FCM Reporting Requirements
Note: This is not an all-inclusive list of reporting requirements. Please review NFA's rules and the CFTC's regulations for additional reporting requirements.
Segregated Funds Statement(1)
An FCM must inform NFA prior to holding customer funds
(NFA Compliance Rule 2-11)
When
Daily, due by noon on the next business day
Daily, due by noon on the next business day
Information Required
Statement of Segregation Requirements and Funds in Segregation for Customers Trading on U.S. Commodity Exchanges—See CFTC Regulation 1.32 for further information. Qualifying institutions holding segregated assets must report the balances in the firm's account(s) held at the qualifying institution to NFA on a daily basis. See NFA Financial Requirement Section 4 for further information.
Statement of Segregation Requirements and Funds in Segregation for Customers Trading on U.S. Commodity Exchanges—See CFTC Regulation 1.32 for further information. Qualifying institutions holding segregated assets must report the balances in the firm's account(s) held at the qualifying institution to NFA on a daily basis. See NFA Financial Requirement Section 4 for further information.
How to file
WinJammerTM
WinJammerTM
Secured Amounts Statement(1), if applicable
When
Daily, due by noon on the next business day
Daily, due by noon on the next business day
Information Required
Statement of Secured Amounts and Funds Held in Separate Accounts for 30.7 Customers Pursuant to Commission Regulation 30.7—See CFTC Regulation 30.7(l) for further information. Qualifying institutions holding secured assets must report the balances in the firm's account(s) held at the qualifying institution to NFA on a daily basis. See NFA Financial Requirement Section 4 for further information.
Statement of Secured Amounts and Funds Held in Separate Accounts for 30.7 Customers Pursuant to Commission Regulation 30.7—See CFTC Regulation 30.7(l) for further information. Qualifying institutions holding secured assets must report the balances in the firm's account(s) held at the qualifying institution to NFA on a daily basis. See NFA Financial Requirement Section 4 for further information.
How to file
WinJammerTM
WinJammerTM
Cleared Swaps Customer Collateral Statement(1) (if applicable)
When
Daily, due by noon on the next business day
Daily, due by noon on the next business day
Information Required
Statement of Cleared Swaps Customer Segregation Requirements and Funds in Cleared Swaps Customer Accounts under 4d(f) of the Commodity Exchange Act (CEA) — See CFTC Regulation 22.2(g) for further information. Qualifying institutions holding cleared swaps assets must report the balances in the firm's account(s) held at the qualifying institution to NFA on a daily basis. See NFA Financial Requirement Section 4 for further information.
Statement of Cleared Swaps Customer Segregation Requirements and Funds in Cleared Swaps Customer Accounts under 4d(f) of the Commodity Exchange Act (CEA) — See CFTC Regulation 22.2(g) for further information. Qualifying institutions holding cleared swaps assets must report the balances in the firm's account(s) held at the qualifying institution to NFA on a daily basis. See NFA Financial Requirement Section 4 for further information.
How to file
WinJammerTM
WinJammerTM
Segregated Investment Detail Report (SIDR)(1)
When
Semi-monthly, due by 11:59p.m. on the first business day after the last business day of month end and due by 11:59 pm. on the 16th (or the following business day if the 15th falls on a weekend)
Semi-monthly, due by 11:59p.m. on the first business day after the last business day of month end and due by 11:59 pm. on the 16th (or the following business day if the 15th falls on a weekend)
Information Required
Detailed breakdown of customer funds held and invested, including identification of all depositories. See CFTC Regulation 1.32 for further information.
Detailed breakdown of customer funds held and invested, including identification of all depositories. See CFTC Regulation 1.32 for further information.
Financial Reports - Unaudited
When
Monthly, due within 17 business days of month end
Monthly, due within 17 business days of month end
Information Required
See CFTC Regulation 1.10 for further information.
See CFTC Regulation 1.10 for further information.
