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Notice I-04-05

February 06, 2004

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. During some of our recent audits, NFA Members have suggested that we provide them with an annual reminder regarding certain requirements that are not part of their day-to-day operations. Responding to this request, NFA is pleased to send you this email listing certain requirements you have for the upcoming year. This list does not capture all of your responsibilities, but it should help remind you of certain non-routine requirements.

Within the next 12 months you will be required to:

    1. Complete the Annual Update/Questionnaire on NFA's website and pay your NFA dues on the anniversary date of your firm's registration.

    2. Complete NFA's Self-Examination Checklist.

    3. Send your firm's Privacy Policy to every current customer (in addition to sending it to every new customer when the customer opens an account).

    4. Conduct Anti-Money Laundering ("AML") training for relevant employees and complete an audit of your AML procedures and training.

    5. Test your Disaster Recovery Plan and make any necessary adjustments.

    6. Provide Ethics Training as outlined in your firm's written Ethics Training Procedures.

    7. Supervise the operations of any Branch Offices, including conducting an annual onsite audit of every Branch Office.

    8. If active in Security Future Products ("SFPs"), notify all SFP customers of NFA's BASIC system.

    9. Submit a certified annual report within 90 days after the firm's fiscal year end. IBs that are also registered as BDs must submit the report within 60 days after the firm's fiscal year end.

You will also be required to do the following more than once a year:

    1. Submit semi-annual 1-FR-IB filings via WinJammer within 17 business days of the date of the statement (in addition to completing and maintaining monthly net capital computations). IBs also registered as Broker Dealers must also file with NFA all statements required by the NASD.

    2. If active in SFPs, submit a quarterly log of any written customer complaints regarding SFPs to NFA by the 15th of the next month. You do not have to file the report if you do not receive any SFP complaints during the quarter.

We recommend that you keep this email as a reference guide to ensure that all requirements are completed on time throughout the year. As always, if you need assistance with these or any other NFA requirements, please contact NFA's Information Center at (800) 621-3570.

NFA is the premier independent provider of efficient and innovative regulatory programs that safeguard the integrity of the derivatives markets.
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