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December 05, 2006
Introducing Broker Certified Financial Statements to be Filed Electronically
Effective December 22, 2006, all independent IBs who are not broker-dealers must file their certified financial statements electronically using EasyFile. For most IBs, their first filing will be the certified statement for the fiscal year ending December 31, 2006, which is due April 2, 2007.
To file with NFA, the IB will create a pdf document consisting of the entire certified statement (including the financial information, footnotes, auditors' statement, and the reconciliation if one is necessary). The person responsible for filing the IB's financial statements will log on to EasyFile in the usual way and upload the pdf version of the certified statement. Since the IB will have already entered the detailed figures from the unaudited Form 1-FR-IB into the system, the IB will not have to enter the figures from the certified statement unless that statement includes a reconciliation.
Each IB must keep the original signed certified financial report in its own files for the period required by CFTC Regulation 1.31. It will not have to send a physical copy to either NFA or the CFTC, however.
These requirements do not apply to broker-dealer IBs since EasyFile is not currently equipped to handle FOCUS reports. We hope to add this capability to EasyFile in the future. Until then, broker-dealer IBs must continue to file their certified FOCUS reports manually.
Questions concerning these requirements should be directed to John Brodersen, Associate Director, Compliance, (firstname.lastname@example.org or 312-781-2226) or Tracey Hunt, Senior Manager, Compliance (email@example.com or 312-658-6835).