Self-Examination Questionnaire For FCMs, FDMs, IBs, CPOs and CTAs (Revision Notes)

Note: Members must review the entire Self-Examination Questionnaire on an annual basis.

In this revised version of the Self-Examination Questionnaire, NFA updated the Questionnaire to incorporate:

Substantive Revisions

Section: Supplemental Questionnaire for CPOs
Subsection: Financials

  • Revised to reflect CPO Member requirements to file NFA Form PQR within 60 days of each calendar quarter end; and
  • Added clarification on calculating the quarterly ratios reported on the CPO Form PQR.

Section: Supplemental Questionnaire for CTAs
Subsection: Financials

  • Added clarification on calculating the quarterly ratios reported on the CTA Form PR.

In this revised version of the Self-Examination Questionnaire, NFA updated the Questionnaire to incorporate:

Substantive Revisions

Section: General Self-Examination Questionnaire for All Members
Subsection: Use of Third-Party Service Providers

  • Added to indicate that each Member outsourcing regulatory functions must adopt and implement a supervisory framework over its outsourcing function to mitigate outsourcing-related risks. (Interpretive Notice 9079)

In this revised version of the Self-Examination Questionnaire, NFA updated the Questionnaire to incorporate:

Substantive Revisions

Section: Supplemental Questionnaire for CPOs
Subsection: Financial

  • Revised to reflect uniform quarterly reporting for CFTC Form CPO-PQR for all CPOs, regardless of assets under management; the elimination of substituted compliance for dually registered CPO investment advisers filing joint Form PF in lieu of CFTC Form CPO-PQR; and permitting CPOs to file NFA Form PQR in lieu of the revised CFTC Form CPO-PQR.

In this revised version of the Self-Examination Questionnaire, NFA updated the Questionnaire to incorporate amendments to:

Substantive Revisions

Section: General Self-Examination Questionnaire for All Members
Subsection: Supervision
Section: Supplemental Questionnaire for FDMs
Subsection: Supervision

  • Revised to indicate that, under certain circumstances, a Member firm that supervises one or more branch offices and/or guaranteed IBs can perform an on-site inspection every other year, instead of every year. (Interpretive Notice 9019)
Section: Supplemental Questionnaire for FCMs
Subsection: Discretionary Trading and Bunched Orders
Section: Supplemental Questionnaire for IBs
Subsection: Post-Execution Allocation of Bunched Orders

  • Revised to clarify that the average pricing of a bunched order may be rounded to the next price increment as long as cash residuals greater than a penny are paid to relevant customers. (Interpretive Notice 9029)

Non-substantive Revisions

Review these entire subsections in the Self-Examination Questionnaire for the changes.

Section: General Self-Examination Questionnaire for All Members
Subsection: Supervision

Section: General Self-Examination Questionnaire for All Members
Subsection: Promotional Material

Section: General Self-Examination Questionnaire for All Members
Subsection: Website, Social Media, other Internet-Based Forums and Electronic Communications

  • Combined previous E-mail subsection with previous Websites, Social Media and other Internet-Based Forums subsection along with relevant additions and deletions to reflect amendments to NFA Compliance Rule 2-29 and 2-36, and related interpretive notices.
Section: Supplemental Questionnaire for FDMs
Subsection: Financial