Notices to Members

September 26, 2024

Member action required: Effective date for NFA Rule modifying Member Questionnaire requirements

NFA Compliance Rule 2-52 and its related Interpretive Notice entitled NFA Member Questionnaire Requirements become effective on October 15, 2024 (see Notice to Members I-24-10). Currently, all NFA Members complete the Questionnaire as part of NFA's membership application and annual renewal process. Compliance Rule 2-52 will require NFA Members to submit the Questionnaire at least annually and more frequently in certain instances as required by NFA. Additionally, the Rule sets forth specific requirements regarding who at a firm must review and submit the Questionnaire.

The Rule requires that the Member Questionnaire for a swap dealer-only Member be reviewed and submitted by an individual who is a principal of the swap dealer and that the Member Questionnaire for any other Member be submitted by an individual who is an associated person and principal of the Member (Qualified Individual). To designate a Qualified Individual(s) to submit the Member Questionnaire, each Member must assign the individual(s) "Enter and Submit" Questionnaire access in NFA's Online Registration System (ORS). For instructions on how to assign "Enter and Submit" Questionnaire access, see Notice to Members I-24-14.

Every Member must assign "Enter and Submit" access to at least one Qualified Individual. Individuals currently designated in ORS to submit the Questionnaire on a Member's behalf will no longer be able to submit the Questionnaire beginning on October 15, 2024, unless the Member completes steps necessary to assign the individual "Enter and Submit" Questionnaire access.

If you have any questions on assigning appropriate access in ORS, please contact NFA's Information Center (information@nfa.futures.org or 312-781-1410 or 800-621-3570). For questions regarding NFA Compliance Rule 2-52, please contact Tracey Hunt, Director, Futures Compliance (thunt@nfa.futures.org or 312-781-1284).