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 amendments to:
- NFA Financial Requirements Section 11 and 12;
- NFA interpretive notice regarding supervision of branch offices and guaranteed IBs;
- NFA Compliance Rule 2-29 and 2-36 and related interpretive notices regarding communications with the public and promotional material; and
- NFA Compliance Rules 2-8 and 2-30 and related interpretive notices regarding bunched orders.
Substantive RevisionsSection: General Self-Examination Questionnaire for All Members
Section: Supplemental Questionnaire for FDMs
- 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)
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 RevisionsReview these entire subsections in the Self-Examination Questionnaire for the changes.
Section: General Self-Examination Questionnaire for All Members
- Revised to reflect amendments to Interpretive Notice 9019.
Subsection: Promotional Material
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.
- Revised to eliminate the approval request process for affiliates as NFA no longer allows the use of affiliates under NFA Financial Requirements Section 11.