Am I required to have procedures for complying with Bylaw 1101?

Yes. The procedures should include 1) the steps firm personnel will take to determine if an entity is required to be registered with the CFTC and to be an NFA Member and 2) a requirement that firm personnel review BASIC to verify that the entity is registered and an NFA Member (if registration and membership are required). The procedures should also require firm personnel to document the review and maintain the documentation.