How to file
WinJammerTM
WinJammerTM
Certified Financial Reports - Audited
When
Annually, due within 60 days after fiscal year end
Annually, due within 60 days after fiscal year end
How to file
WinJammerTM
WinJammerTM
Capital is less than early warning amount/eligibility to guarantee IBs
WhenIf applicable
Information Required
Immediate notification when adjusted net capital falls below amount required in NFA Financial Requirements Section 1 or another amount required by an SRO for which the firm is subject to. See CFTC Regulation 1.12(a).
Immediate notification when adjusted net capital falls below amount required in NFA Financial Requirements Section 1 or another amount required by an SRO for which the firm is subject to. See CFTC Regulation 1.12(a).
How to file
WinJammerTM
WinJammerTM
Failure to keep current books and records
When
If applicable
If applicable
Information Required
Same day notification. Written report stating corrective action due within 48 hours. See CFTC Regulation 1.12(c).
Same day notification. Written report stating corrective action due within 48 hours. See CFTC Regulation 1.12(c).
How to file
WinJammerTM
WinJammerTM
Material inadequacies noted by CPA in audited financials
When
If applicable
If applicable
Information Required
Notification within 24 hours. Written report stating corrective action due within 48 hours. See CFTC Regulation 1.12(d).
Notification within 24 hours. Written report stating corrective action due within 48 hours. See CFTC Regulation 1.12(d).
How to file
WinJammerTM
WinJammerTM
Omnibus account restriction(1)
When
If applicable
If applicable
Information Required
Immediate notification required when a trading account carried for another FCM must be liquidated or transferred immediately due to the account's failure to meet a margin call. See CFTC Regulation 1.12(f)(2)
Immediate notification required when a trading account carried for another FCM must be liquidated or transferred immediately due to the account's failure to meet a margin call. See CFTC Regulation 1.12(f)(2)
How to file
WinJammerTM
WinJammerTM
Margin deficiency exceeds adjusted net capital
When
If applicable
If applicable
Information Required
Immediate notification when an account is undermargined by an amount greater than the FCM's adjusted net capital. See CFTC Regulation 1.12(f)(3).
Immediate notification when an account is undermargined by an amount greater than the FCM's adjusted net capital. See CFTC Regulation 1.12(f)(3).
How to file
WinJammerTM
WinJammerTM
Margin call exceeds excess adjusted net capital
When
If applicable
If applicable
Information Required
Immediate notification is required when an account is subject to a margin call, or call for other deposits required by the FCM, that exceeds the FCM's excess adjusted net capital and the call is not satisfied by the close of business on the day following the issuance of the call. See CFTC Regulation 1.12(f)(4).
Immediate notification is required when an account is subject to a margin call, or call for other deposits required by the FCM, that exceeds the FCM's excess adjusted net capital and the call is not satisfied by the close of business on the day following the issuance of the call. See CFTC Regulation 1.12(f)(4).
How to file
WinJammer TM
WinJammer TM
Maintenance margin requirement exceeds excess adjusted net capital
When
If applicable
If applicable
Information Required
Immediate notification is required when six percent of the maintenance margin requirements for all non- customer positions exceeds the FCM's excess adjusted net capital. See CFTC Regulation 1.12(f)(5).
Immediate notification is required when six percent of the maintenance margin requirements for all non- customer positions exceeds the FCM's excess adjusted net capital. See CFTC Regulation 1.12(f)(5).
How to file
WinJammerTM
WinJammerTM
Reduction in net capital of 20% or more
When
If applicable
If applicable
Information Required
Within two business days of the reduction, including reasons and steps being taken to ensure an appropriate level of net capital is maintained. See CFTC Regulation 1.12(g)(1).
Within two business days of the reduction, including reasons and steps being taken to ensure an appropriate level of net capital is maintained. See CFTC Regulation 1.12(g)(1).
How to file
WinJammer TM
WinJammer TM
Withdrawal of equity capital of 30% or more of excess net capital
When
If applicable
If applicable
Information Required
Within two business days of the reduction. See CFTC Regulation 1.12(g)(2).
