Notices to Members

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Notice I-09-05

January 15, 2009

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. Therefore, we are providing you with an annual reminder regarding certain requirements that are not part of your day-to-day operations. This list does not capture all of your responsibilities for the upcoming year, 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 process on the anniversary date of your firm's registration. This process includes (1) completing the electronic Annual Registration Update; (2) electronically submitting the firm's Annual Questionnaire on NFA's Web site and (3) paying your annual registration fees and NFA dues.

    Failure to satisfy all of the requirements in the annual update process within 30 days of your anniversary date will result in the withdrawal of your firm's NFA registration and/or Membership. Carefully check your registration record including address, contact information, and listed principals. Ensure any individual in a line of supervisory authority over Associated Persons ("APs") is also registered as an AP. For additional information on who has to register as an AP, see NFA's Notice to Members I-07-38 at

    2. Complete NFA's Self-Examination Checklist located on NFA's Web site at

    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). For guidance in preparing your policy, please consult NFA's Privacy Policy questionnaire (Appendix D of the Self-Exam Checklist).

    4. Conduct Anti-Money Laundering ("AML") training for relevant employees and complete an audit of your AML procedures and training. For guidance in preparing your AML procedures, please consult NFA's Anti-Money Laundering questionnaire (Appendix A of the Self-Exam Checklist).

    5. Test your Disaster Recovery Plan and make any necessary adjustments. For guidance in preparing your plan, please consult NFA's Business Continuity and Disaster Recovery Plan questionnaire (Appendix B of the Self-Exam Checklist).

    6. Provide Ethics Training as outlined in your firm's written Ethics Training Procedures. For guidance in developing your procedure, please consult NFA's Ethics Training Policy questionnaire (Appendix C of the Self-Exam Checklist).

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

    8. Submit a certified annual report within 90 days after the firm's fiscal year end. IBs that are also registered as Broker/Dealers ("BDs") must submit the report within 60 days after the firm's fiscal year end. IBs that are not also registered as BDs must file this certified statement via NFA's EasyFile system.

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

    Submit semi-annual 1-FR-IB filings via EasyFile within 17 business days of the date of the statement (in addition to completing and maintaining monthly net capital computations). IBs also registered as BDs may file via WinJammer and must also file with NFA all statements required by FINRA. All financial statements should be prepared using the accrual basis of accounting as required by Generally Accepted Accounting Principles.

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.

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