NFA Compliance Rule 2-9 places a broad and continuing responsibility on every Member to diligently supervise its employees and agents in every aspect of their futures activities. Recognizing the differences in size and complexity of Members' business operations, NFA developed the rule to provide supervisory guidelines rather than dictate a "one size fits all" form of supervision.

NFA has also developed a Self-Examination Checklist to help Members review their operations and recognize potential problem areas where they might need to enhance their procedures. Members are required to complete this checklist on an annual basis.

In 1993, NFA expanded Rule 2-9 in an effort to prevent the deception of customers through abusive telemarketing. The Rule now includes criteria that dictate when a firm is required to implement enhanced supervisory procedures over its telemarketing activities. Very simply put, if a certain percentage of a firm's APs have worked for other firms that were disciplined for sales practice fraud, the firm has to tape record conversations that occur between their APs and both existing and potential customers. A list of disciplined firms is provided on this Web site. Access to this list is restricted to NFA Members with an Online Registration System (ORS) username and password.

For further information on this requirement, please review NFA's Interpretive Notice regarding supervision and contact NFA's Information Center at 800-621-3570 with any questions.