Four Cybersecurity Ideas From CFTC Commissioner Bowen

On Sept. 17, 2015, Commissioner Sharon Y. Bowen of the U.S. Commodity Futures Trading Commission (CFTC) gave the keynote address for the International Swaps and Derivatives Association's 2015 North American Conference in New York. Commissioner Bowen reminded the audience of the National Futures Association's (NFA's) recent proposed cybersecurity interpretative notice that would require swap dealers, major swap participants, futures commission merchants, commodity trading advisors, commodity pool operators and introducing brokers to establish, maintain and follow written information system security programs (ISSPs). The NFA's proposed ISSPs would require member firms to establish and implement a risk governance framework, perform security and risk analyses of its information technology systems, and provide ongoing training for personnel on information security. While the NFA's proposed ISSPs are consistent with cybersecurity programs already imposed on many financial