Within two business days of the reduction. See CFTC Regulation 1.12(g)(2).
How to file
WinJammer TM
WinJammer TM
Customer funds held are less than amount required(1)
When
If applicable
If applicable
Information Required
Immediate notification when segregated funds, secured funds, or cleared swaps funds on deposit are less than amounts required. See CFTC Regulation 1.12(h).
Immediate notification when segregated funds, secured funds, or cleared swaps funds on deposit are less than amounts required. See CFTC Regulation 1.12(h).
How to file
WinJammer TM
WinJammer TM
Investment of customer funds violation(1)
When
If applicable
If applicable
Information Required
Immediate notification required if customer funds are not invested in accordance with CFTC Regulation 1.25. See CFTC Regulation 1.12(i).
Immediate notification required if customer funds are not invested in accordance with CFTC Regulation 1.25. See CFTC Regulation 1.12(i).
How to file
WinJammer TM
WinJammer TM
Customer funds held are less than targeted residual interest or the sum of the undermargined amounts(1)
When
If applicable
If applicable
Information Required
Immediate notification required if the FCM's excess segregated, secured, or customer cleared swaps funds held are less than the FCM's targeted residual interest or the sum of the undermargined amounts in its customer accounts, as determined at the point in time that the firm is required to maintain the sum of the undermargined amounts. See CFTC Regulation 1.12(j).
Immediate notification required if the FCM's excess segregated, secured, or customer cleared swaps funds held are less than the FCM's targeted residual interest or the sum of the undermargined amounts in its customer accounts, as determined at the point in time that the firm is required to maintain the sum of the undermargined amounts. See CFTC Regulation 1.12(j).
How to file
WinJammer TM
WinJammer TM
Material adverse event
When
If applicable
If applicable
Information Required
Immediate notification required if the FCM, FCM's parent or material affiliate experiences a material adverse impact to its creditworthiness or ability to fund its obligations, including any change that could adversely impact the firm's liquidity resources. See CFTC Regulation 1.12(k).
Immediate notification required if the FCM, FCM's parent or material affiliate experiences a material adverse impact to its creditworthiness or ability to fund its obligations, including any change that could adversely impact the firm's liquidity resources. See CFTC Regulation 1.12(k).
How to file
WinJammer TM
WinJammer TM
Material change in operations
When
If applicable
If applicable
Information Required
Notification required within 24 hours if the FCM experiences a material change in operations or risk profile, including a change in the senior management of the FCM, the establishment or termination of a line of business, or a material adverse change in the FCM's clearing arrangements. See CFTC Regulation1.12(l).
Notification required within 24 hours if the FCM experiences a material change in operations or risk profile, including a change in the senior management of the FCM, the establishment or termination of a line of business, or a material adverse change in the FCM's clearing arrangements. See CFTC Regulation1.12(l).
How to file
WinJammer TM
WinJammer TM
Other regulatory matters
When
If applicable
If applicable
Information Required
Notification required within 24 hours if the FCM is notified it is the subject of a formal investigation by the SEC, a securities SRO, or futures SRO. The FCM must provide a copy of any examination report issued to the FCM by the SEC or a securities SRO. The FCM must also provide notice of any correspondence received from the SEC or a securities SRO that raises issues with the adequacy of the FCM's capital position, liquidity to meet its obligations or otherwise operate its business or internal controls. See CFTC Regulation 1.12(m).
Notification required within 24 hours if the FCM is notified it is the subject of a formal investigation by the SEC, a securities SRO, or futures SRO. The FCM must provide a copy of any examination report issued to the FCM by the SEC or a securities SRO. The FCM must also provide notice of any correspondence received from the SEC or a securities SRO that raises issues with the adequacy of the FCM's capital position, liquidity to meet its obligations or otherwise operate its business or internal controls. See CFTC Regulation 1.12(m).
