Key takeaways

• The NFA’s Cybersecurity Interpretive Notice requires NFA member firms to adopt and enforce written policies and procedures to secure customer data and access to their electronic systems.
• This Cybersecurity Interpretive Notice will become effective on March 1, 2016, and applies to all NFA membership categories -- futures commission merchants, swap dealers, major swap participants, introducing brokers, forex dealer members, commodity pool operators and commodity trading advisors.
• Firms that are working diligently to come into compliance, but are not fully there by March 1, can likely expect a collaborative and non-punitive approach from NFA. In light of the Notice, cybersecurity is a likely topic in future examinations.