Associated Person (AP) Registration
An associated person (AP) is an individual who solicits orders, customers or customer funds (or who supervises persons so engaged) on behalf of a futures commission merchant (FCM), retail foreign exchange dealer (RFED), introducing broker (IB), commodity trading advisor (CTA) or commodity pool operator (CPO). An AP is, in effect, anyone who is a salesperson or who supervises salespersons for any of these categories of individuals or firms.
The registration requirements apply to any person in the supervisory chain-of-command and not only to persons who directly supervise the solicitations of orders, customers or funds. See NFA Notice to Members I-07-38 for more information.
Registration is generally required unless:
- The individual is already registered as an FCM, IB or Floor Broker* or
- The individual is already registered as a CPO if he or she is to be associated with a CPO or
- The individual is already registered as a CTA if he or she is to be associated with a CTA or
- The individual is already registered with the Financial Industry Regulatory Authority (FINRA) as a registered representative and limits futures activity to the solicitation of participations in a commodity pool.
*Registered Floor Brokers who intend to solicit customer business should review exchange rules to determine if there are any additional exchange requirements or limitations on activity.
For more details on AP exemptions, refer to CFTC Regulation 3.12(h).
Registration Requirements for APs
To register as an AP and become an NFA Associate Member:
- The sponsor must designate a Security Manager in order to obtain secure access to NFA's Online Registration System (ORS)
- The sponsor completes online Form 8-R for the individual
- Satisfy proficiency requirements; effective January 31, 2020, swap APs will be required to complete NFA's Swaps Proficiency Requirements by the compliance date of January 31, 2021
- Complete application verification in ORS
- Submit fingerprint cards
- If engaging in retail off-exchange forex, be sponsored by a pending or an approved forex firm
- If engaging in swaps, be sponsored by a pending or approved swap firm
- Pay non-refundable application fee of $85 (An application fee is not required if the individual is currently registered with the CFTC in any capacity or is listed as a principal of a current CFTC registrant.)