Just a quick note that we had an article published in the June issue of the NIBA Journal titled How will the Proposed Swaps Regulations Affect IBs? In the article we discuss how the OTC derivatives regulations have essentially overshadowed some of the CFTC's other rulemaking initiatives like Proposed Regulation 1.71.  Proposed Regulation 1.71 would essentially require certain CFTC registered firms, inc

luding introducing brokers, to implement certain compliance procedures to separate research activities from execution activities.  Proposed Regulation 1.71 has not yet been finalized by the CFTC and we provide updates if new rules are adopted.

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Cole-Frieman & Mallon LLP provides legal services to the managed futures industry including CTA, CPO, and Introducing Broker registration and compliance services.  Bart Mallon can be reached directly at 415-868-5345.