani, Partner; Christine Lombardo, Partner; Sarah Riddell, Associate of Morgan, Lewis & Bockius