NFA set the effective date of September 30, 2021, for a recently adopted interpretive notice concerning members' use of third-party service providers.
As previously covered, the NFA stated firms should tailor written supervisory frameworks to their specific business activities, identifying the following specific areas to be addressed: (i) initial risk assessment, (ii) onboarding due diligence, (iii) ongoing monitoring, (iv) termination and (v) recordkeeping.
Primary Sources
- NFA Notice I-21-13: Effective Date for Interpretive Notice regarding Members' Use of Third-Party Service Providers
- NFA Interpretive Notice 9079 - NFA Compliance Rules 2-9 and 2-36: Members' Use of Third-Party Service Providers
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
