Ruddy Gregory PLLC., won "Best Boutique Law Firm" and was a sponsor at the dinner. … [Read more...]

New York State’s "first in the nation" cybersecurity regulation takes effect March 1, 2017, Governor Andrew M. Cuomo announced. The regulation, intended to protect New York’s financial services industry and consumers from cyber-attacks, requires banks, insurance companies, and other financial services institutions regulated by the Department of Financial Services to establish and maintain a … [Read more...]

The Bureau of Economic Analysis (“BEA”), a division of the U.S. Department of Commerce conducts surveys to collect and analyze investments into and out of the United States (“U.S.”). These surveys, conducted quarterly, annually, and every five years, analyze U.S. investments in foreign funds and foreign investments in U.S. funds.  In 2015, the BEA changed the reporting requirement of one of these … [Read more...]

The CFTC announced that it has granted no-action relief to provide for a "grace period" until September 1, 2017, during which swap dealers (SDs) subject to the Commission’s variation margin requirements can come into compliance with rules for the uncleared swaps of SDs without prudential regulators. Part of the relief involves CFTC Regulation 23.153, for which compliance is set to begin on March … [Read more...]

The SEC’s Office of Compliance Inspections and Examinations has issued a risk alert on the five most frequent compliance issues that have been identified during its examinations of investment advisers. These compliance topics are often included in deficiency letters sent to investment advisers and include Rule 206(4)-7, known as the compliance rule; required regulatory filings; Rule 206(4)-2, … [Read more...]

The House Committee on Agriculture, chaired by Chairman Mike Conaway (R-Tex), met briefly and voted unanimously to approve its oversight plan for the 115th Congress. According to the plan, the committee will engage in oversight activities with respect to the futures and derivatives industry as set forth below. Implementation of Title VII of the Dodd-Frank Act. In its review of rulemakings … [Read more...]

The SEC’s EDGAR system has been updated to simplify the annual report filing process for broker-dealers and over-the-counter derivatives dealers. In a letter to FINRA, the Division of Trading and Markets advised that under the new process, only two attachments are required where before each component of the annual report had to be uploaded as a separate document. The staff’s letter updates a … [Read more...]

Ruddy Gregory, PLLC has been shortlisted in two categories of the CTA Intelligence US Services Awards.  The CTA Intelligence US Services Awards will be an afternoon of recognition and rewards for those CTA's and managed futures service providers that have demonstrated exceptional customer service and innovative product development, over the past 12 months.   The awards ceremony will be held … [Read more...]

The CFTC requires any person that claims an exemption from CPO registration under CFTC Regulation 4.13(a)(1), 4.13(a)(2), 4.13(a)(3), 4.13(a)(5), an exclusion from CPO registration under CFTC Regulation 4.5 or an exemption from CTA registration under 4.14(a)(8) (collectively, exemption) to annually affirm the applicable notice of exemption within 60 days of the calendar year end. Persons that fail … [Read more...]

Under CFTC Regulations 4.7, 4.12 and 4.22, CPO's are required to distribute an Annual Report to each participant in the pool within 90 days of the pool's fiscal-year end. Generally, the Annual Report must be prepared by an independent public accountant.  Pools with a fiscal year end of December 31, 2016 must file Annual Report on or before March 31, 2017. To avoid potential disciplinary action for … [Read more...]