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ARTICLE · 18 FEBRUARY 2020

NFA Reminds Members Of Recent Amendments To NFA Rules And Guidance

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NFA highlighted certain regulatory obligations and available educational resources for (i) CPO/CTAs, (ii) swap dealers ("SDs"), and (iii) futures commission merchants, forex dealer members and introducing brokers.

United StatesTechnology
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NFA highlighted certain regulatory obligations and available educational resources for (i) CPO/CTAs, (ii) swap dealers ("SDs"), and (iii) futures commission merchants ("FCMs"), forex dealer members ("FDMs") and introducing brokers ("IBs").

In several Notices, NFA identified the regulatory obligations for each type of NFA member, based off of common deficiencies during examinations.

  • CPO/CTA. In Notice I-20-05, NFA stated that CPO/CTAs must (i) adopt written information systems security programs aimed at mitigating risks such as attacks to their information technology systems, (ii) implement supervisory procedures by creating internal control systems, (iii) complete NFA's Self-Examination Questionnaire to assess their internal operations, (iv) provide written notices to pool participants within 90 days of a pool's formation if it elects a fiscal year end other than a calendar year end for financial reporting purposes, and (v) use the accrual method of accounting

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