On May 22, 2013, NFA proposed Interpretive Notice to Rule 2-9 concerning FCMs’ internal control systems, which is in-dependent of the Commodity Futures Trading Commis-sion’s proposed rules on customer protection enhancements. The Interpretive Notice as proposed provides FCMs with minimum guidelines for establishing an internal control system and for conducting and documenting peri-odic reviews. Failure to adhere to the guidelines would be deemed a Rule 2-9 violation. Amongst other requirements, the proposed Notice requires that an FCM’s internal control system address: (a) adequate systems for separation of duties; (b) procedures for complying with customer segre-gated funds; (c) secured funds and cleared swap customer collateral requirements; (d) establishing and complying with risk management and trad-ing practices; (e) restrictions on access to commu-nication and information systems; (f) monitoring for capital compliance; and (g) establishing super-visory systems and controls. NFA’s proposed Interpretive Notice is available here.