How to file
WinJammer TM
WinJammer TM
Disbursement of funds which exceeds 25% of the FCM's residual interest
When
If applicable
If applicable
Information Required
Immediate notification is required for withdrawals that would exceed 25% of the FCM's residual interest in segregated, secured, or cleared swaps funds accounts, respectively. See NFA Financial Requirements Section 16, its related Interpretive Notice 9066 and CFTC Regulations 1.12(d), 1.23, 22.17(c), and 30.7(g) for further information.
Immediate notification is required for withdrawals that would exceed 25% of the FCM's residual interest in segregated, secured, or cleared swaps funds accounts, respectively. See NFA Financial Requirements Section 16, its related Interpretive Notice 9066 and CFTC Regulations 1.12(d), 1.23, 22.17(c), and 30.7(g) for further information.
How to file
WinJammerTM
WinJammerTM
Cybersecurity Incident(3)
When
If applicable
If applicable
Information Required
Prompt notification is required for certain cybersecurity incidents. See NFA Interpretive Notice 9070 for further information.
Prompt notification is required for certain cybersecurity incidents. See NFA Interpretive Notice 9070 for further information.
Depository Acknowledgment Letters(1)
When
As applicable (submitted upon new or change in accounts)
As applicable (submitted upon new or change in accounts)
Information Required
Within three business days of opening a customer funds account the FCM must file a copy of the executed acknowledgement letter. Within 120 days of any change in account number, name, or business address of any party subject to the letter, a new acknowledgment letter must also be submitted. See CFTC Regulations 1.20(d), 1.26, 22.5, and 30.7(d) for further information.
Within three business days of opening a customer funds account the FCM must file a copy of the executed acknowledgement letter. Within 120 days of any change in account number, name, or business address of any party subject to the letter, a new acknowledgment letter must also be submitted. See CFTC Regulations 1.20(d), 1.26, 22.5, and 30.7(d) for further information.
Risk Assessment Reports
When
Annually and whenever a material change occurs
Annually and whenever a material change occurs
Information Required
Certain information, such as organizational charts and financial and operational policies and procedures, shall be filed 60 days after the FCM's effective date of registration and thereafter, 60 days after the end of the quarter in which a change has occurred. Other information, including fiscal year- end consolidated financial statements for certain affiliates shall be filed within 105 calendar days after the end of each fiscal year. See CFTC Regulation 1.15 for further information.
Certain information, such as organizational charts and financial and operational policies and procedures, shall be filed 60 days after the FCM's effective date of registration and thereafter, 60 days after the end of the quarter in which a change has occurred. Other information, including fiscal year- end consolidated financial statements for certain affiliates shall be filed within 105 calendar days after the end of each fiscal year. See CFTC Regulation 1.15 for further information.
How to file
WinJammerTM
WinJammerTM
Risk Managment Program(1)
When
As applicable (submitted upon registration and thereafter upon request)
As applicable (submitted upon registration and thereafter upon request)
Information Required
Policies and procedures designed to monitor and manage the risks associated with the activities of the FCM. See CFTC Regulation 1.11 for further information.
Policies and procedures designed to monitor and manage the risks associated with the activities of the FCM. See CFTC Regulation 1.11 for further information.
How to file
WinJammerTM
WinJammerTM
Risk Exposure Reports(1)
When
Quarterly and whenever a material change occurs
Quarterly and whenever a material change occurs
Information Required
Report must be filed within five business days of providing to the FCM's senior management. See CFTC Regulation 1.11(e)(2) for further information.
Report must be filed within five business days of providing to the FCM's senior management. See CFTC Regulation 1.11(e)(2) for further information.
How to file
WinJammerTM
WinJammerTM
Chief Compliance Officer Report
When
Annually
Annually
Information Required
Report must be filed within 90 days after the end of the fiscal year. See CFTC Regulation 3.3(e) for further information.
Report must be filed within 90 days after the end of the fiscal year. See CFTC Regulation 3.3(e) for further information.
