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ARTICLE · 20 JANUARY 2022

NFA Highlights Common Regulatory Deficiencies

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Common deficiencies in cybersecurity, third-party service providers and supervision were applicable to all registration groups.

United StatesFinance and Banking
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In three separate notices, NFA reminded (i) futures commission merchants, forex dealers, and introducing brokers, (ii) CPOs and CTAs, and (iii) swap dealers on reporting requirements, and common deficiencies in regulatory compliance. Common deficiencies in cybersecurity, third-party service providers and supervision were applicable to all registration groups.

Notice I-22-02 addressed futures commission merchants, forex dealer members and introducing brokers. Common deficiencies included inadequate self-examination questionnaires, failure to supervise communications and trading, inadequate review of third-party service providers and failure to adopt an information security program.

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