NFA Compliance Rules 2-9, 2-23 and 2-36 place a continuing responsibility on each Member to diligently supervise its employees and agents in the conduct of their commodity interest activities. NFA recognizes that, given the differences in the size and complexity of NFA Members' operations, there must be some degree of flexibility in determining what constitutes diligent supervision for each firm. NFA expects that Members' supervisory programs will vary, and NFA's policy is to provide firms with flexibility to develop and implement procedures that are tailored to their operations. Effective supervisory oversight begins with a due diligence review and ensuring personnel are adequately trained to follow industry rules and regulations, properly handle customer accounts, and satisfy ethics training requirements, among other duties.
See NFA's regulatory guide—NFA Regulatory Requirements for FCMs, IBs, CPOs and CTAs.NFA Regulatory Guide