How to file
WinJammer TM
WinJammer TM
Request to change fiscal year end or for an extension of time to file financial reports
When
If applicable
If applicable
Information Required
Request must be filed with the designated self-regulatory organization (DSRO). The DSRO's response, along with the original request, must be filed with the firm's regional CFTC office. For firms also registered as a broker/dealer, the original request and response from the firms' designated examining authority (DEA) must be filed with DSRO and regional CFTC office. See CFTC Regulations 1.10(e)(2) and 1.10(f) for further information.
Request must be filed with the designated self-regulatory organization (DSRO). The DSRO's response, along with the original request, must be filed with the firm's regional CFTC office. For firms also registered as a broker/dealer, the original request and response from the firms' designated examining authority (DEA) must be filed with DSRO and regional CFTC office. See CFTC Regulations 1.10(e)(2) and 1.10(f) for further information.
How to file
WinJammerTM
WinJammerTM
Replacement of accountant
When
If applicable
If applicable
Information Required
Within 15 business days of changing its independent public accountant the FCM must file written notice. See CFTC Regulation 1.16(g) for further information.
Within 15 business days of changing its independent public accountant the FCM must file written notice. See CFTC Regulation 1.16(g) for further information.
How to file
WinJammerTM
WinJammerTM
Bulk transfers
When
If applicable
If applicable
Information Required
At least 10 business days in advance of a transfer, the FCM must provide notice under certain conditions. See CFTC Regulation 1.65 for further details.
At least 10 business days in advance of a transfer, the FCM must provide notice under certain conditions. See CFTC Regulation 1.65 for further details.
How to file
WinJammerTM
WinJammerTM
NFA Questionnaire
When
Annually, to coincide with annual dues
Annually, to coincide with annual dues
Information Required
Standard forms are available from NFA. The loan and all changes and amendments must be approved before the effective date. For firms also registered as a broker/dealer, any approval from the firm's DEA should also be filed. See CFTC Regulation 1.17(h) for further information.
Standard forms are available from NFA. The loan and all changes and amendments must be approved before the effective date. For firms also registered as a broker/dealer, any approval from the firm's DEA should also be filed. See CFTC Regulation 1.17(h) for further information.
How to file
NFA Website – Annual Questionnaire
NFA Website – Annual Questionnaire
Subordinated Loan Agreements
When
If applicable
If applicable
Information Required
Standard forms are available from NFA. The loan and all changes and amendments must be approved before the effective date. For firms also registered as a broker/dealer, any approval from the firm's DEA should also be filed. See CFTC Regulation 1.17(h) for further information.
Standard forms are available from NFA. The loan and all changes and amendments must be approved before the effective date. For firms also registered as a broker/dealer, any approval from the firm's DEA should also be filed. See CFTC Regulation 1.17(h) for further information.
How to file
WinJammerTM
Contact DSRO for required submission method and other additional information that may be required.
WinJammerTM
Contact DSRO for required submission method and other additional information that may be required.
Reportable Positions(1)
When
Annually, to coincide with annual dues
Annually, to coincide with annual dues
Information Required
See CFTC Regulation 15.03 for the specific quantities and CFTC Regulations Part 17, and 18 and NFA Financial Requirements Section 9 for further information.
See CFTC Regulation 15.03 for the specific quantities and CFTC Regulations Part 17, and 18 and NFA Financial Requirements Section 9 for further information.
How to file
CFTC Large Trader Reporting Program
CFTC Large Trader Reporting Program
1 Not required for FCMs doing business on a fully disclosed basis.
2 Every notice must include a discussion of how the reporting event originated and what steps have been, or are being taken, to address the reporting event. If the FCM is also registered as a broker/dealer, the notice must be filed with the SEC as well.
3 FCM-only Members for which NFA is not the DSRO need not provide copies of notices to NFA.
For further information, see NFA Rulebook and CFTC Regulations.
If the FCM is currently offering off-exchange foreign currency transactions and also registered as a Forex Dealer Member, please see RFED Reporting Requirements for additional filings that may be necessary.