Abstract
Purpose To summarize and analyze the CFTC’s proposed enhanced cybersecurity testing rules for entities that run the core derivatives market infrastructure. Design/methodology/approach This article discusses the CFTC’s proposed rulemaking related to cybersecurity testing, including enhanced cybersecurity testing requirements and guidance on risk analysis and oversight programs, as well as industry commentary on such rulemaking. Findings This article finds that the CFTC’s recent proposed rulemaking has been met with approval generally by industry participants, and is part of a broader effort to protect against cybersecurity threats that may affect the functioning of financial markets. Originality/value Practical guidance from experienced futures and derivatives lawyers.
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