Kevin Foley, a partner in the Financial Services practice, spoke with FinOps Report regarding the new Commodity Futures Trading Commission (CFTC) requirement that CFTC registrants record oral communications relating to derivatives transactions. The recording requirement applies to conversations on landlines, voice mail, cell phones and other media to help the CFTC investigate potentially illegal activity. Kevin points out that “[a]s written, the rule says that all conversations must be recorded, because one never knows when a conversation will lead to a trade. In addition, specific trades must be identified. The CFTC’s presumption is that there is some type of tagging of the trade which can occur.” (“What to Do When the CFTC Gets Into Your Phone Calls,” January 10, 2014)
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