As 2021 comes to a close, staff will begin leaving for holiday vacation and compliance will be forgotten.  Turnkey Trading Partners always likes to remind our clients to consider annual compliance deadlines and obligations.  This year saw both the Commodity Futures Trading Commission (“CFTC”) as well as National Futures Association (“NFA”) roll out a number of new compliance and regulatory changes.  They also increased enforcement efforts and have been significantly more active with audits than they have in previous years.

2021 NFA Annual Obligations

  1. Update/Review Compliance Manual as applicable
  2. Annual privacy notice to customers (consider changes to policy)
  3. For IB’s update and obtain New FCM AML reliance agreements.
  4. Complete NFA’s Annual Questionnaire  
  5. Pay NFA Dues and update all registration information
  6. Complete NFA’s Self-Examination Questionnaire  for main office and branch offices
  7. Ensure branch and GIB locations have been audited within the calendar year (call Turnkey for help!)
  8. Conduct all trainings necessary such as Anti-Money Laundering (“AML”), Ethics, Cybersecurity, Identity Theft training for relevant employee
  9. Test your Cyber Security and Disaster Recovery Plan and make any necessary adjustments.
  10. Implement Third – Party Service Provider Policies and Risk Assessment

If you have any questions or concerns with your compliance program, please contact Turnkey today via (312) 324-0040 or by clicking here. Our team can conduct mock audits for your firm and fully assist with ensuring 2022 is your best year of compliance yet.


2021 Year In Review

If you have not done so sign up for Turnkey’s Newsletter which is sent monthly. We don’t sell or share customer information and we provide industry leading CFTC and NFA compliance content each month. The following are articles we have written in 2021 who’s topics range across new approaches from regulators, how Covid-19 has impacted your compliance obligations and unprecedented market events:

Starting a Hedge Fund or Trading Investment Advisor

How to Start a Profitable CTA

Branch Office Supervision Post-Covid: The “Next-Normal”

CFTC, NFA Third Party Service Provider Obligations

The End of CFTC/NFA Remote Work?

Navigating the Semi-Regulated Cryptocurrency Market

Do Your Books and Records Meet Regulatory Expectations and Guidelines?

NFA Proposes Branch Office Definition Changes

CFTC Cryptocurrency Crackdown

Avoiding Accounting Pitfalls