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The Examination Process

NFA conducts periodic on-site examinations of its Member firms. The examinations are meant to support your firm's commitment to meet its regulatory obligations. During an examination of your firm, NFA examiners will communicate with your firm throughout the examination process. It is important for your firm to maintain accurate information in your firm's Annual Questionnaire. NFA requires that you complete the Annual Questionnaire every 12 months. However, if your customer base or business significantly changes more frequently, we encourage you to update the information accordingly.

Listen to NFA's podcast "Preparing for an NFA Audit" to learn more about the examination process and some tips for how to prepare an NFA examination. NFA announces nearly all of its examinations. During examinations, you'll encounter a lot of questions as our examiners are ensuring that they are clear in understanding your firm's operations.

How to make the examination process faster for you and your firm:

  • NFA examiners will send your firm a document request list when they are preparing to examine your firm. The document request list will show what documents the NFA examiners will require for their review upon arrival. If you have any questions about the documents requested by the examination team, we encourage you to contact your examiners in advance.
  • NFA examiners will look at your cash records (bank statements, cancelled checks, check registers, wire advices, and deposit slips). Maintaining these documents in a central location for all accounts, not just the operating account, helps the examination process.
  • CPOs and CTAs should have their performance-related spreadsheets and calculations available for NFA examiners, as well as the person who prepares these for your firm.
  • Independent Introducing Brokers should maintain a general ledger, balance sheet, net capital computation and all supporting documents as of each month end and have available for review.

Tip: If you use third party service providers and will need their assistance to answer the examiners' questions, make arrangements to have the service providers available during fieldwork for conference calls.

Educational Examination

New Members may request an educational examination or visit by NFA, voluntarily and free of charge. If an educational examination is conducted on your firm, the following areas will be reviewed:

  • All registration categories: procedures, contact information, registration of personnel, promotional materials
  • Introducing Brokers: financials, anti-money laundering procedures
  • Commodity Pool Operators: account statements, customer recordkeeping, disclosure documents
  • Commodity Trading Advisors: customer recordkeeping, disclosure documents
NFA is the premier independent provider of efficient and innovative regulatory programs that safeguard the integrity of the derivatives markets.
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