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January 14, 2010
Annual Regulatory Reminder for Independent Introducing Brokers
National Futures Association has always been committed to providing our Members with the resources they need to meet their regulatory obligations as efficiently as possible. Therefore, we are providing you with an annual reminder regarding certain requirements that are not part of your day-to-day operations. This list does not capture all of your responsibilities for the upcoming year, but it should help remind you of certain non-routine requirements.
Within the next 12 months you will be required to:
Failure to satisfy all of the requirements in the annual update process within 30 days of your anniversary date will result in the withdrawal of your firm's NFA registration and/or Membership. Carefully check your registration record including address, contact information, and listed principals. For a detailed explanation of who needs to listed as a principal, who needs to be registered as an Associated Person, and when it's appropriate to list a branch office and a branch office manager access NFA's Registration Issues Podcast.
2. Complete NFA's Self-Examination Checklist located on NFA's website at http://www.nfa.futures.org/NFA-compliance/publication-library/self-exam-checklist.HTML.
4. Conduct Anti-Money Laundering ("AML") training for relevant employees and complete an audit of your AML procedures and training. For guidance in preparing your AML procedures, please consult NFA's Anti-Money Laundering questionnaire (Appendix A of the Self-Exam Checklist).
5. Test your Disaster Recovery Plan and make any necessary adjustments. For guidance in preparing your plan, please consult NFA's Business Continuity and Disaster Recovery Plan questionnaire (Appendix B of the Self-Exam Checklist).
6. Provide Ethics Training as outlined in your firm's written Ethics Training Procedures. For guidance in developing your procedure, please consult NFA's Ethics Training Policy questionnaire (Appendix C of the Self-Exam Checklist).
7. Supervise the operations of any Branch Offices, including conducting an annual onsite audit of every Branch Office.
8. Submit a certified annual report within 90 days after the firm's fiscal year end. IBs that are also registered as Broker/Dealers ("BDs") must submit the report within 60 days after the firm's fiscal year end. IBs that are not also registered as BDs must file this certified statement via NFA's EasyFile system.
We recommend that you keep this email as a reference guide to ensure that all requirements are completed on time throughout the year.
We also want to remind you again to complete the new questions in the Annual Questionnaire assessing Member's futures-related and off-exchange forex business. On November 30, 2009, NFA issued Notice to Members I-09-21 requesting all Members to complete a series of new questions located in the Annual Questionnaire assessing their futures-related business. Although some NFA Members have complied with this request, many have not. It is critical that Members access and complete questions in the Firm and DR Information section of the Annual Questionnaire as soon as possible. This applies not only to Members trading on-exchange futures products but also Members trading in the off-exchange foreign currency (forex) market.
As always, if you need assistance with these or any other NFA requirements, please contact NFA's Information Center at (800) 621-3570.