FCM Applicants

Firms applying as a FCM have a financial filing requirement (either a Form 1-FR-FCM or a FOCUS report), which can be met in one of the following ways:  

  • A financial statement certified by an independent public accountant as of a date not more than 45 days prior to the date on which such report is filed; or
  • A financial statement as of a date not more than 17 business days prior to the date on which such report is filed and a financial statement certified by an independent public accountant as of a date not more than one year prior to the date on which such report is filed.

NFA would expect an applicant FCM's adjusted net capital to be above the early warning requirement. Applicants who cannot meet the early warning requirement are subject to additional reporting obligations until they have sufficient capital.

A firm's registration as an NFA Member FCM will not be complete until the FCM designates an individual as a Chief Compliance Officer (CCO) and lists the CCO as a principal of the FCM.

An FCM may also need to provide compliance procedures, additional documentation and written representation to NFA for review as part of the application. Such procedures, documents and representation would generally include, but are not limited to:  

As NFA is conducting a review of the firm's financial operations, NFA will often request additional items not listed above, such as bank statements, general ledger, and cancelled checks. An FCM will not be approved until NFA reviews and approves all requested items. Any of these financial or procedural items can be submitted to NFA via email at Applicants@nfa.futures.org.

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